Open consultation

Improving Property Income Data Reporting — Design and Implementation

Published 28 October 2026

Summary

Subject of this consultation

The government has decided to modernise how property income data is collected and reported to HMRC through the new framework established by Schedule 23 of Finance Act 2026. This consultation seeks views on the design and implementation of those reforms to ensure they are proportionate, practical and effective. The objective is to enable HMRC to make better use of the data to support taxpayers to get their tax right the first time, while reducing the tax gap and improving the efficiency of tax administration.

Scope of this consultation

This consultation considers the detailed design and implementation of improvements to the quality of specific data already acquired under HMRC’s data-gathering powers provided by Schedule 23 of Finance Act 2011. The datasets in scope are those relating to:

• letting agent data — rental income data provided by letting agents

• tenancy deposits — tenancy deposit data provided by tenancy deposit protection schemes

The government recognises that these reforms will create new obligations for a large and varied population of letting agents, including businesses that do not currently report to HMRC. Through this consultation, the government seeks views on how future requirements can be designed proportionately, with appropriate lead-in time, guidance, and support to ensure the proposals achieve their objectives while minimising new burdens.

Who should read this

We welcome engagement from third parties, particularly those data suppliers in scope of this consultation (letting agents and tenancy deposit protection scheme providers).

The government also welcomes engagement from any taxpayer or interested party with views on the reform of these datasets and safeguards. This is likely to be of particular interest to membership and professional bodies for the property sector, tax agents, tax professionals, legal professionals, software providers, intermediaries, financial advisers and their clients.

We would also be interested in hearing from stakeholders with a wider view on how government uses data and information to administer public services.

Duration

The consultation runs from 28 October 2026 to 20 January 2027.

Lead officials

The lead officials for this consultation are T. Hyde and E. Wilkes of HM Revenue and Customs (HMRC).

How to respond or enquire about this consultation

Any responses or queries about this consultation should be emailed to thirdpartydata@hmrc.gov.uk

Additional ways to be involved

The government welcomes collaboration with a wide range of stakeholders and will organise stakeholder discussions to ensure that views are heard from across the range of sectors who interact with the tax system. Please contact HMRC using the details above if you would like to be involved.

After the consultation

Responses and engagement with this consultation will help inform policy and legislative changes for how property income data will be acquired from third parties to reduce administrative burdens on HMRC, taxpayers and third parties, and to help close the tax gap.

Getting to this stage

This consultation builds on the previous government consultation on improving how HMRC acquires third-party data. The 2025 consultation, Better use of new and improved third-party data to make it easier to pay tax right the first time listed Rent and Other Payments arising from Land and Property (ROPL – letting agent data) and tenancy deposit protection scheme data alongside questions about extending reforms to dividend and investment income. Many of the issues identified in financial account information and card sales data also apply to these data sets.

Previous engagement

HMRC has begun engaging with industry stakeholders, including representative bodies for letting agents and tenancy deposit protection schemes, to improve its understanding of existing data holdings, operational practices and potential impacts of reform.

HMRC has collected dividend data from a small number of investment platforms during 2026 to progress potential reforms of dividend income data. The analysis of this data will inform the next steps of the policy for dividend income.

Executive Summary

The effective collection and use of data from third parties is an essential part of the reform and modernisation of the tax and customs system.  As set out in the 2025 consultation Better use of new and improved third-party data to make it easier to pay tax right the first time, the government has taken a phased approach to reform, with the first two improved datasets (merchant acquirer data and interest income data) introduced under the new powers in Schedule 23 of Finance Act 2026, due to be implemented in 2028. This second phase of reforms will introduce two further datasets: property data and dividend income data.

Dividend income was included in the previous consultation and HMRC has since been running a small pilot exercise with investment platforms. An update will be provided at a later stage on next steps to implement this new dataset.  

The government is now consulting on planned reforms to improve the quality and usability of third-party data relating to property income. The reforms will apply to information provided by letting agents and tenancy deposit protection schemes. They are part of the government’s wider programme to modernise how HMRC receives and uses third-party data to support taxpayers to get their tax right the first time, in order to reduce the tax gap and improve the efficiency of tax administration. This consultation seeks views on the detailed design and implementation of these reforms.

Currently, HMRC obtains information relating to property income by issuing data holder notices to request data. The government plans to move to the new reporting framework under Schedule 23 of Finance Act 2026 where specified organisations have an ongoing legal obligation to provide agreed data to HMRC on a regular basis.

The government is consulting on the detailed design of the new obligations, including reporting frequency: the scope of information to be included; the standards that should apply to data quality and how data-holders can report the data after the end of the reporting period.

The reforms are intended to help taxpayers get their tax right first time, improve the effectiveness of tax administration and compliance activity, and support the delivery of a more digital tax system. The government is seeking views on how these requirements should be implemented in a way that is proportionate, practical and aligned with existing business processes.

1. Overview and context

Introduction

HMRC already receives, and makes use of, property data from a range of third-party sources to support tax administration, including (but not limited to):

• letting agents
• tenancy deposit protection schemes
• other government departments

These data sets are currently used in various compliance campaigns, such as the Let Property Campaign and the Virtual Street Sweep campaign to tackle unreported property income.

However HMRC continues to struggle to close the tax gap for property income, due in part to the fact that data can be incomplete, difficult to match accurately to taxpayer records, and is often received too late to support timely compliance interventions.

Improved data quality would enable HMRC to deliver better services for taxpayers while strengthening compliance activity. For example, HMRC could provide more personalised support for Self-Assessment customers, automatically identify and register those who need to complete a return, and improve the accuracy of tax forecasts and compliance interventions.

From April 2028, landlords with income over £20,000 will be included in the Making Tax Digital (MTD) reporting requirements.

High-quality, timely and identifiable third-party data will support digital prompts and nudges and will present opportunities to improve the customer experience for landlords in MTD.

Adopting a phased approach to reform

As stated in the 2025 consultation Better use of new and improved third party data to make it easier to pay tax right the first time, the government has adopted a phased approach to reforming how HMRC acquires data from third-party sources.

Phase one focused on reforming the reporting of interest income data and card sales (merchant acquirer) data. It also introduced Schedule 23 of Finance Act 2026, which established the legislative framework for bulk data-gathering powers to ensure HMRC receives the right data, of the right quality, at the right time.

Phase two will introduce reforms for the reporting of property income data, alongside further work on dividends and other income from investments.

Schedule 23 of Finance Act 2026 builds on the existing data-gathering powers in Schedule 23 of Finance Act 2011, modernising the framework to enable more regular, standardised, and scalable data collection. This reflects the government’s broader objective of moving towards a more digital, data-led tax administration system.

Within this framework, specific reporting requirements, including the categories of relevant data holders, the datasets to be provided and the frequency of reporting, are set out in secondary legislation.

2. Establishing standing reporting obligations for property income data

This chapter explains how the government will introduce standing reporting obligations for property income data and seeks views on their detailed design and implementation. This includes:

• moving from a notice-based approach towards standing reporting obligations for letting agent data and tenancy deposit protection scheme data
• continuing to use existing data-gathering powers to obtain data that falls outside the scope of the new reporting obligations, where required
• increasing the frequency and timeliness of data provided to HMRC to support tax administration and customer services

The case for introducing standing reporting obligations

Under the current regime, HMRC must issue a notice each time it requires information from a data holder. This is a manual and resource-intensive process for HMRC and can create uncertainty for data holders about when information may be requested.

HMRC currently issues over 10,000 notices each year to obtain property income information from letting agents and tenancy deposit protection scheme providers. This illustrates the scale of the current notice-based approach and the administrative burden it creates for both HMRC and data holders.

To modernise the reporting framework, the government introduced Schedule 23 of Finance Act 2026, which provides a legal basis for introducing standing reporting obligations for specified categories of data holders. Under the new framework, information will be provided regularly without HMRC issuing individual notices for each reporting cycle, giving data holders greater certainty and supporting better business planning.

The introduction of standing reporting obligations will not replace HMRC’s existing data-gathering powers. The powers in Schedule 23 to Finance Act 2011 will continue to be available where HMRC needs to obtain third-party data that falls outside the scope of the new reporting obligations. This includes other datasets and categories of data currently acquired under Schedule 23 of Finance Act 2011, as well as third-party data relating to commercial property, land and other matters outside the scope of the new reporting framework for property income.

Defining the scope for standing reporting obligations

When considering the scope of standing reporting obligations, the following terms are used throughout this chapter:

Term	Entity	Description
Data holder	Letting agents and tenancy deposit protection schemes	The organisations responsible for reporting third-party data to HMRC.
Data subject	Landlords (including individuals, companies, partnerships and trusts)	The person or entity to whom the reported third-party data relates.
Relevant data	Residential property income data	The third-party data relating to residential property income that supports tax administration and compliance activity.

The scope of standing reporting obligations for letting agent data  

HMRC currently receives property income data from letting agents under the existing notice-based regime. The data includes a broad range of property types and landlord structures. Under the new standing reporting obligations, reporting will focus on the private residential sector, reflecting the primary tax administration use case for the data and ensuring the obligations remain proportionate. The consultation seeks views on how that scope should be defined.

HMRC is currently working with the Ministry of Housing, Communities and Local Government to ensure any new reporting requirements are considered together with the reporting requirements of the new landlords register.

Data holders

Standing reporting obligations will apply to letting agents acting on behalf of UK-based landlords who let UK residential property. This establishes a clear and proportionate population of reporting entities, aligned with the policy objective of improving HMRC’s access to property income data.

The government welcomes views on how this scope should be defined in practice, including whether particular categories of letting agents require specific treatment.

Data subjects

The government proposes that data should be reported in relation to all landlord types, including:

• individual landlords
• corporate landlords
• partnerships
• trusts

This would provide a more complete picture of the private rented sector and support a consistent approach to tax administration across different ownership structures.

Relevant data

Relevant data will relate to UK residential properties within the private rented sector. This would ensure reporting obligations are aligned with the policy objective of improving HMRC’s visibility of taxable rental income while limiting reporting requirements to data that has a clear tax administration purpose.

Exclusions

Where a data holder acts on behalf of a landlord whose usual place of abode is outside the UK, the data holder is already required to withhold Income Tax and make returns to HMRC under the Non-Resident Landlord Scheme regulations. These data holders will be excluded from the proposed reforms as they are already required to report the landlord’s property income and to pay withheld tax to HMRC.

The government will also provide targeted exclusions where collecting the data would deliver no tax administration benefit. For example, some public bodies may be exempt from tax and therefore reporting information about them may not provide a clear compliance or administrative benefit.

The government welcomes views on the specific exclusions needed and how they could be defined clearly and proportionately.

Question 1: Data holders

The government proposes to define the scope of data holders as letting agents acting on behalf of UK-based landlords who let UK residential property. Do you agree with this approach? Is there an alternative approach that the government should consider? Are there any other agents, outside of letting agents, that should be brought within scope?

Question 2: Data subjects

Are there practical issues in applying the reporting obligations to individual landlords, corporate landlords, partnerships and trusts? Please explain any specific treatment that may be needed.

Question 3: Relevant data

How should UK residential properties within the private rented sector be defined for these reporting obligations?

Question 4: Exemptions

What targeted exemptions or exclusions are needed? Please explain how they should be defined.

Question 5: Business Models

Do franchise, network or other business models create any challenges in determining the correct reporting entity or ensuring complete and accurate reporting?

The scope of standing reporting obligations for tenancy deposit protection schemes

Under the new standing reporting obligations, authorised tenancy deposit protection schemes will form a category of relevant data holder. This consultation seeks views on how that category should be defined.Tenancy deposit protection schemes operate within a clearly defined regulatory framework and comprise a small number of authorised providers. Schemes collect information relating to UK residential tenancies and all landlord types, including individuals, companies, partnerships and trusts. As the information they collect already aligns with the data the government is seeking to receive through standing reporting obligations, the primary consideration is defining the category of data holder rather than further defining the data subject or relevant data.

The government welcomes views on whether the proposed scope captures all authorised UK tenancy deposit protection schemes and whether any clarification is needed.

Question 6: Does the proposed scope of authorised UK tenancy deposit protection schemes capture all organisations that will be subject to the standing reporting obligations? If not, what change is needed?

De minimis reporting and awareness of reporting obligations

De minimis reporting

The government has considered whether reporting obligations should only apply where rental income, tenancy deposits, or other relevant amounts exceed a specified threshold (commonly referred to as a de minimis). Under current reporting requirements there is no de minimis threshold.

The government’s initial view is that introducing thresholds could reduce the completeness of property income data and limit HMRC’s ability to identify taxpayers who may have tax obligations or require support. This could undermine some of the intended benefits of the reforms, including improving data matching, supporting customers to get their tax right first time and identifying those who may need to register for Self-Assessment.

The new reporting obligations will therefore apply without a de minimis threshold.

Question 7: Are there implementation issues arising from applying the reporting obligations without a de minimis threshold, and how could these be mitigated?

Developing a process for in-scope data holders to be aware of their reporting obligations

As highlighted in the 2025 consultation, Better Use of New and Improved Third-Party Data to Make it Easier to Pay Tax Right First Time, removing the need for HMRC to issue formal notices raises a number of practical challenges for both HMRC and data providers, including:

• how HMRC can identify those that are within scope of the reporting requirements but are not currently reporting
• how data providers can be made aware of their reporting obligations where they have not received a formal notice from HMRC

Addressing these challenges may require closer collaboration with representative and regulatory bodies to ensure reporting obligations are clearly communicated and to help identify new entrants to the market. HMRC will draw on learning from other data sets to see how we can best apply them to make data holders aware of their obligations. However, the government welcomes views on how these issues could best be addressed and any alternative approaches that could support effective compliance with the reporting requirements.

Question 8: How can HMRC ensure that those in scope are aware of their reporting obligations, as well as HMRC being aware of those who should be reporting?

The case for improving the frequency and timeliness of third-party data

Frequency refers to how often third-party data is reported, while timeliness refers to how quickly that data is received after the end of a reporting period. Improving both can help HMRC use the data more effectively to support tax administration and help taxpayers get their tax right first time.

The government considers that the appropriate frequency and timeliness of third-party data reporting depends on both the nature of the data collected and its intended use. In assessing the potential service improvements arising from more timely data from letting agent and tenancy deposit protection schemes, the government has concluded that, in both instances, it would be beneficial to:

• increase the frequency of third-party reporting
• reduce the period between the end of the reporting period and data submission

The government is committed to working collaboratively with industry to develop a proportionate approach that delivers benefits for taxpayers while remaining aligned with existing business processes.

Improving the frequency and timeliness of letting agent data and tenancy deposit protection scheme data

Under the current notice-based reporting regime, both letting agents and tenancy deposit protection schemes are asked to provide property income data on an annual basis and linked to the tax year.

Once a notice is issued, data holders have 60 days to provide the requested information. As a result, HMRC may not receive some data until more than 13 months after the underlying transaction occurred. For example, rental income paid to a landlord at the start of a 12-month reporting period may not be reported to HMRC until the end of that period, after which data holders have up to 60 days to provide the data.

As part of the move towards standing reporting obligations, the government intends to require more frequent and timely reporting of property income data. This consultation seeks views on the appropriate reporting frequency and submission deadline.

Increasing the frequency of reporting will allow HMRC to receive updated information more regularly throughout the year. Improving the timeliness of reporting would reduce the period between the end of a reporting period and the submission of data. Together, these changes could enable HMRC to make better use of third-party data, support earlier identification of inaccuracies and non-compliance, and provide more timely support and guidance to customers.

The government recognises that changes to reporting frequency and timeliness may have operational and administrative impacts on letting agents. The aim is to identify a proportionate approach that balances the benefits of more up-to-date data with the practicalities and costs of reporting.

Potential benefits of more frequent and timely reporting

More frequent and timely property income data could support a range of improvements to tax administration and customer services.

For taxpayers, more up-to-date third-party data could help identify potential omissions or inaccuracies earlier and support them in getting their tax right first time. This could reduce the need for corrections, enquiries, financial penalties for non-compliance and late payment, and follow-up activity later in the tax cycle.

For customers within Making Tax Digital for Income Tax, more timely third-party data could support the development of digital services that provide prompts, insights and feedback to help improve the accuracy of quarterly updates and end-of-year tax reporting.

More timely third-party data could also help HMRC identify individuals who may have taxable property income but are not registered for Self Assessment, enabling earlier engagement and support to help them understand and meet their obligations.

Finally, more frequent and timely data could support the development of digital services that provide customers with more up-to-date information about their property income and potential tax liabilities, helping them make better-informed financial decisions throughout the year

Increasing the reporting frequency of letting agent data and tenancy deposit protection scheme data

While annual reporting provides HMRC with data for tax administration and compliance purposes, it does not deliver the benefits associated with more frequent reporting.

The government has considered a range of reporting frequencies, from maintaining annual reporting through to reporting at or close to the point at which rental income and deposits are processed. For example, this could involve reporting data when a letting agent receives rental income from a tenant, or the moment where deposits are registered with a tenancy deposit protection scheme.

In considering alternative reporting frequencies, the government seeks to balance the benefits of receiving data more regularly against the administrative and operational impacts on data holders. Reporting requirements should be frequent enough to support effective tax administration while remaining proportionate and practical to deliver.

The government intends to increase reporting from the current annual cycle and is consulting on whether monthly or quarterly reporting provides the most appropriate balance. Both options will support improved use of third-party data. The benefits delivered would also depend on how quickly data is reported after the end of each reporting period.

The government welcomes views on which reporting frequency would best align with existing business processes and operational practices.

Question 9: Reporting frequency

The government intends to increase the frequency of reporting and is seeking evidence to determine whether monthly or quarterly reporting best balances tax administration benefits with operational practicality.

• how frequently could letting agent data reasonably be reported to HMRC?

  • monthly
  • quarterly

• how frequently could tenancy deposit protection scheme data reasonably be reported to HMRC?

  • monthly
  • quarterly

• which reporting frequency would best align with existing business processes and operational practices, and why?

• what costs, administrative burdens or operational challenges would arise from more frequent reporting?

Reducing the time taken to report letting agent data and tenancy deposit protection scheme data after the end of a reporting period

The government has considered a range of options for how quickly letting agent data and tenancy deposit protection scheme data should be provided following the end of a reporting period. These range from the current requirement to provide data within 60 days to reporting closer to the point at which rental income is received or processed or the moment where deposits are registered with a deposit protection scheme.

The current 60-day reporting window limits the extent to which HMRC can use the data to support timely tax administration activities, including providing tailored support to customers and identifying issues earlier in the tax cycle.

The government intends to shorten reporting deadlines as part of the move to standing reporting obligations. This consultation seeks evidence on whether data should be submitted within one month of the end of a reporting period, within two weeks, or within a shorter timeframe where that aligns with existing business processes. The government recognises that shorter reporting deadlines may involve operational and administrative challenges for data holders. It is therefore seeking views on what reporting timeframe would provide an appropriate balance between improving the timeliness of data and ensuring reporting obligations remain proportionate and achievable.

Question 10: The government intends to introduce shorter reporting deadlines for letting agent and tenancy deposit protection scheme data. The following questions seek evidence on the appropriate timeframe and implementation requirements.

• how soon after the end of a reporting period could letting agent data reasonably be provided to HMRC?

  • within one month
  • within two weeks
  • less than two weeks

• how soon after the end of a reporting period could tenancy deposit protection scheme data reasonably be provided to HMRC?

  • within one month
  • within two weeks
  • less than two weeks

• what operational, technical, or commercial challenges would more timely reporting create for data holders for each of the options above?

3. Modernising reporting and data transmission for letting agents and tenancy deposit protection schemes

This chapter seeks views on how letting agents and tenancy deposit protection schemes should provide data to HMRC in order to comply with the proposed reporting obligations.

Specifically, the government is seeking views on:

• introducing standardised reporting schemas for letting agent and tenancy deposit protection scheme data
• modernising the way data is transmitted to HMRC
• minimising burdens on data suppliers through digital reporting solutions and appropriate support arrangements

The case for introducing new schemas

As outlined in the 2025 Better use of new and improved third-party data to make it easier to pay tax right first-timeconsultation, a schema is a structured format for holding and transmitting data electronically and in bulk. A schema defines the data required within a report and applies validation rules to support consistency and data quality.

Standardised schemas are already used across government and internationally to support secure, efficient and automated data exchange.

Current reporting arrangements

Letting agent data and tenancy deposit protection scheme data

HMRC currently receives letting agent data and tenancy deposit protection scheme data through spreadsheet-based returns submitted by email.

While this approach has enabled HMRC to acquire the data needed for tax administration purposes, it presents a number of limitations, including:

• security risks associated with the transmission of information and data
• lack of built-in support for data validation (to ensure data quality)
• lack of interoperability with HMRC systems, limiting the ability to identify errors at the point of submission
• increased operational burdens for both suppliers and HMRC

Developing a modern reporting schema

Benefits of a more modern schema

The government intends to introduce standardised digital reporting schemas for both letting agent and tenancy deposit protection scheme data.

Moving to a structured digital format, such as XML or JSON, will provide several benefits:

• improved consistency in data formatting
• automated validation and error checking
• faster processing and correction of errors
• improved interoperability with HMRC systems
• greater efficiency for both data suppliers and HMRC

The government is seeking to understand current technical capabilities and the practical implications of moving to a structured digital reporting format.

Modernising data transmission

Alongside the introduction of standardised schemas, the government is developing HMRC’s Third-Party Data Ingestion System (TPDI).

TPDI is intended to modernise how HMRC receives, validates and processes third-party data. The system will support digital submission channels, automated validation and more efficient data processing.

The government recognises that reporting populations may range from large organisations with sophisticated software solutions through to smaller organisations with lower reporting volumes. It is therefore seeking views on how reporting channels should be designed to minimise burdens and support compliance.

This could include digital interfaces allowing lower-volume reporters to enter data directly through an online service, while supporting automated submissions from organisations using commercial software.

Question 11: Reporting schemas

The government intends to introduce standardised digital reporting schemas for letting agent and tenancy deposit protection scheme data and is seeking evidence to inform the technical design and transition arrangements.

• would there be any anticipated issues with moving from spreadsheet-based reporting to a structured digital format, such as XML or JSON?
• what costs or system changes would be associated with adopting a new reporting schema?
• to what extent do software solutions used within the letting agent and tenancy deposit protection scheme sectors support structured data formats such as XML or JSON or submission through an API?
• what transition period would be required to implement a new reporting schema?

Question 12: Methods of data transmission

The government is seeking views on how data should be submitted to HMRC.

• what digital methods of submitting data to HMRC should be supported under a future reporting regime?

• what support would assist implementation?

• are there any secure and effective methods of transmitting bulk data that government should consider?

4. Collecting tax identifiers and additional data

The case for improved data matching

Data that can reliably identify taxpayers is essential to a modern tax administration system.

Accurate identifiers enable HMRC to match data reported by third-party data holders to the correct taxpayer record and support a range of tax administration activities, including customer support, compliance activity and service improvements.

While HMRC currently receives data such as names and addresses, tax identifiers are often not reported because they are not routinely required for the business purposes of the data holders.

Where identifiers are unavailable, HMRC must rely on less robust matching methods, reducing the effectiveness and efficiency of third-party data.

The government intends to require specified additional identifiers to be collected and reported alongside the data already provided. This consultation seeks views on the detailed requirements and proportionate implementation.

Tax identifiers currently collected

The government is interested in understanding what information is currently collected by letting agents and tenancy deposit protection schemes through customer onboarding, identity verification, anti-money laundering and customer due diligence processes. This includes the sanctions checks that became a requirement from May 2025 for letting agents, and form part of the standard Know Your Customer (KYC) process for every landlord and tenant.

This also includes whether organisations currently collect, verify or hold other information that could support improved data matching.

Collecting tax identifiers

The government intends to require letting agents and tenancy deposit protection schemes to request, hold, maintain and report specified tax identifiers, which may include:

• National Insurance Numbers (NINOs) for individual landlords
• Company Registration Numbers (CRNs) for incorporated companies
• VAT Registration Numbers (VRNs), where applicable
• Unique Taxpayer References (UTRs) for partnerships, trustees, estates and non-resident landlords who do not have a NINO or CRN

These identifiers would be reported alongside the designatory information already supplied to HMRC.

The government recognises that collecting new identifiers may involve operational costs and changes to onboarding processes, systems and data management practices. It is therefore seeking views on what would be a proportionate and practical approach.

New customers

For new landlord relationships and newly registered tenancy deposits, the government proposes that identifiers will be requested as part of onboarding processes. The government recognises that requirements for new customers may be simpler to implement than retrospectively obtaining identifiers for existing records, but may still involve changes to onboarding processes, systems and customer communications. The government seeks evidence on the system, process and customer communication changes needed to implement this requirement proportionately.

Existing customers

For existing landlord records, the government proposes that data holders will be required to make reasonable efforts to obtain the specified identifiers. The detailed approach will reflect the practical differences between existing and new customer relationships. For existing customers, organisations would be required to make reasonable efforts, consistent with paragraph 2(2) of Schedule 23 of Finance Act 2026, to obtain identifiers.

This may include targeted customer communications, periodic customer reviews or other opportunities to update customer information. The government will work with data holders to define ‘reasonable efforts’ clearly and practically.

The government welcomes views on what would be proportionate and achievable.

Question 13: Current collection practices and identifiers

The government is interested in understanding the information currently collected by letting agents and tenancy deposit protection schemes as part of customer onboarding, identity verification, customer due diligence and ongoing customer relationship management.

• what identifiers and customer information are commonly collected by letting agents and tenancy deposit protection schemes as part of these processes?
• to what extent is information about landlord type (for example, individual, company, partnership, trust or estate) currently captured and maintained?
• what challenges might arise in collecting and reporting additional identifiers or customer information?

Question 14: Tax identifiers for new customers

The government intends to require letting agents and tenancy deposit protection schemes to request and report specified tax identifiers for new landlord relationships and newly registered tenancy deposits. The following questions seek evidence on implementation.

• what are your views on requiring the collection and reporting of tax identifiers as part of onboarding processes for new landlord relationships and newly registered tenancy deposits.
• what costs, system changes or process changes would be associated with introducing these requirements for new customers?

Question 15: Tax identifiers for existing customers

The government recognises that collecting identifiers for existing landlord relationships may present different challenges to collecting them for new customers.

• what would represent a proportionate approach to obtaining tax identifiers for existing landlord records?
• what lead-in period or transitional arrangements would support implementation?
• what practical barriers should government be aware of?

Additional data fields

In addition to tax identifiers, the government believes additional data already collected by letting agents and tenancy deposit protection schemes could improve tax administration if reported to HMRC. This would enhance HMRC’s ability to match data to the correct taxpayer records and provide customers with more accurate tailored feedback for self-assessment submissions and Making Tax Digital updates.

Potential data fields could include, but are not limited to:

• landlord type (for example, individual, company, partnership, trust or estate)
• landlord date of birth
• tenancy start and end dates
• gross rental income
• property management fees
• allowable expenses or other deductions from rental income
• beneficial ownership information where property is held in trust
• identifiers for the rented property, including Unique Property Reference Numbers (UPRN)
• landlord identifiers introduced through the Private Rented Sector database

The government is seeking views on both the feasibility and proportionality of collecting and reporting such information.

Question 16: Additional data fields

The government is interested in understanding whether additional information already collected by letting agents and tenancy deposit protection schemes could support tax administration if reported to HMRC.

• what additional information is commonly collected that could be reported with minimal additional burden?
• which additional data fields would you suggest are feasible to collect and report to HMRC?

Question 17: Costs, impacts and proportionality

The government is seeking evidence on the impacts of collecting and reporting additional identifiers and data fields.

• what costs, administrative burdens or system changes might arise from the proposals outlined in this chapter?
• are there particular proposals that would be disproportionately burdensome, and why?

5. Ensuring data quality — due diligence requirements

The case for improving data quality

High-quality third-party data is essential to the effective operation of a modern tax administration system. Without confidence in the accuracy and completeness of the data received, HMRC cannot make effective use of third-party data to improve services, support customers or undertake compliance activity.

Letting agents are already subject to a range of legal and regulatory obligations that support the collection and maintenance of accurate customer information. These include customer due diligence and identity verification requirements under anti-money laundering regulations, and the UK GDPR accuracy principle, which requires personal data to be accurate and, where necessary, kept up to date.

Similarly, tenancy deposit protection schemes are required to comply with the UK GDPR accuracy principle and maintain accurate records as part of their business operations.

While these existing obligations support data quality, HMRC continues to receive data that is incomplete, inaccurate or inconsistent. In some cases, information that could support improved data matching and tax administration is not collected consistently across the sector.

Due diligence requirements for third-party reporting

Accurate identifiers and customer information will be critical to the success of the proposed reforms. The quality of the data reported directly affects HMRC’s ability to match third-party data to taxpayer records and use that data effectively.

There is currently no specific requirement for data suppliers to undertake verification of tax identifiers before reporting them to HMRC.

Schedule 23 of Finance Act 2026 will address this by requiring data holders to take reasonable steps, using information already available to the business and publicly available information sources where appropriate, to improve the accuracy of tax identifiers before they are reported.

The government recognises that any such requirements must be proportionate and should build on existing business processes wherever possible. It is therefore seeking views on what level of verification would be reasonable and practical for letting agents and tenancy deposit protection schemes.

For example, where tax identifiers are collected, the government is interested in views on:

• what validation or verification checks are already undertaken
• whether additional checks would be required
• the costs and operational impacts of any verification requirements
• how guidance or digital services could support compliance

Consistent with existing approaches to data quality, HMRC would seek to understand the reasons for incomplete or inaccurate submissions before considering compliance action.

Question 18: Data quality and due diligence

The government is seeking views on what level of due diligence checks is reasonable and practical for data providers to carry out.

• what checks or verification processes are commonly undertaken by letting agents and tenancy deposit protection schemes today, and to what extent could these support the proposed reporting requirements?
• what current challenges exist in the verification of information for letting agents and tenancy deposit protection schemes now?
• what would represent a proportionate approach to verifying tax identifiers and other information before it is reported to HMRC?
• are there particular operational or other challenges that government should consider?

Question 19: Implementation and support

What guidance, support or digital tools would assist organisations in meeting any future data quality requirements?

6. Summary of consultation questions

The scope of standing reporting obligations for letting agent data

Question 1: Data holders

 The government proposes to define the scope of data holders as letting agents acting on behalf of UK-based landlords who let UK residential property.  Do you agree with this approach? Is there an alternative approach that the government should consider? Are there any other agents, outside of letting agents, that should be brought within scope?

Question 2: Data subjects

 Are there practical issues in applying the reporting obligations to individual landlords, corporate landlords, partnerships and trusts? Please explain any specific treatment that may be needed.  

Question 3: Relevant data

 How should UK residential properties within the private rented sector be defined for these reporting obligations?  

Question 4: Exemptions

 What targeted exemptions or exclusions are needed? Please explain how they should be defined

Question 5: Business Models

Do franchise, network or other business models create any challenges in determining the correct reporting entity or ensuring complete and accurate reporting?

Question 6:  Does the proposed scope of authorised UK tenancy deposit protection schemes capture all organisations that will be subject to the standing reporting obligations? If not, what change is needed?

Question 7:  Are there implementation issues arising from applying the reporting obligations without a de minimis threshold, and how could these be mitigated?

Question 8: How can HMRC ensure that those in scope are aware of their reporting obligations, as well as HMRC being aware of those who should be reporting?

Question 9: Reporting frequency

• how frequently could letting agent data reasonably be reported to HMRC?
  • monthly
  • quarterly
• how frequently could tenancy deposit protection scheme data reasonably be reported to HMRC?
  • monthly
  • quarterly

• which reporting frequency would best align with existing business processes and operational practices, and why?

• what costs, administrative burdens or operational challenges would arise from more frequent reporting?

Question 10:  How soon after the end of a reporting period could letting agent data reasonably be provided to HMRC?

• within one month
• within two weeks

• less than two weeks

• how soon after the end of a reporting period could tenancy deposit protection scheme data reasonably be provided to HMRC?
  • within one month
  • within two weeks
  • less than two weeks
• what operational, technical, or commercial challenges would more timely reporting create for data holders for each of the options above?

Question 11: Reporting schemas

• would there be any anticipated issues with moving from spreadsheet-based reporting to a structured digital format, such as XML or JSON?

• what costs or system changes would be associated with adopting a new reporting schema?

• to what extent do software solutions used within the letting agent and tenancy deposit protection scheme sectors support structured formats such as XML, JSON or API-based reporting?

• what transition period would be required to implement a new reporting schema?

Question 12: Methods of data transmission

• what digital methods of submitting data to HMRC should be supported under a future reporting regime?

• what support would assist implementation?

• are there any secure and effective methods of transmitting bulk data that government should consider?

Collecting tax identifiers and additional data

Question 13: Current collection practices and identifiers

• what identifiers and customer information are commonly collected by letting agents and tenancy deposit protection schemes as part of these processes?

• to what extent is information about landlord type (for example, individual, company, partnership, trust or estate) currently captured and maintained?

• what challenges might arise in collecting and reporting additional identifiers or customer information?

Question 14: Tax identifiers for new customers

• what are your views on requiring the collection and reporting of tax identifiers as part of onboarding processes for new landlord relationships and newly registered tenancy deposits.

• what costs, system changes or process changes would be associated with introducing these requirements for new customers?

Question 15: Tax identifiers for existing customers

• what would represent a proportionate approach to obtaining tax identifiers for existing landlord records?

• what lead-in period or transitional arrangements would support implementation?

• what practical barriers should government be aware of?

Question 16: Additional data fields

• what additional information is commonly collected that could be reported with minimal additional burden?

• which additional data fields would you suggest are feasible to collect and report to HMRC?

Question 17: Costs, impacts and proportionality

• what costs, administrative burdens or system changes might arise from the proposals outlined in this chapter?

• are there particular proposals that would be disproportionately burdensome, and why?

Ensuring data quality – due diligence requirements

Question 18: Data quality and due diligence

• what checks or verification processes are commonly undertaken by letting agents and tenancy deposit protection schemes today, and to what extent could these support the proposed reporting requirements?
• what current challenges exist in the verification of information for letting agents and tenancy deposit protection schemes now?
• what would represent a proportionate approach to verifying tax identifiers and other information before it is reported to HMRC?
• are there particular operational or other challenges that government should consider?

Question 19: Implementation and support

• what guidance, support or digital tools would assist organisations in meeting any future data quality requirements?

7. Assessment of impacts

Impacts on individuals, households, and families

This consultation seeks views on proposals to improve the quality of third-party data relating to property income. HMRC’s assessment of the impacts of these proposals will be developed based on consultation responses and subsequent policy design.

Equalities Impacts

This consultation seeks views on proposals to improve the quality of third-party data relating to property income. HMRC’s assessment of the impacts of these proposals will be developed based on consultation responses and subsequent policy design.

Impacts on businesses and civil society organisations

This consultation seeks views on proposals to improve the quality of third-party data relating to property income, which are expected primarily to impact letting agents and tenancy deposit protection schemes. HMRC’s assessment of the impacts of these proposals will be developed based on consultation responses and subsequent policy design.

8. The consultation process

Tax Policy Making principles

The following principles underpin the government’s approach to tax policy making:

• predictability and stability: the single major fiscal event cycle will provide a predictable and stable framework for the delivery of tax changes
• a smart and agile approach to consultation: the government will engage stakeholders fully and flexibly when developing tax policy, prioritising dynamic and frequent engagement with tax professionals at both ministerial and official levels — where formal consultation is required, it will be targeted and precise, only seeking information that is genuinely needed, and will last a proportionate amount of time
• transparency: the government is committed to transparency, and will make sure that its rationales for tax policy changes and assessments of policy impacts are clear

These principles will enable the government to deliver change quickly, whilst making sure that the impacts of tax policy changes are fully understood.

How to respond

A summary of the questions in this consultation is included in chapter 6.

Responses should be sent by 20 January 2027, by email to thirdpartydata@hmrc.gov.uk.

Please do not send responses to the Consultation Coordinator. Paper copies of this document in Welsh may be obtained free of charge from the above address.

When responding, please say if you are a business, individual or representative body. In the case of representative bodies, please provide information on the number and nature of people you represent.

Confidentiality

HMRC is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law, including the UK GDPR and the Data Protection Act (DPA) 2018.

Information provided in response to this consultation, including personal information, may be published or disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the DPA 2018, UK GDPR and the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the Freedom of Information Act 2000, there is a statutory Code of Practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Revenue and Customs.

Consultation Privacy Notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the UK GDPR.

Your data

We will process the following personal data:

Name

Email address

Postal address

Phone number

Job title

Purpose

The purpose for which we are processing your personal data is to assist in the design of policy for better use of improved third-party data for property income.

Legal basis of processing

The legal basis for processing your personal data is that the processing is necessary for the exercise of a function of a government department.

Recipients

Your personal data will be shared by us with HM Treasury

Retention

Your personal data will be kept by us for 6 years and will then be deleted

Your rights

You have the right to request information about how your personal data are processed, and to request a copy of that personal data

You have the right to request that any inaccuracies in your personal data are rectified without delay.

You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.

You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.

You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113  casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Contact details

The data controller for your personal data is HMRC. The contact details for the data controller are:

HMRC
100 Parliament Street
Westminster
London
SW1A 2BQ

The contact details for HMRC’s Data Protection Officer are:

The Data Protection Officer
HMRC
14 Westfield Avenue
Stratford
London
E20 1HZ
Advice.dpa@hmrc.gov.uk

Annex — relevant government legislation

The data-gathering powers of Schedule 23 of Finance Act 2011, and the accompanying Data-gathering Powers (Relevant Data) Regulations 2012/847, enable HMRC to issue a data-holder notice and collect data from certain third parties used for compliance activity. These third parties are called ‘relevant data holders’, and the legislation stipulates the type of relevant data that HMRC may acquire. The data-gathering powers cannot be used for checking the tax position of the data-holder, but the powers in Schedule 36 of Finance Act 2008 are available for that purpose.

The data-gathering powers of Schedule 23 of Finance Act 2026 enables HMRC to require ‘relevant data holders’ to collect, verify and provide prescribed data to HMRC on an ongoing basis. ‘Relevant data holders’ are defined in accompanying regulations.

‘Relevant data holders’

A ‘relevant data-holder’ is a person who holds, or previously held, one or more of the types of ‘relevant data’.  The scope of ‘relevant data-holders’ for property income will be defined in legislation.

‘Relevant data’

‘The data gathering powers allow HMRC to require a relevant data-holder to provide ‘relevant data’. The scope of ‘relevant data’ for property income will be defined in legislation.

Other

There is a limit to how far back HMRC can request data (4 years). Under Schedule 23 of Finance Act 2011, the department can only require the data-holder to provide documents that are in the data-holder’s possession or power.