Consultation outcome

Government response to the Strengthening leaseholder protections over charges and services consultation

Updated 15 July 2026

Ministerial foreword 

The leasehold system is blighting millions of lives. The leasehold system is a barrier to a fair and efficient modern residential property market. The leasehold system is an anachronism in the twenty-first century. That is why this government made a clear and unambiguous commitment in its manifesto to act where previous governments had failed and finally bring it to an end.

To bring the feudal leasehold system to an orderly end in this Parliament, we must stop it perpetuating itself. To do so, we will legislate through our forthcoming Commonhold and Leasehold Reform Bill to reinvigorate commonhold through the introduction of a comprehensive new legal framework and make it the default tenure by banning the use of leasehold for new flats – complimenting the ban on new leasehold houses already on the statute book.

In the commonhold future that is on the horizon, existing leaseholders will not be left behind. Our substantive Commonhold and Leasehold Reform Bill will include a new and improved process for commonhold conversion. To ensure more leaseholders can convert in practice, we will implement measures in the Leasehold and Freehold Reform Act 2024 that make enfranchisement cheaper and easier.

Our proposed £250 cap on ground rent will further reduce the cost of enfranchisement for many leaseholders with ground rent. We will also implement mandatory leasebacks to ensure that enfranchising leaseholders are not forced to buy expensive commercial units or non-participating leases which can too often make enfranchisement prohibitively expensive. And we will honour our manifesto commitment to enact remaining Law Commission recommendations on enfranchisement and Right to Manage in this Parliament.

The end result of bringing all these measures into force will be more existing leaseholders able to take control of their buildings and more easily convert to commonhold as and when they judge the time is right time for them – rapidly reducing the prevalence of existing leasehold.

Alongside progressing the reforms necessary to bring the leasehold system to an end, we are strengthening protections for existing leaseholders in the here and now. Central to that effort is providing relief to leaseholders currently suffering as a result of unfair and unreasonable practices by continuing to bring into force reforms to the leasehold system already in statue.

This consultation sought views on measures contained in the Leasehold and Freehold Reform Act 2024 to drive up the transparency of service charges and reform the litigation costs regime, as well as a number of further reforms outside the scope of that Act including mandating reserve funds, introducing mandatory qualifications for managing agents and improving the section 20 major works regime. We received a very large number of thoughtful and detailed responses to it from leaseholders, landlords, managing agents and representative organisations. The insight provided has been invaluable in shaping our approach.

Having considered carefully the feedback received to this consultation, as well as the separate consultation undertaken in respect of permitted insurance fees, the government will now proceed to implement measures to drive up the transparency of service charges and reform the litigation costs regime, as well as look to introduce a transparent and fair permitted building insurance payment. These measures will work in tandem to help leaseholders better understand what they are paying for and empower them to challenge charges where they believe them to be unreasonable.

This impactful package of reforms will be laid in Parliament later this year through a minimum of five complementary statutory instruments, at least two of which will be made under the affirmative procedure. We will provide a separate response in due course in relation to the further reforms consulted upon that are outside the scope of the Leasehold and Freehold Reform Act 2024.

Matthew Pennycook MP
Minister for Housing and Planning

Executive summary

This government is committed to addressing the current imbalance between leaseholders and freeholders. Part 4 of the 2024 Act contains a number of provisions designed to standardise and increase the transparency of service charges and remove barriers for leaseholders to challenge their landlord. The 2024 Act also includes provision to scrap the presumption that leaseholders should pay their landlords’ litigation costs through the service or administration charge, thereby removing a significant barrier to challenging poor practice.

A consultation ran from 4 July to 26 September 2025 to seek views on how best to implement the 2024 Act proposals. The key responses and outcomes are set out below. We will lay Statutory Instruments to put these measures into place in England as soon as possible. Leaseholders, including shared owners, and tenants of Private Registered Providers (PRPs) will start to see changes during 2027.

The consultation also sought views on further leasehold reform. This included reforms to the major works regime, introducing mandatory reserve funds, and introducing mandatory qualifications for managing agents. We will provide a separate response on these proposals in due course.

Driving up transparency of fees and charges

Annual report

The government will introduce an annual report to give leaseholders an insight into the health and condition of their building, plans for forthcoming major works and other useful information. We will prescribe the form and contents of the annual report. There will be adjustments to cater for existing circumstances, including leaseholders who pay fixed charges and event fees, and where there is both a head lessor and superior landlord in place. The annual report may be provided by post or, where permitted or agreed by the leaseholder, electronically, including via a portal.

Landlords will be required to send this report to leaseholders and shared owners. In light of the forthcoming introduction of the Social Tenant Access to Information Requirements (“STAIRs”) in October 2026, we do not consider this measure needs to apply to PRP tenants. We plan to give private landlords 12 months’ notice of the measures, and social landlords 24 months’ notice, so as to give landlords adequate time to make the required adjustments to their processes and systems.

Standardised service charge demand form

The government will introduce a standardised service charge demand form. We will require the initial service charge demand to be accompanied by an annual budget for the relevant block, building or development, which includes a comparison with the expenditure for the previous accounting period so that leaseholders can understand the difference. Any further demand forms throughout the year will also be prescribed, as will any reconciliation demand form that accompanies the final set of accounts for the previous year. We will introduce a bespoke demand form for local authority landlords to reflect their particular circumstances.

We will provide some flexibility for landlords or managing agents to provide additional information alongside the demand form. We plan to give private landlords 12 months’ notice of the measures, and social landlords 24 months’ notice, so as to give landlords adequate time to make the required adjustments to their processes and systems.

Notices of future demands

The government will prescribe a new future demand notice which will provide leaseholders with key information about why they may face a delayed demand for a service charge payment and when that demand is expected to be made. At this stage, we will not cap costs where the time limit or estimate set out in the initial future demand notice has been exceeded. We plan to commence this measure as soon as possible in 2027.

Right to obtain information on request  

The government will prescribe a list of information that landlords must provide to leaseholders on request relating to service charges and management, maintenance, repair, improvement and insurance of their building. We will create a bespoke, smaller list for PRP tenants in light of the information that will be available to them through STAIRs. We will give leaseholders the right to request information going back six years, and will limit the grounds on which landlords may refuse to provide information. We will introduce a sliding timescale for responding to requests. Where landlords are unable to obtain the information, they must provide the leaseholder with an explanation.

In situations where landlords need to obtain information from third parties, we will prescribe a maximum time period of 15 days within which landlords must request that information from a relevant third party. We will continue to give leaseholders the right to inspect documents in person, and require reasonable arrangements for inspection to be made within three calendar months of the request. Landlords will be required to keep leaseholders informed of progress. We plan to commence this measure as soon as possible in 2027.

Application of proposals to those who rent

The government will require landlords to provide a standardised service charge demand form to PRP tenants who pay both fixed and variable service charges. However, landlords will not be required to provide these tenants with an annual report given the introduction of STAIRs from October 2026. In addition, we will give PRP tenants access to a defined list of information under our right to request information measures.

Administration charge schedule

The government will introduce a prescribed schedule that landlords must provide where they demand, or propose to demand, administration charges from leaseholders. We will require landlords to set out the exact charge or, where an exact charge cannot be included, the method for calculating the charge. We will require landlords to provide the schedule as part of the annual report and on request from a leaseholder. We will give landlords 12 months’ notice of the measures so they can make adjustments to their processes and systems.

Better information about insurance      

The government will introduce new transparency requirements for building insurance. We will prescribe disclosure of relationships and arrangements between landlords and managing agents with brokers and insurers. We will also require clear information on insurance procurement, pricing and cover. These measures will apply without any exceptions and information will be delivered in a standalone form. We will prescribe clear deadlines, alongside a mechanism to help leaseholders identify and challenge delays. We plan to give 12 months’ notice of the measures for the relevant parties to make the required adjustments to their processes and systems.

New standardised service charge accounts  

The government will introduce a standardised framework for service charge accounts to improve consistency, transparency and accountability. We will prescribe the form and minimum content of accounts, including clear financial information and comparative information, where appropriate. Accounts will need to be prepared and signed off by appropriately qualified professionals, with ISRS 4400 as the default reporting standard and ISA 800 where the lease requires an audit. We will also introduce an accountant’s statement alongside the accounts. There will be bespoke arrangements for local authority and PRP landlords to reflect their existing accounting frameworks and regulatory arrangements.

We plan to give private landlords 12 months’ notice of the measures, and social landlords 24 months’ notice, so as to give landlords time to make the required adjustments to their processes and systems.

Rebalancing the litigation costs regime   

The government will reform the litigation costs regime to address the imbalance between leaseholders and landlords, while maintaining appropriate safeguards. It will require court or tribunal approval for all recovery of litigation costs through the service charge, reflecting the need to protect other leaseholders who may bear those costs. For administration charges, a targeted, threshold-based exemption will be introduced, allowing lower value litigation costs to be recovered without approval to reduce unnecessary delay and burden. Limited, timebound flexibilities will apply to resident-led buildings, supported by clear safeguards on transparency, notification and repayment.

The government will also implement a new right for leaseholders to recover their own litigation costs in specified circumstances.

The consultation: content and approach 

The consultation sought views from leaseholders, landlords, managing agents and representative organisations on the implementation of measures in the 2024 Act to improve the rights of existing leaseholders and help them better hold their landlords to account by increasing transparency of service charges and building insurance policies, as well as by tackling unjustified litigation costs. It also sought views on new proposals for reform around the charges that leaseholders pay and the services they receive, as well as measures to strengthen the regulation of managing agents through mandating professional qualifications.

The consultation was open for 12 weeks, between 4 July and 26 September 2025. Respondents could respond via an online survey on Citizen Space, or by email.

In addition to this consultation, we engaged with a range of stakeholders, including representative organisations, to ensure they had the opportunity to hear from government and to give their views on the proposals. 

The consultation asked 205 questions in total, including questions using a response scale and free text box responses.

The consultation adhered to the consultation principles guidance issued by the Cabinet Office.

Throughout this consultation response, we will use the term “landlords” as shorthand for “freeholders, landlords of intermediate leases, Resident Management Companies and Right to Manage Companies”, as these are the people who are able to demand a service charge.

We use the term “leaseholder” to refer to those owning houses or flats who are liable to pay a service charge (including those owning their homes on a shared ownership basis). The exception to this is where we refer to legislation which uses the term “tenant” to mean a leaseholder (not someone who rents a property in the private rented sector).

We also refer to the “appropriate tribunal” or “relevant tribunal” for litigation costs in reference to the First-tier Tribunal (or Upper Tribunal) in England or the Leasehold Valuation Tribunal in Wales.

A glossary of key terms is included at the end of this response.

Geographical scope

While the proposals in the consultation related to both England and Wales, responsibility for implementing the relevant provisions of the 2024 Act rests with the Secretary of State in England and with Welsh Ministers in Wales. This response by the UK Government relates to implementation in England only. Welsh Ministers will consider the consultation findings separately and determine their own approach to implementation in Wales, including whether and how to take forward equivalent reforms.

Summary of consultation responses      

The consultation received 1356 responses across England and Wales. Questions 5 and 6 asked for details about those responding to the consultation. A breakdown by type of respondent, for organisations and individuals, is set out in the table below. We combined the answers to these questions to produce a single breakdown of respondent types, shown in the table below. In the few instances where a respondent identified as more than one category, we made a judgement call about their identity based on evidence provided.

Group	Total	Percent
Individual – Leaseholder/Tenant (Private)	829	61%
Individual – Leaseholder/Tenant (Social)	149	11%
Organisation – Representative Leaseholder/Tenant (Private)	98	7%
Organisation – Landlord (Social)	81	6%
Organisation – Managing agent (Private)	42	3%
Organisation – Landlord (Private)	23	2%
Organisation – Managing agent (Social)	19	1%
Individual – Leaseholder/Tenant (Retirement)	16	1%
Organisation – Professional/Industry	16	1%
RMT / RMC	13	1%
Organisation – Leaseholder/Tenant (Private)	13	1%
Individual – Landlord (Private)	12	1%
Individual – Landlord (Social)	11	1%
Organisation – Public/Regulatory/Political	11	1%
Individual – Public/Regulatory/Political	9	1%
Individual – Managing agent (Private)	9	1%
Organisation – Managing agent (Retirement)	3	0%
Organisation – Leaseholder/Tenant (Retirement)	1	0%
Organisation – Leaseholder/Tenant (Social)	1	0%

All responses received have been considered, and this document provides a summary of those responses. Respondents were not required to answer all the questions in the consultation. While the figures in this document refer to all responses received (unless explicitly stated), including those from outside England, only the responses from England were considered.

Responses to the tick box questions are presented in table format throughout the response. Percentages in tables are presented as a proportion of those that answered the relevant question and do not include non-responses.

Some of the tick box questions asked a supplementary free text questions. All relevant responses to these free-text questions were analysed to identify common themes and coded where possible to collate similar views and comments. We have reviewed all comments provided by respondents, even when not asked to by that specific question, or where they had not selected the relevant parent response option. While these responses are reflected in the qualitative analysis, they are not included in the frequency tables. Where there were respondents who worked together and provided the same answers to each question, they were treated as individual responses.

Key themes or issues are presented to provide a summary of these responses. After the summary analysis of the consultation proposals, we have provided the government response.

Driving up transparency of fees and charges

1. New annual report 

Questions 17 to 18: Form and content

Question 17: Do you agree with the minimum information proposed for the annual report?

There were 1000 responses to this question.

Option	Total	Percent
Yes	563	57%
No	437	44%

Question 17 (free text): If no, what additions or changes would make it more effective?

There were 419 direct responses to this part of the question.

Question 18: Should the information in the annual report be set out in a prescribed and standardised manner?

There were 939 responses to this question.

Option	Total	Percent
Yes	865	92%
No	74	8%

There was broad support in principle for the proposed annual report across all stakeholder groups. The clear majority of leaseholders supported the annual report on the grounds that it would increase transparency about the management of their building. Several leaseholders felt that the report should contain additional information about their building/block, the management of it, and associated costs. However, some leaseholders expressed concern at the cost of introducing an annual report, and a few called for measures to restrict landlords passing any additional cost. Many landlords supported the proposal on principle, but cautioned that requirements would incur additional costs, which would be passed on to leaseholders, and that it would take over 12 months to put arrangements in place to deliver these requirements. Social landlords conveyed that they tend to manage a much larger number of blocks, many of which contained a mix of leaseholder and rented properties, which means that it would be more costly and labour intensive to provide the required information.

There was strong support for government to prescribe and standardise the annual report form, especially from leaseholders. However, several landlords opposed the proposals on the grounds that a more flexible approach would enable them to more easily present information using current systems, and align it with other products sent to leaseholders. They also added that this approach to ensure the document remains user friendly to suit their leaseholders. Landlords considered that, in contrast, prescribing the form would add additional costs to the production of the annual report.

Government response

The content of the annual report will largely reflect what was proposed in the consultation. However, some amendments will be made to reflect points raised in response to the consultation.

The report will include an additional requirement for a declaration of relevant relationships between the landlord and any third party, such as a managing agent, to reflect calls for any existing relationships to be made clear to leaseholders. The report will also require landlords to provide less information relating to major works and enforcement/litigation in response to landlord concerns about the additional cost of obtaining this information, which would be passed on to leaseholders.  

We will prescribe the form that must be used, to standardise how leaseholders receive information and ensure greater consistency in the annual report information provided to leaseholders.

The government will prescribe that the form must be provided by post, in line with terms in individual leases, unless leaseholders agree that the information may be provided digitally.  

Questions 19 to 23: Exemptions

Question 19: Do you agree with the proposals for the annual report for leaseholders in retirement properties and pay both fixed service charges and an event fee?

There were 609 responses to this question.

Option	Total	Percent
Yes	436	72%
No	173	28%

Question 19 (free text): Please explain your answer

There were 260 responses to this part of the question.

Question 20: For those with a superior landlord, how do accounting periods differ between that of the superior landlord and the head lessor?

There were 228 responses to this question.

Option	Total	Percent
0-1 month	52	23%
1-3 months	64	28%
4-6 months	44	19%
Over 6 months	68	30%

Question 21: Where there are different accounting periods between head lessors and superior landlords, do you agree with annual report exemption Option 1 or Option 2 as a means to ensure leaseholders receive timely information?

There were 412 responses to this question.

Option	Total	Percent
Option 1	118	29%
Option 2	184	45%
Neither	110	27%

Question 21 (free text): If neither, please suggest what other arrangement should be in place?

There were 82 direct responses to this part of the question.

Question 22: What circumstances are there where the proposed minimum information may not be available to the landlord to provide the annual report in the specified time period?  

There were 395 responses to this part of the question.

Question 23: Should there be any other exemptions for provision of some or all parts of the proposed annual report which should apply?

There were 664 responses to this question.

Option	Total	Percent
Yes	105	16%
No	559	84%

Question 23 (free text): If so, please explain

There were 98 direct responses to this part of the question.

The majority of respondents favoured proposals for leaseholders who pay both fixed charges and event fees (principally those living in retirement properties) to have a bespoke version of the annual report to suit their particular circumstances. Most leaseholders believed that more transparency was better. Some respondents, mainly leaseholders, argued that this bespoke report should also include details of formal actions or statutory processes.

In circumstances where there is both a head lessor and superior landlord, the vast majority of respondents reported a period of greater than one month between the relevant reporting periods. Where their accounting periods differ, several respondents preferred that the head lessor and superior landlord should each provide information to leaseholders when the information was available (option 2), rather than submitting it together (option 1). Some respondents were concerned that either option could be used as a loophole to avoid providing information.

The majority of respondents, overwhelmingly leaseholders, considered that there should be no further exemptions, on the grounds that transparency should not be compromised. In contrast, the majority of landlords who responded argued for an exemption from providing all the required information in specific circumstances, principally in cases where they do not hold the information because it is held by a third party (such as a contractor) or where there are delays caused by changes in managing agents.

Government response

The government will prescribe a bespoke version of the annual report for leaseholders who pay a fixed service charge and event fee. As proposed in the consultation, this form will require landlords to disclose information on the nature of event fees being charged.

Where a head lessor and superior landlord have non-aligned accounting periods, the government will legislate so that each landlord must provide information when it is made available (option 2). In doing so, we will permit the provider of the annual report to omit information that has not yet been made available by the superior landlord, provided that the report explains that the information has been omitted on that basis.

While we recognise that there may be instances where the landlord may struggle to obtain information, the government will not legislate to provide an exemption for landlords who do not have access to information on the grounds that it is held by another party. We consider that this is necessary to encourage sector-wide behaviour to share and hand over relevant information so that landlords can provide the annual report in full.

The government will, however, exempt PRPs from requirements to send an annual report to their renting tenants. This is to avoid overlap and duplication with STAIRs which, when introduced from October 2026, will enable renting tenants and shared owners to access specific information. This information will be updated on a regular basis.

2. New standardised service charge demand form 

Questions 24 to 25: Contents

Question 24: Do you agree with the proposed contents of the initial service charge demand form?

There were 903 responses to this question.

Option	Total	Percent
Yes	621	69%
No	282	31%

Question 24 (free text): If not, what changes to the proposed contents would you like to see

There were 269 direct responses to this part of the question.

Question 25: [England only] Do you consider that the new building safety information should be provided as part of the service charge demand or annual report?

There were 792 responses to this question.

Option	Total	Percent
Yes	676	85%
No	116	15%

Question 25 (free text): Please explain your answer [England only]

There were 378 direct responses to this part of the question.

The majority of respondents, mainly leaseholders, were broadly in favour of the principle of the standardised service charge demand form. Many leaseholders believed the measures should include further information.

Those respondents who opposed a standardised form, stated that collating and providing the required information through a prescribed format would require significant changes to systems and staff, and produce costs that would be passed down to leaseholders. Some landlords also felt that prescribing a form was unnecessary, and that they already provide the most helpful information using their current setups. Social landlords reported that they collect information on a larger, borough-wide basis, making it difficult to produce information specific to a block or building.

A majority of respondents supported requiring building safety information to be provided in one prescribed annual document, rather than repeated with each service charge demand. Leaseholder respondents supported inclusion on transparency grounds, particularly because the information relates directly to the building they occupy. Many landlords considered that the annual report would be the more appropriate vehicle, given that much of the information is relatively static and that repeating it on each demand could result in unnecessary duplication. Leaseholder groups also supported provision once a year in order to avoid overwhelming leaseholders.

Government response

The government will prescribe the content of the demand form, which will largely reflect what was proposed in Annex B to the consultation. There will be some minor amendments to reflect points and concerns raised in response to the consultation.

We recognise that many landlords already issue service charge demand forms that meet the needs of their leaseholders or tenants. This may include more information than we are prescribing. For this reason, we will legislate to ensure that landlords may attach additional information beyond what is stipulated in the form, so they can continue to provide the same level information as they do currently. This could include, for example, additional information where there are multiple service charge schedules.

Questions 26 to 30: Budget, interim and reconciliation form

Question 26: Which option do you think provides the most appropriate level of breakdown of heads of costs budget headings for the annual budget document?

There were 786 responses to this question.

Option	Total	Percent
Option 1	239	30%
Option 2	547	70%

Question 26 (free text): Explain why you prefer Option 1 or Option 2

There were 702 direct responses to this part of the question.

Question 27: Do you consider that details of the budget should be provided as part of the initial demand form or as part of the annual report?

There were 796 responses to this question.

Option	Total	Percent
Yes	722	91%
No	74	9%

Question 27: Explain your answer

There were 637 direct responses to this part of the question. This includes those who didn’t answer yes or no above.

Question 28: Do you agree with the proposed interim and reconciliation demands forms?

There were 759 responses to this question.

Option	Total	Percent
Yes	583	77%
No	176	23%

Question 28 (free text): Please explain your response. If you disagree, please suggest an alternative approach.

There were 373 direct responses to this part of the question.

Question 29: Should there be any exemptions from providing service charge demands using standardised forms?

There were 814 responses to this question.

Option	Total	Percent
Yes	111	14%
No	703	86%

Question 29 (free text): If yes, please explain what exemptions should apply, and why?

There were 104 direct responses to this part of the question.

Question 30: Do you agree that existing flexibilities to agree how service charge demand forms are provided should continue to apply?

There were 751 responses to this question.

Option	Total	Percent
Yes	396	53%
No	355	47%

Question 30 (free text): Please explain your answer

There were 421 direct responses to this part of the question.

The consultation offered two options for a budget. Option 1 was high level, focused on a number of headings for key services for which landlords would charge. Option 2 was more detailed, providing additional subheadings. Of the two budget options provided, the majority of respondents favoured budget option 2. This included the majority of leaseholder responses and those of leaseholder representative groups, who felt it would require landlords to provide more granular detail, and improve transparency.

There were a number of landlord respondents who favoured option 2, but who typically said in their responses that whilst sub-headings should be included within the budget, they should not be prescribed, because of the varied definitions landlords across the sector use for subheadings.

Most landlords favoured option 1 on the grounds that a more succinct budget breakdown was sufficient, and that the level of information proposed in option 2 was not necessarily relevant or important to residents and could overwhelm them.

The vast majority of respondents supported the proposal to include details of the budget within either the annual report or the service charge demand form. Both landlords and leaseholders favoured including the budget within the service charge demand form, as it would provide full context for what residents are being charged and why, and therefore is the more relevant document.

The clear majority of respondents broadly agreed with the proposal for the interim demand form. The majority of respondents also supported proposals not to include the budget in any interim form, with landlord respondents in particular feeling that to do so would be both costly and unnecessary.

Many leaseholder respondents supported the proposed reconciliation form where it provided additional information on overspend or underspend, but some proposed that it should be accompanied by a table with a comparison of actual expenditure against the estimated budget. Some local authority respondents cautioned that it would be difficult to provide narrative explanations of actual spend compared to estimates where they have large portfolios. A few local authority respondents called for exemptions where the information and accounting practices do not align with proposed forms, and they would encounter difficulty in presenting information as required.

The clear majority of respondents broadly opposed exemptions to providing the service charge demand forms using standardised forms, in order to best ensure transparency for leaseholders. A few respondents, mainly landlords, argued that only the information should be prescribed, and that landlords should be able to determine how best to present the information to leaseholders, to accommodate the different ways in which landlords define services and provide breakdowns based on portfolios.

A small majority of leaseholder respondents, and a large majority of landlords were in favour of providing and receiving the form digitally. This was because digital methods tended to be viewed as easier to access, and cheaper to provide. Several responses pushed for digital means to become the default, acknowledging the standardisation of digital communication; however, others noted that it was important that leaseholders be given a choice in how they receive information, particularly if they have difficulties accessing digital information.

Government response

The government will prescribe that the budget should accompany the initial demand form. It will be based on option 1 of the consultation proposals and include an expanded list of high-level headings. In doing so, we will allow landlords to provide further breakdowns of headings to outline individual costs to suit their particular circumstances.

We will work with stakeholders to finalise the exact detail of the budget before introduction.

The government will prescribe that the demand form must be provided by post, in line with terms in individual leases, unless leaseholders agree that the information may be provided digitally.  

As proposed in the consultation, the government will prescribe that the interim and reconciliation demand forms will mirror the format of the initial demand form, to ensure consistency. We will not require the budget to accompany these forms.

We will prescribe a bespoke demand form for local authority landlords, to reflect the specific circumstances in which they operate.  

In the interests of transparency and equality of experience across the leasehold sector, the government will not exempt leaseholders or PRP tenants with fixed service charges.

Questions 31 to 35: Transition and cost

Question 31: Landlords and managing agents only: Is there any information for the proposed service charge demand and annual report that you do not already collect?

There were 129 direct responses to this question.

Option	Total	Percent
Yes	57	44%
No	72	56%

Question 31 (free text): If yes, what is this information and how much time and cost would it take to collect this information?  

There were 51 direct responses to this part of the question.

Question 32: Landlords and managing agents only: Do you use management software, or do you manually process demands?

There were 126 direct responses to this question.

Option	Total	Percent
Professional management software	51	22%
Manually process	47	20%
Other	28	58%

Question 32 (free text): If other, please provide details

There were 27 direct responses to this part of the question.

Question 33: Landlords and managing agents only: Would you need to make significant adjustments to your systems to meet the new information requirements?

There were 140 direct responses to this question.

Option	Total	Percent
Yes	115	84%
No	25	16%

Question 33 (free text): If yes, would any adjustments be outsourced (for example, to an IT software provider)?

There were 107 direct responses to this part of the question.

Question 34: Landlords and managing agents only: How long would it take and how much would it cost you (or, if outsourced, the provider) in terms of set up costs to adjust systems to collect and provide the information proposed in the demand forms or annual report and thereafter additional ongoing costs?

Please provide a breakdown of both set up costs which may be required and any additional costs of providing the information on an ongoing basis after set up.

There were 113 responses to this question.

Question 35: Do you agree that 12 months is an acceptable transition period for landlords to prepare for the new demand form and annual report arrangements to commence?

There were 785 responses to this question.

Option	Total	Percent
Yes	530	68%
No	255	32%

Question 35 (free text): If no, what should be an appropriate period and why.

There were 248 direct responses to this part of the question.

A small majority of social landlord respondents said they did not currently collect certain information within the proposed annual report, while a larger majority of private landlords said they did. However, even where landlords did collect the information, some noted that it could be held by third parties, making it difficult to access.

Most landlords utilised either software, or a blend of software and manual processes to provide their current annual reports and demand forms. Some noted that even where they were largely automated or using software, there would need to be manual alterations in order to provide the proposed forms to their residents.

A clear majority of landlords said they would need to make adjustments to their systems. Some landlords would need to make time-intensive manual changes if they did not update their systems to accommodate for the proposals. For some, the required information was held, but not collected together in a way that could currently be provided as set out in the proposed forms.

Many landlords noted that much of this work would need to be outsourced to external providers, who would be required to develop the necessary software and provide support with implementation.

A very small number of landlords provided an indication of the costs involved, both in terms of set up costs to adjust systems to collect and provide the information proposed in the demand forms or annual report, as well as additional ongoing costs. Of those the majority indicated that the costs would be high, with costs estimating from tens of thousands to hundreds of thousands. A minority indicated that costs would be low, small or insignificant. Some respondents said set up costs would be the bulk of costs, whilst others said ongoing costs would be significant, even matching initial costs.

A majority of leaseholder respondents felt that a 12-month transitional period was sufficient, whilst some believed this was longer than necessary, and that landlords demonstrating good practice should be able to meet the proposed requirements already.

Most landlords broadly said that 12 months was insufficient to provide the annual report and service charge demand form, and that they would need longer, typically around 24-36 months, but some said they would need as long as five years. In explaining their position, landlords frequently cited the need to update and implement new systems, hire and train new staff, prepare leaseholders for additional costs/charges, and needing to liaise with/depend upon software providers. Some landlords also cautioned that software providers themselves will struggle with high demand from landlords, given the requirements being sector-wide. Landlords said this will also contribute to the time required to implement new systems.

A majority of social landlords said they would need more time to transition, due to differing accounting practices and formats not aligning with the requirements within the proposed demand form, as well as the time required for software providers to reconfigure systems as needed to complete the proposed documents.

Government response

The government is grateful for the constructive feedback on the operational and financial impact of the proposed annual report and service charge demand form. We have taken full account of these issues when considering all the measures under the proposed new service charge accounts regime.

We have carefully considered the arguments for a transitional period. On balance, we plan to give private landlords 12 months’ notice of the measures, and social landlords 24 months’ notice. We consider this represents an appropriate balance between the need for landlords to adjust their processes and systems, and the need to ensure that leaseholders can experience the benefit of these measures as soon as possible. In doing so, we also recognise that social landlords will require additional time to prepare since they have accounting practices and larger portfolios that will make it particularly challenging to take the actions necessary to meet the requirements of the new proposed forms when compared to landlords in the private sector.

3. A new notice of future service charge demands

Questions 36 to 38: Form, content and grounds for extension

Question 36: Do you agree with the proposed structure and content of the future demand notice in Annex C?

There were 781 direct responses to this question.

Option	Total	Percent
Yes	565	72%
No	216	28%

Question 36 (free text): If no, what changes do you consider are needed and why?

There were 203 responses to this question.

The majority of respondents, including both leaseholders and landlords, supported prescribing the format of the future demand notice. Many respondents agreed that the level of information in the proposed notice (estimated costs, individual leaseholder costs, and expected date of demand) was important for increasing transparency for leaseholders.

However, some respondents, particularly leaseholders, felt that the notice should go further and suggested the notice should include additional information, such as the legislation under which the notice is being issued under, to boost transparency and understanding. In contrast, a small number of landlords and managing agents raised concerns about the availability of the required information, particularly the estimated demand date, which they stated could be difficult to predict.

Some respondents also highlighted the need for clarity and guidance, including on when the 18-month period commences, the reason the notice has been issued, and what rights leaseholders have to dispute charges they feel are unreasonable.

Question 37: Do you agree with the proposed grounds for extending the estimated demand date?

There were 757 responses to this question.

Option	Total	Percent
Yes	535	71%
No	222	29%

Question 37 (free text): If no, under what other reasons should landlords be able to change the demand date?

There were 178 direct responses to this question.

The majority of respondents, including most leaseholders and landlords, supported the two proposed grounds, but many respondents highlighted the need for transparency and clear communication between parties.

However, some respondents, mainly landlords, opposed the proposals as they felt that they were too restrictive and would not provide sufficient flexibility in unavoidable circumstances which could delay the demand beyond the expected date. Several respondents provided suggestions for additional valid grounds to cover these circumstances. Some landlords and managing agents also raised concerns about the potential to create additional administrative burden.

Some leaseholders felt that extensions should not be allowed under any circumstances. Similarly, many leaseholders called for strict controls on any extensions, including requiring the provision of evidence and imposing maximum time limits, to prevent exploitation by landlords.  

Question 38: Should we legislate so that costs should not be recovered if the time limit has lapsed on the initial future demand notice or capped if the estimate on the initial notice has been exceeded?

There were 775 responses to this question.

Option	Total	Percent
Yes	646	83%
No	129	17%

Question 38 (free text): If no, please explain why and what limitations you would consider acceptable?

There were 117 direct responses to this question.

There was very strong support, including from the clear majority of leaseholders, for legislating so that costs are not recoverable if the time limit has lapsed on the initial future demand notice, and to cap costs if the estimate on the initial demand notice has been exceeded. Many respondents agreed that this would strengthen transparency and support effective financial planning.

However, most landlords and managing agents opposed this measure, citing the need for flexibility where there has been a reasonable delay or increase in costs due to circumstances beyond the landlord’s control, such as unplanned additional works.

Several respondents raised concerns about the potential for estimates or timelines to be inflated to provide a cushion and reduce the risk of not being able to recover costs. This could negatively impact leaseholders by reducing transparency and affordability.

Some respondents also raised concerns about responsibility for covering any shortfall where costs could not be recovered, particularly the potential implications for landlords of smaller blocks, resident-controlled buildings, and local authorities, who may not have sufficient funds to cover any shortfall where costs could not be recovered. This could lead to poor building management and upkeep or, in extreme cases, insolvency.

Government response

The government will take forward action on standardising the future demand notice to ensure consistency and transparency for leaseholders. In response to concerns about the level of information being insufficient, the prescribed notice will expand on the level of information consulted on (estimated costs, individual leaseholder costs, and expected date of demand) to further support understanding and transparency. We will also provide information on the legislation under which the notice is being issued and on leaseholders’ rights.

Where the landlord is not able to issue the service charge demand before the specified date, the government will allow landlords to change the demand date provided but explain to leaseholders why a further extension is required.

The government has carefully considered feedback on preventing costs from being recovered where the time limit has lapsed on the initial future demand notice, or capping costs where the estimate in that notice has been exceeded.

On balance, while these proposals could provide more certainty and protections for leaseholders, we recognise that there are several areas which require further work to ensure they function as intended. We plan to commence this measure as soon as possible in 2027.

4. Extended rights to obtain information on request 

Questions 39 to 41 and 46: Information that can be requested and limits on the duty

Question 39: Do you agree with the proposed list of information that leaseholders can request from their landlords in Table 1?

There were 913 responses to this question.

Option	Total	Percent
Yes	626	69%
No	287	31%

Question 39 (free text): If no, what changes do you think are needed?

There were 272 direct responses to this question.

Question 40: Do you agree with the proposal to give leaseholders the right to request to retrieve documents relating to matters for up to 6 years?

There were 867 responses to this question.

Option	Total	Percent
Yes	700	81%
No	167	19%

Question 40 (free text): If no, please explain why.

There were 164 direct responses to this question.

Question 41: Please comment or suggest any changes to the proposals to the enhanced rights to request information

There were 468 responses to this question.

Question 46: Do you agree with the proposed exemptions to the duty to provide requested information?

There were 833 responses to this question.

Option	Total	Percent
Yes	428	51%
No	405	49%

Question 46 (free text): If not, what exemptions, if any, do you think should be provided and why?

There were 347 responses to this question.

Just over half of all respondents supported the principle of strengthening the right to obtain information on request, noting that it would improve transparency and enable more effective scrutiny and challenge of service charges and building management. However, consultation responses highlighted a number of consistent concerns about how the regime would operate in practice, particularly in relation to scope, proportionality, and deliverability.

Many respondents broadly welcomed a defined list of information, but emphasised that it must be proportionate, clearly connected to service charges and building management, and capable of being applied consistently. Some respondents, particularly landlords were concerned that an overly extensive list could capture information of limited value or impose unnecessary administrative burden. In contrast, others supported expanding the list, particularly in areas that drive costs and decision-making, such as contracts, invoices, reserve funds, insurance, conflicts of interest and major works. Some respondents, particularly leaseholders, also emphasised the importance of ensuring the list remains sufficiently flexible to reflect changes in practice over time.

Some respondents expressed concern about the practical operation of the proposals, particularly where documents may not be held or are difficult to obtain. These respondents highlighted challenges where managing agents have changed and records have not transferred, where information is held by third parties, or where records pre-date current systems and retention practices.

Some respondents also raised concerns about the usability of certain categories of information, particularly technical documents which may be complex and difficult to interpret. While these respondents supported greater transparency, they questioned whether additional requirements would be justified given the extra cost, risk or resource involved .

On the question of how far back the duty should extend, respondents highlighted a clear trade-off between transparency and proportionality, noting that longer timeframes would support meaningful scrutiny over time, while shorter periods may be more proportionate where historic records are incomplete or difficult to retrieve. A few respondents raised suggestions to tailor the period to ownership, lease length or current management tenure rather than applying a single fixed timeframe.

Many respondents also raised concerns about the application of exemptions, whilst recognising that some limits were necessary, particularly in relation to commercially sensitive information and vexatious requests. Respondents, especially leaseholders, considered that these should be narrowly framed, clearly justified and supported by safeguards. Many respondents emphasised that broadly applied exemptions could undermine the effectiveness of the regime, particularly in relation to the vexatious request exemption, where repeat requests arise from incomplete or unclear responses rather than misuse.

Government response

The government will introduce a clear, prescribed statutory list of information that leaseholders are entitled to request. This list will be limited to information relating to service charges and the management, maintenance, repair, improvement and insurance of dwellings. We will create a bespoke, smaller list for PRP tenants in light of the information that will be available to them through STAIRs. This approach will provide consistency and clarity, while addressing concerns about uncertainty and variability in current practice. The government will prepare non‑statutory guidance to encourage provision of additional relevant information beyond the prescribed list where appropriate, and to support consistent interpretation and delivery.      

Landlords will be required to take reasonable steps to obtain relevant information, but will not be expected to produce material that is not held or cannot reasonably be obtained, provided that this is clearly explained to the leaseholder. Where information cannot be provided, landlords will be required to explain this clearly to the leaseholder.

In relation to historic information, the government will legislate so that landlords must provide information going back six years. This provides a clear and consistent timeframe that supports meaningful scrutiny of service charge costs and management decisions, while remaining proportionate and aligned with common record-keeping and limitation periods. This approach balances the need for transparency with the practical challenges of retrieving older information, and avoids the inconsistency and complexity that could arise from tailoring the look-back period to individual circumstances.

To ensure that the framework remains proportionate and workable, the government will allow landlords to satisfy the statutory requirement by directing leaseholders to existing documents where those documents fully provide the required information, rather than requiring unnecessary duplication. Supporting guidance will promote consistent interpretation and application across different sectors and management arrangements.     

Exemptions to the requirement to provide the prescribed list of information will be limited and tightly defined. The government will adopt a ‘disclose and redact’ approach to commercially sensitive information, ensuring that only genuinely sensitive elements are withheld. We will also set out a narrowly framed provision for vexatious requests, supported by indicative factors rather than a rigid definition. The framework will also recognise that in some cases historic information may no longer be held and cannot reasonably be obtained, including because records were disposed of in accordance with pre-existing retention practices. In such cases, the landlord will be required to explain clearly why the information cannot be provided. Supporting guidance will be developed to support the use of these exemptions.

The government considers that, taken together, these measures strike a balance between maximising transparency for leaseholders and ensuring that the regime remains operable, proportionate and enforceable in practice.

Questions 42 to 44: Process and timeframes for providing information

Question 42: Do agree that 28 calendar days is a reasonable timeframe for a landlord to provide requested information to a leaseholder (in Table 1)?

There were 895 responses to this question.

Option	Total	Percent
Yes	615	69%
No	280	31%

Question 42 (free text): Please provide reasons for your answer.

There were 469 direct responses to this question.

Question 43: Do you agree with the circumstances under which the overall 28 day time period should be extended, and the proposal to allow an additional 7 extra calendar days?

There were 808 responses to this question.

Option	Total	Percent
Yes	501	62%
No	307	38%

Question 43 (free text): Please provide reasons for your answer.

There were 378 direct responses to this question.

Question 44: Do you agree that the Receiving Party should respond to the landlord’s request within 15 days?

There were 786 responses to this question.

Option	Total	Percent
Yes	633	81%
No	153	19%

Many respondents supported the introduction of clear and enforceable timeframes, recognising the importance of timely and predictable access to information. However, consultation responses highlighted a consistent trade-off between simplicity and practicality, with mixed views on whether a single fixed timeframe would be appropriate across different types of requests.

While some respondents, particularly leaseholders considered a standard deadline (such as 28 days) to be clear and workable, for straightforward or information that is readily available, others questioned whether a single timeframe could accommodate the wide range of requests a landlord may receive. Many respondents, particularly landlords argued that 28-days would not always provide enough time to provide the requested information. This was especially the case where requests may span multiple years, involve large volumes of material, require archive retrieval, or depend on information held by third parties.

A recurring theme was the importance of aligning timeframes with the nature and scope of the request. Respondents emphasised that more complex or historic requests would reasonably require additional time, while more recent or routinely held information should be provided more quickly.

Many respondents identified third parties as playing a key role affecting delivery. Several respondents emphasised that landlords should remain accountable for providing information, even where it must be obtained from third parties. At the same time, the majority of respondents agreed that frameworks should require early identification of third party dependencies and prompt onward requests, supported by clear communication where this affects delivery.

Some respondents also highlighted the importance of transparency throughout the process of requesting information, including acknowledgement of requests, regular updates, and clarity about expected response times.

Respondents consistently emphasised that extensions should be limited, clearly justified and not used routinely. There was concern that, without clear constraints, extension provisions could undermine the effectiveness of the regime. Respondents also highlighted that timeframes would only be meaningful if supported by clear expectations of compliance and accountability.

Government response

The government will introduce a proportionate framework for responding to requests, designed to reflect the nature and complexity of the information requested while maintaining clarity and predictability for leaseholders. Rather than relying solely on a fixed deadline, the government will adopt a structured approach to response timeframes, including a sliding scale, that links response times to the age and scope of the information requested. This will enable more straightforward requests to be fulfilled within shorter timeframes, while allowing appropriate flexibility, and a longer time period, where requests involve historic information, larger volumes of material or third party retrieval.

Landlords will be required to follow a clear and transparent process when responding to requests. This will include prompt acknowledgement of requests, provision of updates where information is being obtained from third parties, and delivery of a single, consolidated response rather than fragmented disclosures. To support third party retrieval, landlords will be expected to act promptly in seeking information within a defined internal timeframe of 15 working days. However, landlords will remain fully responsible for meeting the overall response deadline, and the time period for responding to the request will not be stopped because of delays by third parties in providing information.

The government will also set clear expectations on how the overall response timeline operates, including the interaction between the main response period, any permitted extensions, and the process for obtaining information from third parties. This will provide a coherent and predictable system, reducing ambiguity and ensuring that leaseholders understand when information can be expected.

Question 45: Inspection of documents in person

Question 45: Do you agree that leaseholders should have a maximum of three months after making a request to inspect documents in person?

There were 813 responses to this question.

Option	Total	Percent
Yes	568	70%
No	245	30%

Question 45 (free text): Please provide reasons for your answer and any changes you consider necessary.

There were 407 responses to this question.

Many respondents supported retaining the option for in‑person inspection, recognising that some leaseholders may prefer or require this form of access. However, several responses, including many landlords, highlighted a range of practical challenges associated with delivering an in‑person inspection regime, particularly in the context of modern management practices.

Some respondents emphasised that in‑person inspection may be difficult to deliver where landlords or managing agents have limited physical premises, particularly where portfolios are geographically dispersed or primarily operated on a digital basis. Some respondents also expressed concern about the ease of accessing documents, highlighting barriers for leaseholders who live remotely or face mobility, health or time-related constraints.

Respondents consistently emphasised the importance of prioritising digital provision as the primary method of sharing information, given its accessibility and efficiency, with in‑person inspection operating as a supplementary access route. A few respondents were concerned that reliance on physical inspection could create barriers to access.

There were mixed views on how the inspection window should operate. Several respondents accepted the principle of a defined period, some considered a period of up to three months to be reasonable, while others called for greater flexibility to reflect individual circumstances. There were also mixed views on when the inspection period should begin, with some respondents favouring a start point from the date of request for clarity, and others suggesting it should begin when documents are available.

Government response

The government will retain a right for leaseholders to inspect documents in person, recognising that this remains an important access route in certain circumstances. However, we will ensure that this right is both practical and proportionate, taking account of the operational and accessibility issues raised through the consultation.

The framework will provide a defined inspection period of up to three months from the date of request, providing clarity and consistency while allowing extensions to be agreed where necessary. Landlords will be required to ensure that inspection arrangements are reasonable and accessible, taking account of factors such as location, individual circumstances and the nature of the documents requested.

Alongside this, the government will reinforce the expectation that information should be provided in a digital and accessible format wherever possible, thereby reducing reliance on physical inspection as the primary route of access. Where documents are available electronically, landlords will not be required to create additional physical copies solely for in-person inspection, ensuring that the regime remains proportionate while still enabling leaseholders to access the information they need.

Supporting non-statutory guidance will set out expectations on how inspection rights should operate in practice. This will include guidance on suitable arrangements for inspections, accessibility considerations, use of electronic viewing where appropriate, and how landlords and managing agents should work with leaseholders to agree practical solutions where standard arrangements are not suitable.

5. Application of proposals to those who rent    

Question 47: Do you agree that social housing tenants of Private Registered Providers and Registered Social Landlords should receive an annual report and right to access specific information?

There were 452 responses to this question.

Option	Total	Percent
Yes	402	89%
No	50	11%

Question 47 (free text): Please explain your answer.

There were 211 responses to this question.

The majority of respondents, particularly tenants and representative organisations, supported improving transparency for social tenants, although they held different views on how this should work in practice. Landlords expressed concerns around proportionality, cost, and the administrative burden associated with any new requirements.

Many social tenants, leaseholders, and representative groups expressed support for parity and fairness across tenures, and believed that tenants should have access to the same information as leaseholders. This included the annual report and access to information. These responses emphasised transparency, and accountability, consistency, and avoidance of a two-tier system in mixed-tenure buildings. However, some leaseholder respondents suggested that the annual report should only be provided where tenants pay service charges or contribute to communal costs, rather than universally across all tenants.

In contrast, some tenant and leaseholder respondents, and a small number of landlord respondents raised concerns about tenants receiving too much information so as to be confusing. Some landlord and tenant respondents said that any requirements should be relevant to social tenants, they argued that the annual report contained too much information and could be overwhelming and inaccessible, particularly for more vulnerable tenants or those in supported housing settings. These respondents supported transparency in principle but emphasised the need for information to be clear, proportionate, and user-friendly. However, a small number also questioned the practical benefit of expanded access where tenants do not hold equivalent legal rights to challenge charges or may not directly bear costs .

Most landlord respondents raised concerns about cost, and deliverability. These included the time required to produce annual reports, system changes, and the cumulative cost of implementation across large housing portfolios. In doing so, several landlord respondents also highlighted overlap with existing requirements, for example with STAIRs, and argued that consequentially most of these proposals were unnecessary for social tenants.

Some respondents said an annual report could be provided through multiple formats such as online, or through existing communication channels, as well as using clear, plain language. Some landlords also proposed that information should be made available on request or via signposting, rather than through an annual report issued to all tenants.

Some landlord respondents noted however that in situations where a housing association is the head lessor, information will need to be provided to tenants by the registered provider rather than the superior landlord.

Question 48: Would you suggest any modifications to our proposed format of the annual report and information that may be requested?

There were 389 responses to this question.

Option	Total	Percent
Yes	137	35%
No	252	65%

Question 48 (free text): If no, please give your specific reasons

There were 68 direct responses to this question.

Many respondents supported the proposed approach to the format of annual reports and information requests for social housing tenants of PRPs, or emphasised the importance of greater transparency, particularly clearer and more detailed financial information, such as itemised cost breakdowns and access to supporting documentation. This was most commonly raised by individuals focused on improving scrutiny of service charges.

Many respondents, particularly organisations, raised concerns about cost, proportionality and administrative burden, including the resources required to produce reports, duplication with existing requirements, and the risk of costs being passed on to tenants. Some suggested that information should instead be provided on request or through digital channels.

Some respondents, particularly individuals, emphasised that information should be relevant and tailored to the specific building or services paid for, while others highlighted parity across tenures, noting that tenants, leaseholders and shared owners should have access to comparable information and rights.

Some respondents supported simplifying reports for clarity and accessibility, while others emphasised that simplification should not lead to the omission of key information. A number of respondents also proposed expanding the scope of information, including performance, safety or procurement-related information.

A smaller number of respondents supported standardisation of the format across providers, while others favoured greater flexibility to reflect different tenancy types or operating models. A minority of respondents, primarily organisations, suggested that the requirements should be reduced or removed.

Question 49: What would be the additional cost to Private Registered Providers and Registered Social Landlords of obtaining and supplying this information to social housing tenants? Please provide a breakdown of both initial costs and long term sustained additional costs. 

There were 141 responses to this question.

Question 50: Do you think that 12 months is an acceptable transition period for Private Registered Providers and Registered Social Landlords to adjust their systems and train their staff to the new arrangements? 

There were 398 responses to this question.

Option	Total	Percent
Yes	281	71%
No	117	29%

Question 50 (free text): If no, what should be an appropriate period and why?

There were 111 direct responses to this part of the question.

There was a range of responses to the question about additional costs to PRPs and Registered Social Landlords of obtaining and supplying information to social housing tenants. Several respondents, mainly individual leaseholders, claimed that social landlords already hold the required data, and considered that providing the information would require only limited work, such as collation or formatting. Other leaseholders considered that there should be no additional costs associated with this, or that the proposals would not introduce a materially new cost burden.

Several responses identified printing, photocopying and postage as key sources of additional cost, particularly where information must be distributed at scale. All stakeholder groups considered that greater use of digital systems would minimise or reduce costs.

In contrast, some respondents, mainly social landlords and managing agents, argued that there would be a range of additional costs incurred. This might vary depending on provider size, systems currently in place and capability. The level of cost would vary considerably – from additional staff and administrative burden to improvements to IT systems and data management costs. Many organisations stated that they could not estimate costs accurately until they had a clearer understanding of the detailed proposal, but some added that they could be substantial. Some respondents pointed out that costs would be passed on to leaseholders and tenants.

There was also a wide variety of responses on the length of any transitional period. Several respondents agreed with the 12-month transitional period, so that it could align with the financial and reporting cycles and allow time of staff training and preparation of relevant IT systems. In contrast several other respondents, including most landlords and managing agents, considered that 12 months was insufficient time period and advocated a long period (principally between 18-36 months). The main grounds for doing so were the need to upgrade and procure IT systems (including integrating data and testing outputs), as well as the need to train staff and embed new processes.

Several respondents, mainly individual leaseholders called for a shorter transitional period. They argued that information and systems already exist, and that only limited changes would be required. A few respondents called for a phased transitional period to tie in with managing workloads, system changes and communications with residents.

Government response 

The government will legislate so that PRP tenants who pay both fixed and variable service charges will receive a standardised service charge demand form. However, landlords will not be required to provide these tenants with an annual report given the introduction of STAIRs from October 2026. In addition, we will give them access to a defined list of information under our right to request information measures.

6. New duty to publish administration charge schedules 

Questions 51 to 53: Structure, content and how leaseholders can access it

Question 51: Do you agree with the proposed structure and contents of the administration charge schedule as set out at Annex D?

There were 731 responses to this question.

Option	Total	Percent
Yes	568	78%
No	163	22%

Question 51 (free text): If no, what changes do you think are needed?

There were 151 direct responses to this question.

Question 52: Do agree that landlords should make the administration charge schedule available on request (see Table 1), in addition to as part of the annual report?

There were 747 responses to this question.

Option	Total	Percent
Yes	707	95%
No	40	5%

Question 53: Are there any other situations when landlords should be able or required to provide the administration charge schedule to leaseholders?

There were 370 responses to this question.

The majority of respondents supported the introduction of an administration charge schedule as a means of improving transparency about the charges leaseholders may face and helping them understand costs in advance. However, some respondents highlighted concerns about how the schedule would operate in practice, particularly in relation to the presentation of the information, treatment of variable costs and accessibility.

Some respondents considered the administration charge schedule overly detailed and suggested that it should be simplified to make it easier for leaseholders to identify relevant charges. Others supported a more detailed approach, provided that the information remained clear and easy to navigate.

Many respondents raised concerns about the treatment of variable and third party costs. Several landlords, managing agents and representative bodies highlighted that the cost of dealing with some requests often depend on factors outside their direct control, such as the involvement and cost of external professionals, or the scope of work required. These respondents also raised concerns about the use of fixed estimates where costs may vary significantly, and favoured an approach to provide greater transparency about how charges would be calculated, including clearer explanations of the methodology used and the provision of supporting evidence.

Some respondents were concerned that the schedule could be perceived as legitimising any level of administration charges set out, and emphasised the importance of making clear that these charges remain subject to existing legal protections, for example that they must still be reasonable. Some respondents suggested that the schedule should include clear signposting of routes to challenge.

A smaller number of respondents stressed the importance of leaseholders’ ability to identify when a schedule was issued and which is the updated version that should be used.

Some respondents also highlighted that the responsibility for administration charges may be shared across multiple parties depending on the management structure - including scenarios where there are landlords, managing agents and right to manage companies. These respondents emphasised the need for clarity about who is responsible for preparing, maintaining and providing the schedule.

Many respondents supported making the administration charge schedule available through the annual report and on request. The majority of respondents favoured digital access (for example via a website or portal) to improve accessibility and transparency of the charges. Some respondents suggested additional circumstances in which the schedule could be provided or signposted towards, such as during conveyancing transactions or a change in management arrangements. In contrast other respondents argued that mandating publication of the schedule in multiple circumstance could create duplication and increase administrative burden.

Government response 

The government will legislate to require landlords to produce an administration charge schedule to improve transparency about administration charges leaseholders may be liable to pay. We will prescribe the format of the schedule to ensure consistency and comparability across buildings, while allowing landlords to populate the schedule to reflect the administration charges that apply in their specific circumstances.

In response to feedback about complexity and clarity, we will simplify the template, while retaining the core requirement that the schedule clearly sets out charges that can be stated upfront and explain how other charges (‘unspecified costs’) will be determined where they cannot be fixed in advance. To address concerns about variable and third party costs, landlords will be required to set out a clear method for determining unspecified costs, including the factors that may affect the amount payable. This will be supported by non-statutory guidance to promote consistency of approach and improve transparency in practice.

The government will require the administration charge schedule to be provided as part of the annual report and be available on request at any time, with updated versions provided when changes are made. We have considered whether to mandate provision of the schedule in additional situations, but on balance, do not consider this proportionate where leaseholders will already receive the schedule annually and can request it at any time. We will support a digital-first approach where appropriate (for example via a website or portal), alongside appropriate alternatives for leaseholders who cannot or do not wish to access information digitally.

To ensure clarity about which schedule applies, the government will require the schedule to include a clear date of issue and effective from date. The law requires revised schedules to be published at least 28 days before any new charges take effect.

The administration charge schedule will provide clarity on responsibility for compliance. The legislation will identify the person responsible for complying with these requirements by reference to the person entitled to demand the relevant administration charge. Where functions are carried out in practice by a managing agent or another management entity, that person may act on behalf of the duty-holder, but responsibility for compliance will remain with the person on whom the duty is imposed by legislation.

Supporting non‑statutory guidance will set out expectations on how the schedule should be completed, updated and provided, including the treatment of unspecified costs, presentation of information and arrangements in more complex management structures.

7. Better information about insurance

Questions 54 to 57: Conflicts of interest and FCA level information

Question 54: Do you think that managing agents and landlords should also have to declare conflicts of interests with the insurance broker and insurer?

There were 862 responses to this question.

Option	Total	Percent
Yes	859	>99%
No	3	<1%

Question 54 (free text): Please explain your answer.

There were 528 responses to this question..

Question 55: Are there any other conflicts in the chain of organising, managing and providing insurance that should be declared to a leaseholder?

There were 498 direct responses to this question.

Many respondents supported the principle that managing agents and landlords should be required to declare conflicts of interest with insurance brokers and insurers. Many felt that current arrangements lack openness because of hidden commissions, financial incentives and close commercial relationships contributing to inflated premiums and undermining trust. A common concern was that leaseholders ultimately pay for insurance but have little visibility over how decisions are made or whether policies represent good value. Some respondents went further, arguing that disclosure alone may be insufficient and that certain practices such as the use of in-house brokers, captive insurers, or other vertically integrated arrangements, should be restricted or prohibited altogether.

Many respondents also highlighted the need for comprehensive disclosure across the full insurance chain, not limited to direct conflicts. This included transparency on commissions, referral fees, ownership links, and broader corporate or personal connections that could influence procurement decisions. Some emphasised the importance of demonstrating that the market has been properly tested, for example through obtaining multiple quotes, competitive tendering, and providing clear justification for the selected policy. A few respondents extended these concerns to surveyors, contractors, and claims handlers, arguing that any party with a potential financial interest should be covered by transparency requirements.

Question 56: Do you think that the FCA definition of a conflict of interest covers conflicts that are relevant to leaseholders?

There were 704 responses to this question.

Option	Total	Percent
Yes	456	65%
No	248	35%

Question 56 (free text): If not, how should conflict of interest be defined? Are there existing definitions of conflict of interest in other industries or countries that could be followed?

There were 215 direct responses to this question.

Question 57: If the information required under FCA rules, additional details about conflicts of interest and making a claim were sent to all leaseholders, would this be the right amount of information? 

There were 691 responses to this question.

Option	Total	Percent
Yes, this is the right amount of information	430	62%
Not enough information	214	31%
Too much information	47	7%

Question 57 (free text): If you answered yes, give reasons 

There were 163 direct responses to this question. 

Question 57 (free text): If you answered not enough information, give reasons. What additional information should be provided about building insurance?

There were 163 direct responses to this question. 

Question 57 (free text): If you answered too much information, please give reasons. What information should not be required to be shared with leaseholders?

There were 37 direct responses to this question.

Respondents expressed concern that the current definition of the Financial Conduct Authority (“FCA”) of a conflict of interest is too narrow and does not reflect the realities of the leasehold insurance market. Many highlighted that the focus on ownership thresholds and formal relationships fails to capture more common potential conflicts, such as commissions, referral fees, and commercial links between landlords, managing agents, brokers, and insurers. There was a strong view that these financial incentives can influence procurement decisions and lead to outcomes that do not consider leaseholders’ interests. As a result, many respondents supported a broader definition which would include any financial, personal or corporate relationships that could reasonably be seen to affect decision-making, on top of greater transparency over all payments, ownership structures, and third party arrangements.

Views on the proposed level of information disclosure were mixed. Many respondents welcomed increased transparency and felt that providing more information on policy terms, costs, commissions, and how to make a claim, would represent a significant improvement and help leaseholders better understand and challenge insurance charges. However, some argued that the proposals do not go far enough, calling for more detailed disclosures including breakdowns of premiums, alternative quotes, policy selection rationale and claims history. In contrast, a small number cautioned that excessive or overly technical information could be overwhelming, suggesting that more detailed material should be made available on request.

Government response

The government will introduce a set of requirements to improve transparency of building insurance information by extending and building upon existing FCA disclosure rules, which currently apply only to FCA-regulated firms.

We are considering requirements for landlords and managing agents to disclose relevant connections and remuneration arrangements with brokers and insurers. In response to consultation feedback, these requirements will go further than existing FCA rules by capturing a broader range of commercial relationships and incentives that may reasonably be considered to influence decision-making.

Feedback from consultation responses also demonstrated support for clearer insight into how costs are structured, and what policies cover. In response, we are considering requiring additional information around procurement and pricing of insurance policies to be provided, to ensure that leaseholders receive meaningful information to support understanding of the policy they pay for and assurance that procurement decisions reflect the interests of both policyholders and leaseholders. This includes better information about reinstatement costs and how insurance quotes are obtained and selected.

Questions 58 to 66: Provision of insurance information

Question 58: Do you think there should be any circumstances where the duty to provide information on insurance does not apply?

There were 746 responses to this question.

Option	Total	Percent
Yes	45	6%
No	701	94%

Question 58 (free text): If yes, please give detail on when you think the duty should not apply, for example a specific type of landlord or type of insurance.

There were 38 direct responses to this question.

Question 59: Should landlords be required to provide information in a set template?

There were 702 responses to this question.

Option	Total	Percent
Yes	636	91%
No	66	9%

Question 59 (free text): Please explain your answer. 

There were 391 responses to this question.

Question 60: What is your opinion of the proposed template provided at Annex E? Provide details.

There were 451 responses to this question.

Question 61: Should landlords be able to provide leaseholders with insurance information only by email?

There were 729 responses to this question.

Option	Total	Percent
Yes	276	38%
No	453	62%

Question 61 (free text): If the landlord can send insurance information only by email and does so, what safeguards, if any, should be put in place to make sure the leaseholder received it?

There were 456 direct responses to this question.

Question 62: Do you think 30 days is enough time to give landlords to provide building insurance information to leaseholders?

There were 702 responses to this question.

Option	Total	Percent
Yes	585	83%
No	117	17%

Question 62 (free text): If no, please give a reason and whether you think landlords should have more or less time to provide the specified information once the insurance comes into effect.

There were 115 direct responses to this question.

Question 63: Do you think there are any circumstances where this time period should be extended?

There were 704 responses to this question.

Option	Total	Percent
Yes	135	19%
No	569	81%

Question 63 (free text): If yes, give reasons and when you think the time period should be extended 

There were 122 responses to this question.

Question 64: Should landlords be required to request information from a third person in a certain way?

There were 549 responses to this question.

Option	Total	Percent
Yes	222	40%
No	327	60%

Question 64 (free text): If yes, please give reasons why.

There were 143 direct responses to this question.

Question 65: Should there be any circumstances where a person is exempt from the duty to provide information to the landlord?

There were 587 responses to this question.

Option	Total	Percent
Yes	52	9%
No	535	91%

Question 65 (free text): If yes, please give detail of the circumstances when you think the duty should not apply, for example a request for a certain of type of information or a category of third party that should be exempt.   

There were 35 direct responses to this question.

Question 66: Should there be a set time period within which a request for information from a landlord to a third party be made?

There were 613 responses to this question.

Option	Total	Percent
Yes	468	76%
No	145	24%

Question 66 (free text): If yes, what should that time period be?

There were 392 direct responses to this question

Overall, many respondents expressed a strong preference for limiting exemptions so that all leaseholders who pay for insurance can access relevant information. While some accepted that narrowly defined exemptions may be appropriate in specific circumstances, these were generally seen as exceptions. This focus on transparency was reflected in a broad support for a standardised template, with many considering it essential to ensuring consistency and clarity. However, some respondents highlighted the need to avoid unnecessary administrative burdens and to retain flexibility, particularly in more complex cases.

Views on our proposed template were largely positive, with many describing it as a helpful starting point that would improve the accessibility of information. Some respondents called for additional detail, particularly on commissions and conflicts of interest, while a small number raised concerns about duplication or the ability to reflect more complex arrangements. Views were mixed on delivering information by email only. Many supported digital delivery as efficient, but many also stressed the importance of safeguards to ensure accessibility for all leaseholders.

In relation to timing, many respondents considered a 30-day deadline for providing information to be reasonable, although some expressed concerns that this could be either too rigid or too slow depending on circumstances. Reflecting this, many respondents supported allowing limited extensions where delays arise, particularly where information is required from third parties or in complex cases, but respondents emphasised that extensions should be tightly controlled. More broadly, many respondents supported strengthening accountability across the information chain, including clear requirements for landlords when requesting information from third parties and strong expectations that third parties should not be exempt from requirements to provide information. Many also favoured introducing defined timeframes for information requests to third parties, although views varied on whether this should be fixed or more flexible.

Government response

The government agrees that all leaseholders should benefit from the same level of transparency and that this must be applied consistently across the sector. We are therefore not considering exemptions to the duty to provide insurance information, neither in specific circumstances nor on an individual basis, as consultation feedback demonstrated strong support for a common approach and highlighted that carve-outs would introduce complexity and risk creating gaps in transparency.

To facilitate consistent implementation across the sector, we are considering requiring information to be delivered in a single standardised document. This approach is intended to improve accessibility, promote the use of plain and simple English, and support leaseholders in easily identifying and comparing relevant insurance information. Landlords will be able to provide information either by post or digitally, taking into account lease requirements about how documents are to be sent. This flexibility would also allow landlords to consider leaseholders’ communication preferences.

In addition, we will introduce clear deadlines for the provision of this information, including where the landlord needs to obtain information from third parties. We recognise that information may need to be obtained from multiple parties and that leaseholders may not always be certain where delays arise. To address this, and reduce the risk of parties being blamed unfairly for delays from others, we are considering a mechanism to enable leaseholders to identify delays or gaps in disclosure and hold the responsible party to account.

Questions 67 to 69: Transitional arrangements   

Question 67: [If you are a landlord or managing agent] What do you think transitioning to these new arrangements would cost your organisation? Provide details.

There were 108 direct responses to this question.

Question 68: [If you are a landlord or managing agent] How much would it cost you to obtain the required information that you do not currently have? Provide details.

There were 88 direct responses to this question.

Question 69: Do you think that 3 months is the right amount of time to allow landlords and managing agents to adjust their systems and train their staff to carry out the new arrangements?

There were 619 responses to this question.

Option	Total	Percent
Yes	480	78%
No	139	22%

Question 69 (free text): If not, what would be the right amount of time and why?

There were 137 direct responses to this part of the question.

Responses were varied and often inconclusive, with many respondents stating they could not provide meaningful cost estimates due to a lack of certainty around which of the proposed requirements would be implemented. Without clear guidance, many viewed any attempt to quantify costs as speculative, particularly given differences in complexity, reliance on third parties for information and existing capabilities of organisations , including smaller and less resourced landlords and managing agents.

Overall, views on cost fell into three broad positions: many expected minimal or no additional cost where information is already held, many others were unable to estimate costs due to uncertainty and third party dependencies, and a smaller number anticipated potentially significant or variable costs, particularly where new systems, processes, or staffing may be required. Respondents also noted that costs may ultimately be passed on to leaseholders.

Among those who provided estimates, additional administrative burdens emerged as the most consistent theme, with many highlighting the time required to gather information from multiple systems, format it into new templates, and respond to increased queries from leaseholders. IT-related costs were also commonly raised, including system updates and template integration, although these varied widely depending on existing capabilities.

Government response

We plan to give 12 months’ notice of the measures for the relevant parties to make the required adjustments to their processes and systems. This acknowledges that compliance with the new requirements will require coordination across the insurance distribution chain, given that relevant information may be held by multiple parties, including landlords, managing agents, brokers and insurers. The government considers that the transitional period will allow the sector sufficient time to make the necessary operational, contractual and system changes, including adapting existing processes for collating and sharing information, and to embed new approaches in a consistent and sustainable way.

8. New standardised service charge accounts  

Question 70: Minimum information in accounts

Question 70: Do you agree that accounts must include the following minimum information:

a. a balance sheet for the service charge fund which sets out the assets and liabilities of the block

b. an income and expenditure account and explanatory notes

c. sinking fund or reserve funds statements (where applicable)

d. a statement of service charge collection deficits

There were 806 responses to this question.

Option	Total	Percent
Yes	692	86%
No	114	14%

Question 70 (free text): If no, what should be different, why and in what circumstances (please be specific)?

There were 113 direct responses to this question.

The vast majority of respondents, mainly individual leaseholders, supported the standardisation of service charge accounts. Many respondents agreed that the proposed minimum information set out in the consultation (balance sheet, income and expenditure account with notes, reserve/sinking fund statements, and collection deficit statements) was essential for transparency and accountability, as well as enabling benchmarking between developments.

Several respondents, especially leaseholders, provided further suggestions on measures that would go further and include additional data as part of the accounts. For example, some respondents called for the expansion of the income and expenditure account to include a comparison of actual expenditure between years. However, other respondents had concerns with one or more of the four components. There were mixed views over the proposal for accounts to include a statement on collection deficits, where several landlords and leaseholders expressed concerns about data protection and the social impact on individuals in a block, as well as practical difficulties in reporting.

Several respondents recognised that the diversity of the leasehold sector – including the size of blocks and nature of ownership – meant that a single approach may not be appropriate for all. Several respondents also called for a proportionate approach, and exemptions or alternative arrangements. Social landlords in particular argued that some of the requirements were costly and complex to deliver and ultimately would not be meaningful for tenants. They also felt that the overall regulatory framework around local authority accounting and registered housing providers was robust.

Several respondents also raised concerns about the added cost that would be incurred with increased reporting requirements, especially where systems needed to be upgraded or manual processes were required. Ultimately, this may increase costs for leaseholders, some of whom expressed that they were content with their current reporting processes.

Government response

The government will introduce a prescribed minimum set of information for service charge accounts, broadly reflecting the proposals set out in the consultation. Landlords will be required to provide a balance sheet, an income and expenditure account with explanatory notes, and sinking funds where applicable. Following feedback from stakeholders, the government recognises concerns raised by consultees about a separate and detailed dedicated collection deficit statement, for example the ability to identify individuals who have not paid and that it is only ever a snapshot in time. However, it is important that leaseholders understand the financial health of the accounts relating to their development and so an aggregate amount of unpaid service charges will be included as part of the accounts. We will prescribe the format of the accounts to ensure consistency and comparability across developments, while allowing landlords to populate them to reflect the specific charges and arrangements that apply. These measures will improve consistency and transparency, enabling leaseholders to better understand and scrutinise costs over time.

We recognise concerns about proportionality and will ensure that the requirements are clear and proportionate in practice, taking account of the diversity of the sector.

Question 71: Balance sheets

Question 71: Do you agree that, where there are multiple service schedules, a balance sheet should be provided with each schedule?

There were 751 responses to this question.

Option	Total	Percent
Yes	638	85%
No	113	15%

Question 71 (free text): Please explain your answer.

There were 306 direct responses to this question.

The vast majority of respondents, mainly leaseholders, considered that there should be a balance sheet provided with every schedule. The main arguments from those in favour were that the proposals would provide clarity, highlight any cross-subsidisation, and increase transparency. Some respondents in favour argued that the balance sheet should be simple and proportionate.

The minority of respondents who opposed the proposal, including many landlords, argued that the measures would incur excessive cost and add unnecessary complexity to the preparation of accounts. They also mentioned that it would be of no benefit to leaseholders, and argued that a single balance sheet per development would be more appropriate.

Government response

The government recognises the value of having a balance sheet for each schedule but is persuaded by the arguments that the additional costs involved will be excessive and add additional complexity for limited benefit when key information of relevance to leaseholders will be in the income and expenditure section of the accounts. We will legislate to only require a balance sheet per individual set of accounts.

Questions 72 to 75: Financial reporting standards and the written report

Question 72: Do you agree that ISRS4400 should be the default reporting standard for assuring service charge accounts?

There were 637 responses to this question

Option	Total	Percent
Yes	559	88%
No	78	12%

Question 73: Are there any other reporting standards, such as ISRE 2400, that should be followed?

Please be specific, including what any threshold for use should be.

There were 193 responses to this question.

Question 74: Do you agree with the format of the statement of declaration (at Annex G)?

There were 621 responses to this question.

Option	Total	Percent
Yes	538	87%
No	83	13%

Question 75: Do you agree with the proposals to expand the number of qualified people who can prepare the written report?

There were 627 responses to this question

Option	Total	Percent
Yes	533	85%
No	94	15%

Question 75 (free text): Explain your answer.

There were 309 responses to this question.

The vast majority of respondents agreed with the proposal that ISRS4400 was the most appropriate reporting standards for signing off accounts. In addition, there were many respondents who called for ISRE2400 to be used in some circumstances, with a range of suggestions based on the number of units in the development and/or the monetary size of accounts. A few responses recommended adopting the Institute of Chartered Accountants in England and Wales (ICAEW) Tech 03/11 guidance as an appropriate standard, or using the full audit standard of ISA800. A few responses also suggested that government should adopt a tiered/proportional system by applying different reporting standards for different scenarios.

The majority of respondents, across all stakeholder groups, supported the expansion of the number of people qualified to prepare the written report. This was on the grounds that it would help keep costs competitive and ensure sufficient capacity to enable delivery on time. However, a few respondents expressed concern about expanding the pool on the grounds of dilution of standards, increased costs for leaseholders and risks of conflict of interest or inadequate oversight. Many respondents also stressed the need for greater assurance and transparency about the preparer’s qualifications and independence from the freeholder or managing agent. Leaseholders in particular called for clear routes to escalate complaints about any poor practice by the person preparing the report.

The principal concern for respondents who opposed the measures was that any new requirement could increase costs. Some argued that additional professional fees should not be passed through to leaseholders or applied disproportionately to small schemes.

Government response

The government will prescribe that ISRS4400 will be the default reporting standard for most leases. We will also explore whether leaseholders may request a higher reporting standard if they so wish. Where the lease explicitly requires an audit, then government will prescribe that leases must meet the ISA800 reporting standard.

We recognise that many respondents called for ISRE2400 in certain circumstances, including above a threshold based on total service charge budget or size of the building. However, there is no single recognised accounting framework, unlike in commercial and other sectors, that applies to residential service charge accounts. This, combined with the inconsistencies of record-keeping, would make it difficult/risky for auditors to report on the accounts under the ISRE2400 reporting framework. Given this, we will not prescribe ISRE2400 as a default reporting standard.

However, given leaseholder concerns about the quality of some accounts, we will explore giving leaseholders the right to require a higher standard of reporting should a sufficient number within a block agree to do so.

The government will expand the number of people qualified to prepare the written report to include the Association of Authorised Public Accountants as well as members of the Institute of Chartered Accountants in Ireland and Scotland. We will also continue to explore ways of further extending the pool of appropriately qualified people (subject to assurances about the appropriate level of qualifications). This may include guidance that would allow individuals with certain financial qualifications to prepare but not sign the report on statement of accounts.

The government will also prescribe a written statement that a qualified accountant must prescribe alongside the accounts. This statement will be based on the statement of declaration on which we consulted. However, recognising our decision to require compliance with ISRS4400 as the default basis, we will modify the wording of the statement. We will also prepare a separate statement for those accounts that are subject to ISA800.

Questions 76 to 79: Exemptions for private registered provider and local authority landlords

Question 76: What financial information do local authorities, Private Registered Providers and Registered Social Landlords provide to their leaseholders?

There were 293 responses to this question

Option	Total	Percent
Balance Sheet	182	62%
Income and Expenditure report	230	78%
Sinking/reserve fund statement	201	69%
Other	89	30%

*Note: Respondents were able to select multiple options for this question. Percentages in this table are calculated as a proportion of the number of responses to the question.

Question 76 (free text): If other, please specify

There were 76 direct responses to this part of the question.

Question 77: What procedures are in place within local authorities, Private Registered Providers and Registered Social Landlords to ensure that any accounts or financial statements are accurately reported and who signs off any information?

There were 166 responses to this question.

Question 78: Do you think that local authority and Private Registered Provider landlords, and Registered Social Landlords, should be exempt from the provisions to prepare written statements of account for each block and signed off by a suitably qualified accountant?

There were 398 responses to this question.

Option	Total	Percent
Yes	72	18%
No	326	82%

Question 78 (free text): If yes, what provisions should apply to local authority and private Registered Provider landlords? Please be specific.

There were 54 responses to this question.

Question 79: Are there any other landlords or specific scenarios where you think exemptions or modifications are needed?

There were 359 responses to this question,

Option	Total	Percent
Yes	44	12%
No	315	88%

Question 79 (free text): If yes, provide details.

There were 42 responses to this question.

Questions 76 to 79 sought views on the existing arrangements for social landlords.

The majority of respondents, in particular leaseholders, were opposed to blanket exemptions for social landlords from block-level accounting requirements. Social housing leaseholders in particular argued that they already face poor transparency, slow responses, and difficulty challenging service charges. They considered that exemptions would entrench a two-tier system, leaving social housing leaseholders with weaker protections than those in the private sector. Leaseholder respondents also pointed out that that block-level statements are essential for understanding and challenging costs, especially in mixed-tenure developments, to prevent cross-subsidy, hidden costs and mismanagement.

Social landlords, and local authorities in particular, favoured an exemption. They argued that requiring block-level statements, prepared by a qualified accountant, would impose significant administrative and financial burdens, especially for organisations managing thousands of blocks. In doing so they highlighted that many blocks are mixed tenure where leaseholders are a minority, making block-level accounting less meaningful and more costly. Some local authorities also argued that producing accounts for each block was impractical due to the structure of the Housing Revenue Account.

The vast majority of social landlords added that these costs would ultimately be passed on to leaseholders, many of whom are on low incomes. These landlords also emphasised that they are already subject to rigorous regulatory frameworks, including oversight by the Regulator of Social Housing, and public accountability through elected members and statutory officers (e.g. Section 151 Officers), which provide sufficient assurance of financial integrity and transparency at the organisational level.

Several respondents suggested that a proportionate approach was needed, with simplified reporting for small blocks or low-value service charge budgets.

Government response

The government recognises the challenges facing PRPs and local authority landlords. It recognises that they are organised differently from private landlords and do not typically operate on a block-by-block basis, as well as having unique circumstances such as a mix of tenures within the same block. It also recognises the different regulatory obligations facing these landlords, including the requirement to prepare annual accounts and, in the case of PRPs, financial oversight from the Regulator of Social Housing. However, the government accepts the argument put forward by leaseholders that greater landlord accountability is required and considers that leaseholders of social housing are entitled to better information and understanding on how their service charges are accounted for.

We will therefore legislate to require PRPs and local authorities to provide a report, which includes details of reserve funds if applicable. In doing so we will exempt these landlords from the full requirement to comply with a reporting standard and, in the case of PRPs, we will also exempt them from having their report prepared by an external qualified accountant. This is in recognition of the regulatory oversight arrangements currently in place. We consider this is a proportionate and balanced approach.

Questions 80 to 88: Questions for landlords and managing agents

Question 80. Do you already provide your leaseholders with service charge accounts?

There were 114 responses to this question.

Option	Total	Percent
Yes	101	89%
No	13	11%

Question 81: What are the differences between these new proposals and the information you currently provide to leaseholders?

There were 100 direct responses to this question.

Question 82: How long does it take you to prepare accounts now? How long would it take you to prepare accounts if you had to implement the proposals?

There were 101 direct responses to this question.

Question 83: How much does it cost you to prepare a set of accounts on average?

There were 88 direct responses to this question.

Question 84: What additional costs or savings would you face if you had to implement the proposals? 

There were 91 direct responses to this question.

Question 85: Would you adjust your systems, or would any adjustments be outsourced (for example to an IT software provider)?

There were 94 direct responses to this question.

Question 86: How much would it cost to adjust systems to collect and provide the information?

There were 73 direct responses to this question.

Question 87: Do you agree that 12 months is enough time to allow landlords and managing agents to adjust their systems and train their staff to the new arrangements?

There were 116 responses to this question.

Option	Total	Percent
Yes	54	47%
No	62	53%

Question 87 (free text): If no, what should be enough time and why?

There were 60 direct responses to this question

Question 88: Would set up costs be reduced if we provided a longer transition period?

There were 98 responses to this question.

Option	Total	Percent
Yes	26	27%
No	72	73%

Question 88 (free text) And if yes, by how much?

There were 22 direct responses to this part of the question.

Landlords and agents reported that the time taken to prepare service charge accounts varies considerably, depending on the size and complexity of the development. Many landlord respondents indicated that there were five main cost drivers: the size and complexity of the scheme; the level of professional fees; the amount of staff time required; systems and other overhead costs (e.g. management support), as well as printing and mailing costs. Respondents reported that the process for preparing accounts also involves multiple teams (finance, IT, leasehold staff, technical staff), and is influenced by the quality of documentation, and the need for external audit in some cases.

The majority of respondents reported a high degree of transparency in their current service charge practices. Many already provide detailed breakdowns of charges, annual statements, and opportunities for leaseholders to inspect accounts.

Several respondents considered that the new proposals would introduce significant additional costs and administrative complexity. This would include the cost of requiring accounts to be audited. Local authority respondents, in particular, expressed concern that the new requirements would necessitate data collation across multiple reporting systems. Some respondents called for a flexible approach – including in relation to the template, audit requirements, proposed standards and digital provision.

Many managing agent respondents indicated that they already employ professional accountants and have systems in place for regular account preparation and audit. However, the quality and standardisation of accounts could vary, and some agents noted that delays are often due to client review and approval processes.

While some respondents welcomed the support for greater transparency, many expressed concern that the new proposals would result in longer preparation time, and increased resource needs (including additional staff and new systems).

The vast majority of respondents expected significant additional costs from implementing the proposals, with little or no prospect of savings. The main cost drivers were staffing, professional fees, IT and system upgrades, training, and administrative overheads. All landlord types anticipated passing these costs on to leaseholders. A few respondents stated that there would be potential for some non-monetary savings, for example a reduction in disputes and tribunal cases, saving time and legal costs in the long run.

Several responses indicated that landlords and managing agents would have very different approaches to adjusting systems to meet new service charge requirements. This included the need to make changes in-house, outsource system change requests, or do both. The vast majority of leaseholders were sceptical of the need for major adjustments and strongly opposed passing costs on to them. Other stakeholders highlighted the diversity of the sector and the need for clear guidance and support. Across all types of respondent, there was a call for detailed specifications, phased implementation, and robust change management to ensure successful delivery.

Many landlord respondents reported significant uncertainty about the costs of adjusting systems to meet new information requirements. Landlords and managing agents anticipated substantial IT and staffing investments, with costs likely to be passed to leaseholders. Leaseholders, in contrast, were sceptical of these claims and argued for greater transparency and accountability. Other stakeholders (such as managing agents) highlighted the diversity of the sector and the need for clear government guidance. Across all groups, there was a call for detailed specifications and phased implementation to manage costs and avoid unnecessary burdens.

In terms of a transition to the new regime, landlords and managing agents reported a number of implementation challenges. The main implementation challenges were around IT and data, staffing and skills, process management, cost recovery, proportionality for different types of landlord, and the risk of delays or confusion without clear, phased planning. Addressing these will require early guidance, sector-specific support, and robust project management.

Government response

The government is grateful for the constructive feedback on the operational and financial impact of the proposed service charge accounts regime. We have taken full account of these issues when considering all the measures under the proposed new service charge accounts regime.

We have carefully considered the arguments for a transitional period. On balance, we plan to give private landlords 12 months’ notice of the measures, and social landlords 24 months’ notice.   

9. Rebalancing the litigation costs regime

Questions 89 to 94: Exemptions from the landlord application requirement

Question 89: Should there be an exemption to the requirement for landlords to apply to the court or tribunal in order to recover their litigation costs as an administration charge where a landlord has issued a debt claim in the civil court, for the debt of an unpaid service charge, where the leaseholder has admitted to the claim or not defended the claim?

There were 556 responses to this question.

Option	Total	Percent
Yes	357	64%
No	199	36%

Question 89 (free text): If no, explain your answer

There were 141 direct responses to this part of the question.

Question 89 (free text): Are there any further considerations or unintended consequences to this proposed exemption?

There were 154 responses to this part of the question

Question 90: We would welcome further evidence on the proportion of cases to recover a debt brought by the landlord which are undefended or admitted to by the leaseholder.

There were 107 responses to this question.

Question 91: We would also welcome evidence from leaseholders about whether they have ever had to pay a landlord’s litigation costs as part of a debt claim, and if so, how much were those costs.

There were 119 responses to this question.

Question 92: Are there any other cases where you think there needs to be an exemption to the landlord requirement to apply in order to recover their litigation costs as an administration charge?

There were 191 responses to this question.

Question 93: We are aware that some landlords may not be able to recover their litigation costs from an individual leaseholder as an administration charge due to the terms of the lease. Are there instances that such an exemption should be made to allow a landlord to recover their litigation costs through the service charge without an application to the court or tribunal?

There were 274 responses to this question.

Question 94: We would welcome views from social landlords and their leaseholders on any further considerations in relation to the power to exempt certain situations from the landlord application requirement.

There were 102 direct responses to this question.

The consultation focused on how the regime should operate in practice, including the scope of exemptions. Many respondents supported a limited exemption for admitted or undefended debt claims, on the basis that requiring a further application for litigation costs where liability is not in dispute could add cost and delay. However, many responses also showed significant concern about removing judicial scrutiny in these cases. Many respondents argued that undefended claims can involve accounting errors, procedural mistakes or involve leaseholders who have not understood the process, lacked access to advice, or are discouraged from defending claims due to concerns about legal fees, even where charges may be unfair. In some cases, we have heard that leaseholders have not received the court paperwork so were unaware of the proceedings. Respondents also raised concerns about inflated legal fees, pressure tactics in debt recovery and the risk of landlords moving too quickly to litigation rather than using pre-action engagement, instalment plans or alternative dispute resolution first.

Across the questions on evidence on litigation costs in debt recovery, respondents reinforced these broader themes. Some respondents suggested undefended or admitted claims are common in practice, while others emphasised that leaseholders may fail to defend claims even where charges are disputed. A small number of leaseholders reported having paid landlords’ litigation costs, sometimes without the costs being clearly identified. Views were mixed on whether any further exemptions should be created. Some respondents suggested narrow exemptions for resident-led buildings, vexatious claims, urgent health and safety matters or clear success cases. Others argued strongly against widening exemptions, particularly through the service charge route, on the basis that this could spread one person’s dispute costs across uninvolved leaseholders. Social landlord responses pointed in different directions, with some calling for the same rules to apply across the board and others suggesting limited additional exemptions for specific enforcement situations.

Government response

The government will take a targeted approach to exemptions from the requirement for landlords to apply for judicial approval to obtain their litigation costs through the service and administration charge.

As was proposed in the consultation, we will not create an exemption for service charge recovery. Where litigation costs are recovered through the service charge, landlords will, in all cases whether defended, undefended or admitted, be required to obtain court or tribunal approval. This reflects the stronger protection needed where costs may be passed on to other leaseholders who were not party to the dispute.

For administration charges, we consider that a limited exemption remains necessary in straightforward undefended claims, but we will not proceed with the blanket approach consulted on which would have exempted all undefended or admitted claims. Instead, we intend to introduce a threshold-based exemption for all cases (both undefended and admitted), so that lower value litigation costs can be recovered without approval. This is intended to preserve the leaseholder protection set out in the 2024 Act for claims involving higher legal costs, while avoiding disproportionate delays and burdens on the court and tribunal system. We will also take forward supporting safeguards on notification to ensure the regime remains fair and transparent for leaseholders , including those who are not party to the claim. In particular, we will ensure fairness and transparency as to the level of the threshold, with claims where the costs are below the threshold avoiding the need to apply to the court or tribunal, and higher value costs needing approval. We will continue to engage with stakeholders on the detailed operation of this exemption and to ensure that the exemption threshold is fair and proportionate.

Questions 95 to 100: Partial admissions, default judgments and strike out cases

Question 95: Where the leaseholder has partially admitted a debt, and so has defended another part of the debt, and therefore the claim will go before a judge who can then assess a landlord’s application for litigation costs, do you think the exemption to the landlord application requirement should not apply?

There were 382 direct responses to this question.

Option	Total	Percent
Yes	266	70%
No	116	30%

Question 95 (free text): If no, please explain your answer.

There were 85 direct responses to this part of the question.

Question 95 (free text): Are there any further considerations or unintended consequences to this approach?

There were 88 direct responses to this part of the question.

Question 96: We would welcome any further evidence of the proportion of cases to recover a debt brought by the landlord which are partially admitted to by the leaseholder. 

There were 83 responses to this question.

Question 97: Do you think that the proposed exemption to the landlord application requirement should not apply where the leaseholder has successfully applied to set aside a default judgment?

There were 351 responses to this question.

Option	Total	Percent
Yes	260	74%
No	91	26%

Question 97 (free text): Are there any further considerations or unintended consequences to this approach?

There were 105 responses to this part of the question.

Question 98: Should the proposed exemption extend to cases where the leaseholder has unsuccessfully applied to set aside a default judgment?

There were 341 responses to this question.

Option	Total	Percent
Yes	174	51%
No	167	49%

Question 98 (free text): Are there any further considerations or unintended consequences to this approach?

There were 101 responses to this part of the question.

Question 99: Should there be an exemption to the landlord application requirement to recover their costs as an administration charge where the civil court has automatically struck out a leaseholder’s case because of something the leaseholder has done or failed to do?

There were 373 responses to this question.

Option	Total	Percent
Yes	197	53%
No	176	47%

Question 99 (free text): Are there any further considerations or unintended consequences to this approach?

There were 124 responses to this part of the question.

Question 100: We would welcome any further evidence of the proportion of cases where a landlord and a leaseholder is involved which are struck out automatically, without a formal review of the case.

There were 59 responses to this question.

There was stronger support for retaining judicial scrutiny of landlord litigation costs where claims are only partly admitted or where a default judgment has been set aside successfully. Respondents generally considered that once any part of a claim remains disputed, or a judgment has been reopened, litigation costs should not be treated as recoverable under the lease without judicial approval. Follow-up responses reinforced this, with many respondents emphasising fairness, the importance of assessing the merits of the defence, and the risk that leaseholders may otherwise be penalised in situations where the underlying case remains contested. Some respondents also noted a potential risk of tactical behaviour, for example partial admissions or set aside applications being used to affect costs recovery, but this was not the dominant concern.

Views were more finely balanced in relation to cases where an application to set aside a default judgment has been unsuccessful, or where a claim has been struck out automatically on procedural grounds. Some respondents considered that where a leaseholder has been unsuccessful in an application or their case has been struck out, landlords should be able to recover costs more easily. Others argued that procedural failure does not necessarily justify dispensing with judicial scrutiny, particularly where leaseholders may be unrepresented, unfamiliar with the process or affected by technical errors. The follow-up responses raised concerns about perverse incentives, including landlords pursuing default judgments or procedural strike out too readily, and highlighted the need for consistent guidance and safeguards. Evidence on automatic strike out cases was limited, with most respondents offering only general observations.

Government response

The government proposes to take the same threshold approach as is set out in the sections above and apply this to partial admissions, set aside applications or automatic strike out cases. This means that where litigation costs claimed via an administrative charge exceed the threshold an application to the court or tribunal will be required. Where costs are under the threshold, no application will be needed. This approach will apply to all type case regardless of them being admitted or not.

Service charge recovery will require court or tribunal approval in all cases. Within the administration charge regime, our proposed threshold is intended to provide a limited and proportionate exemption for claims involving lower value litigation costs, while requiring judicial scrutiny for cases giving rise to higher value litigation costs. We recognise that issues were raised about different types of cases, but we do not intend to create a broader exemption that would weaken the core protection of judicial oversight and add further complexity to the system.

Questions 101 to 109: Suspension of the application requirement for resident-led buildings

Question 101: We would welcome further evidence about how resident led buildings, for example those with Resident Management Companies in place or buildings with the Right to Manage, fund litigation when they bring a claim against a leaseholder.

There were 129 direct responses to this question.

Question 102: Should the requirement for landlords to apply to the court or tribunal to recover their litigation costs from leaseholders be suspended until a later time for resident-led buildings, enabling them to recover litigation costs from the service charge prior to proceedings?

There were 308 responses to this question.

Option	Total	Percent
Yes	222	72%
No	86	28%

Question 102 (free text): If no, please explain your answer

There were 61 direct responses to this part of the question.

Question 103: Should the proposed use of the suspension power apply to resident-led buildings only?

There were 303 responses to this question.

Option	Total	Percent
Yes	200	66%
No	103	34%

Question 103 (free text) If no, please explain your answer

There were 70 direct responses to this part of the question

Question 104: Should the definition of resident led buildings, for example those who will have the application requirement suspended, be those where a recognised Right to Manage Company or Resident Management Company have been established, or where a manager has been appointed under Section 24 of the Landlord and Tenant Act 1987?

There were 303 responses to this question.

Option	Total	Percent
Yes	234	77%
No	69	23%

Question 104 (free text): If no, please explain your answer

There were 55 direct responses to this part of the question.

Question 105: Should the event which will then require resident led buildings to apply for their litigation costs be upon the substantive claim or application being decided, or, where relevant, upon the case being withdrawn, struck out or a consent order being made? Resident led buildings will be able to apply for their costs alongside the initial substantive application so as to simplify processes for resident led buildings and the courts or tribunals.

There were 275 responses to this question.

Option	Total	Percent
Yes	241	88%
No	34	12%

Question 105 (free text): If no, please explain your answer

There were 27 direct responses to this part of the question.

Question 106: Are there any further considerations or unintended consequences to the proposed approach?

There were 100 responses to this question.

Question 107: Do you think that any other organisation or person, or any other situation should have the requirement to apply for litigation costs, either for recovery through the service charge or as an administration charge, suspended until a later date in this way?

There were 266 responses to this question.

Option	Total	Percent
Yes	45	17%
No	221	83%

Question 107 (free text): If yes, please explain your answer

There were 30 direct responses to this part of the question.

Question 108: We would welcome views from social landlords and their leaseholders on any further considerations in relation to the power to suspend the landlord application requirement until a time or event specified by regulations.

There were 46 responses to this question

Question 109: Should the requirement for resident led buildings to apply to recover their litigation costs be re-suspended if the court or tribunal agrees for a case to go to appeal and places a stay on the determination of an application for costs in a substantive case until the appeal concludes?

There were 249 responses to this question.

Option	Total	Percent
Yes	206	83%
No	43	17%

Question 109 (free text): Are there any further considerations or unintended consequences to the proposed approach?

There were 74 responses to this question

Many respondents recognised the distinctive position of resident-led buildings and accepted that these bodies may face particular cashflow and funding problems when they need to bring legal proceedings against a leaseholder. The evidence gathered from the responses suggested that resident-led buildings often rely on limited sources of finance, and that this can make litigation difficult to fund. Accordingly, there was support for a temporary suspension mechanism. However, the follow-up responses also showed clear concern that allowing litigation costs to be recovered through the service charge before judicial approval could expose leaseholders to unfair pressure, shift cashflow problems directly onto residents, and allow non-professional decision-makers to incur costs without sufficient scrutiny.

Many respondents favoured limiting any suspension power to genuinely resident-led buildings, and supporting this with a clear definition, though some argued that the definition should be narrower and others wanted parity across different management structures. There was broad support for ending any suspension once the substantive case or related event had concluded, and strong opposition to widening the power to other categories. Responses also stressed the need for safeguards around appeals, repayment if costs are later disallowed, transparency to leaseholders, and clear verification of resident-led status. Social landlord responses were limited, but those who did comment were split between saying the power should not apply to them and suggesting similar treatment should be available.

Government response

The government will proceed with a suspension mechanism for resident-led buildings, reflecting the distinct funding constraints faced by Resident Management Companies, Right to Manage Companies and tribunal-appointed managers. These bodies often have no realistic source of funds other than the service charge, and without a limited suspension they may be unable to pursue legitimate claims needed for effective building management. We therefore intend to allow this category of resident-led organisation or a tribunal-appointed manager to use service charge funds to meet their litigation costs before judicial approval is obtained, but only on a temporary basis and subject to clear safeguards. The suspension will apply only to defined resident-led organisation exercising management functions and to tribunal-appointed managers and will end once the underlying litigation has concluded, including after any appeal period has passed or an appeal has been finally determined. At that point, the relevant body will need to apply for approval retrospectively if it wishes to retain those litigation costs. If approval is refused, given only in part, or an application is not made in time, the relevant body must repay the relevant sum to the service charge account. We will also take forward supporting safeguards on notification, timing and repayment to ensure that the regime remains fair and transparent for leaseholders.

Questions 110 to 114: Leaseholder right to recover litigation costs from landlords

Question 110: Should the leaseholder right to apply to the court or tribunal to claim their litigation costs from their landlord broadly align with the right to litigation costs that landlords have?

There were 531 responses to this question.

Option	Total	Percent
Yes	490	92%
No	41	8%

Question 110 (free text): Are there any further considerations or unintended consequences to this approach?

There were 189 responses to this part of the question.

Question 111: Do you think the proposed cases, those set out in Table 2 and 3, should be those that relevant proceedings must relate to in order for the leaseholder to have the right to apply to the court or tribunal to claim their litigation costs from their landlord?

There were 461 responses to this question.

Option	Total	Percent
Yes	397	86%
No	64	14%

Question 111 (free text): If no, please explain your answer

There were 57 direct responses to this part of the question.

Question 112: Do you have any views and evidence on whether lease terms allowing for the recovery of litigation costs from leaseholders generally give landlords the right to recover their costs for varying a lease under section 35 of the Landlord and Tenant Act 1987?

There were 170 responses to this question.

Question 113: Do you think leaseholders should be given the right to apply to the court or tribunal to claim their litigation costs from varying a lease, under Section 35 of the Landlord and Tenant Act 1987, from their landlord, either by bringing a claim or defending a claim?

There were 488 responses to this question.

Option	Total	Percent
Yes	432	89%
No	56	11%

Question 114: We would welcome views from social landlords and their leaseholders on any further considerations in relation to the leaseholder right to apply to the court or tribunal to claim their litigation costs from their landlord.

There were 85 responses to this question.

There was strong support for giving leaseholders a clearer right to recover their own litigation costs from landlords, with many respondents seeing this as an important step towards fairness and improved access to justice. The follow-up responses emphasised that parity with landlord rights was the minimum required, while some respondents argued that leaseholders may in practice need stronger protections because of the financial impact that litigation can have on households. Respondents also called for safeguards to prevent abuse, for clear judicial oversight, and for the regime to work in practice rather than existing only in theory.

Responses showed broad support for the proposed scope of proceedings, including lease variation cases under section 35 of the Landlord and Tenant Act 1987, although many respondents argued that the list should remain capable of expansion and should capture other relevant proceedings where landlords can already recover their own costs. Responses also suggested that some lease terms are drafted broadly enough to allow landlords to seek recovery of lease variation costs, while many respondents opposed automatic reliance on lease wording without judicial scrutiny. Social landlord responses stressed that equivalent protections should apply to leaseholders of social landlords as well, while also noting the operational and financial considerations in that sector.

Government response

The government will proceed with regulations under section 63 of the 2024 Act to create a new right for leaseholders to recover their litigation costs from landlords in defined circumstances. Our approach is to align leaseholder rights broadly with the rights that landlords already benefit from, while ensuring that the court or tribunal retains discretion to decide what is just and equitable in the circumstances. We intend to specify a defined set of relevant matters covering the main civil court and tribunal cases in which leaseholders may need to defend enforcement action or bring claims to enforce their rights, including disputes relating to the variation of a lease. We also recognise the need to ensure that the scope remains workable as the wider legislative framework evolves. Alongside this, the regulations will set out the factors that courts and tribunals must consider when awarding leaseholder costs, including case outcomes, conduct of the parties and the position of resident-led organisation. This strikes a fair balance between access to justice, proportionality and clarity.

Question 115: Transition period

Question 115: What transition period do you envisage being sufficient to provide time for landlords, resident led buildings and the courts to transition to a new system for litigation costs once the regulations have been made?

There were 429 responses to this question.

Option	Total	Percent
1 to 2 months	109	25%
3 to 4 months	104	24%
5 to 6 months	122	28%
More than 6 months	94	22%

Question 115 (free text) Are there any further considerations or unintended consequences to the proposed approach?

There were 114 responses to this part of the question.

Views on the transitional period before the measures should come into force were spread, but many respondents pointed to the need for clear guidance, training and communication to support implementation, while others urged early commencement to reduce delay and avoid extended uncertainty.

Government response

The government intends to provide for a three-month period between the making of the litigation costs regulations and their coming into force. While consultation responses were spread across the options presented, many respondents highlighted the need for clear guidance, training and communication to support implementation, and the court and tribunal system will also need time to prepare for the new regime. At the same time, we are mindful of the strong expectation that these reforms should be brought into force as soon as practicable. On balance, we consider that a three-month period strikes the right balance between these considerations. It is long enough to support operational readiness, including engagement with the Ministry of Justice on the supporting tribunal procedure changes, but short enough to avoid unnecessary delay in delivering the protections created by the 2024 Act. We also intend that the new regime should apply only to proceedings issued after commencement of the measures, so that ongoing claims continue to operate under the current costs regime. This reflects the usual approach to transitional arrangements for changes of this nature and will help to ensure a clear and workable implementation framework.

Glossary of key terms

Accounting period	A period of 12 months specified in the lease as an accounting period or, if no such period is specified in the lease, a period of 12 months beginning with 1 April.
Administration charge	An amount payable by a leaseholder as part of or in addition to the rent which is payable, directly or indirectly (a) for or in connection with the grant of approvals under the lease, or applications for such approvals, (b) for or in connection with the provision of information or documents by or on behalf of the landlord or a person who is party to the lease other than the landlord or leaseholder, (c) in respect of a failure by the leaseholder to make a payment by the due date to the landlord or a person who is a party to the lease other than the landlord or leaseholder, or (d) in connection with a breach (or alleged breach) of a covenant or condition of his lease.
Annual report	An annual report will cover a range of financial and other information, and must be provided to leaseholders by their landlord before or within one month of a new 12-month accounting period.
Appropriate tribunal or relevant tribunal	Appropriate tribunal or relevant tribunal refers to the First-tier Tribunal (Property Chamber), or where determined by or under Tribunal Procedure Rules, the Upper Tribunal, in England and the Leasehold Valuation Tribunal in Wales, which deal with settling disputes in relation to leasehold property, including service charge disputes and failure to provide information to leaseholders.
Building insurance	It is common for the lease to require the whole building or a part of the building to be insured against risks such as fire, lightning, subsidence and even terrorism. Building insurance is usually but not always the responsibility of the landlord although the lease will usually require the leaseholder to pay a share of the cost.
Common parts	Any areas of the building which do not form part of a unit (or flat). Generally, this includes communal areas shared between unit owners (such as gardens, halls and staircases), structural parts of the building, such as the external walls and the roof, and any pipes, cables and other installations not situated within a unit, nor which serve only that unit. The exact definition depends on the wording of the lease.
Default judgment	A judgment by a court as an administrative act rather than a trial or hearing. A default judgment is the early determination of a claim where a defendant has failed to acknowledge a claim or file a defence within set time limits.
Event fee	A fee payable under a term of or relating to a residential lease of a retirement property on certain events such as resale or sub-letting. Event fees may be referred to by a variety of names including exit fees, transfer fees, deferred management fees, contingency fees and selling service fees.
First-tier Tribunal	The First-tier Tribunal (Property Chamber) deals with settling disputes in relation to leasehold property in England, including service charge disputes and failure to provide information to leaseholders.
Fixed service charge	A fixed service charge specifies the exact amount of service charge that leaseholders pay for the accounting period, for a specific list of services.
Head lessor	A landlord of an intermediate lease.
Indemnity basis	The basis upon which a court assesses a party’s litigation costs, which must have been reasonably incurred and reasonable in amount in order to be payable.
Initial service charge demand	An initial service charge demand is the first demand issued to a leaseholder for service charge contributions for a specified accounting period, whether on account or in arrears.
Intermediate landlord	A person who holds an ‘intermediate lease’. They hold a leasehold interest in, and in turn are a landlord under another lease, of all or part of the same property.
Landlord	The meaning of “landlord” depends on the context. In relation to service charges, it includes any person who has a right to enforce payment of a service charge. A landlord may be either the freeholder of the property or may itself hold a leasehold interest in the property.
Lease	The legal document that allows the holder to occupy a property for a specific period of time. It contains the terms of the contractual arrangement, such as what landlord costs can be recharged to leaseholders via a service charge, any restrictions on the leaseholder’s ability to sublet or make alterations.
Leasehold	A form of property ownership which is time-limited, where control of the property is shared with, and limited by, the landlord.
Leasehold Valuation Tribunal	The Leasehold Valuation Tribunal deals with settling disputes in relation to leasehold property in Wales, including service charge disputes, lease variations and the determination of premiums for freehold purchase and lease extensions.
Leaseholder	A leaseholder is a person or company who owns a property subject to the terms of a written lease agreement, typically for 99, 125 or 999 years. The lease creates obligations which a leaseholder must comply with, including the obligation to pay the service charge.
Litigation costs	Costs incurred by either a landlord or a leaseholder during legal proceedings. In sections 62 and 63 of the 2024 Act, “litigation costs” means any costs incurred, or to be incurred, by a person in connection with relevant proceedings to which they are party.
Major works	“Qualifying works” carried out to a building or other premises, such as decoration, repairs, improvements, or refurbishments, which are necessary to keep a block or estate in a satisfactory state of repair, which would cost each leaseholder either over £250 or, if a “qualifying long term agreement” was entered into, over £100. *As defined by s.20ZA(2) of the Landlord and Tenant Act 1985 and regulation 6 of the Service Charge (Consultation Requirements)(England) Regulations 2003 and regulation 6 of the Service Charge (Consultation Requirements)(Wales) Regulations 2004.
Managing agent	An individual or company appointed to run and manage the building and services on behalf of a landlord or residents management company.
Reconciliation demand	A demand for payment following publication of service charge accounts. It seeks additional funds from leaseholders where there was an overspend for the previous accounting period against actual costs incurred.
Relevant costs*	Relevant costs are the costs or estimated costs incurred or to be incurred by or on behalf of the landlord, or a superior landlord, in connection with services, repairs, maintenance, improvements, or insurance or the landlord’s costs of management. *As defined by section 18(2) of the Landlord and Tenant Act 1985, as amended by the 2024 Act.
Reserve fund/sinking fund	A pool of money which is collected to cover the costs of future, one-off or major works needed, such as replacement of a lift or roof.
Resident Management Company	A company that is owned and run by leaseholders of a building containing flats who undertake the management and maintenance of the building. A Resident Management Company is usually a party to the lease and their duties to leaseholders are set out in the lease. A Resident Management Company may or may not own the freehold.
Right to Manage Company	A company created by leaseholders of a building containing flats to take over the management of the building from the freeholder, without buying or owning the freehold.
Section 20	Section 20 of the Landlord and Tenant Act 1985 sets out the consultation requirements that a landlord must follow for any qualifying works or QLTAs (major works).
Section 20B notice	A section 20B notice is sent out by a landlord when they are unable to send a demand for payment to the leaseholder within 18 months of the cost being incurred. It informs the leaseholder that costs have been incurred during the service charge period that will be payable through the service charge.
Service charge*	A financial contribution payable by a leaseholder typically to a landlord, for a share of the cost of insuring, maintaining, repairing, cleaning, etc. the building. Details of what can (and cannot) be charged by the landlord and the proportion of the charge to be paid by the individual leaseholder will all be set out in the lease. *As defined by section 18(1) of the Landlord and Tenant Act 1985, as amended by the 2024 Act.
Service charge accounts	A statement or statements issued to leaseholders by the landlord to account for actual service charge income and expenditure in the 12-month accounting period.
Service charge demand	A service charge demand is an invoice issued by the landlord or managing agent setting out the service charge contribution that a leaseholder is required to pay for a specified period as set out in the lease, to contribute to managing and maintaining the building.
Social landlord	An organisation such as an organisation such as a local authority, a PRP in England, or registered social landlord in Wales, who provides housing. Most do not make a profit. Social landlords can rent their properties to social tenants. Leaseholders may have a social landlord if they have a shared ownership property or their property was previously owned by a social landlord.
Social housing tenant	For the purposes of this consultation, a tenant means someone who rents from a social landlord and is asked to pay a service charge.
Sub-lessee	A person who holds a ‘sub-lease’ (a lease that has a leasehold interest above it). The individual holds a leasehold interest, and their immediate landlord is also a leaseholder.
Superior landlord	Where there are multiple leases or interests in a property, creating a chain of landlords and tenants, the superior landlord is usually the one who holds the highest interest in the chain.