Policy paper

Park homes research report recommendations: summary of responses

Published 5 March 2026

Applies to England

Introduction

Park home residents are required to pay a site owner a maximum 10% commission when they sell their homes. This requirement has and continues to be a divisive issue with residents calling for the commission to be abolished or reduced while site owners have argued for it to be maintained.

In 2021, the government commissioned the University of Liverpool and Sheffield Hallam University to carry out research (the research) to enable an assessment of any impacts on both residents and site owners through a change to the rate of commission. The final report - The impact of a change in the maximum park home sale commission - published in June 2022, made 4 recommendations, which were:

• to strengthen the professionalism of park operators
• to consider whether a national enforcement body could ensure a more - consistent and higher quality of park operation
• to explore and clarify the rationale of the commission; and that,
• there should be no reduction to the commission rate without financial support, which should be independent of residents, for smaller parks in particular.

In 2023, MHCLG published a discussion paper seeking stakeholders’ views on the report’s recommendations. The stakeholders invited were:

• The National Association of Park Home Residents (NAPHR)
• Park Home Owners’ Justice Campaign (PHOJC) - Park Homes Policy Forum (PHPF)
• Independent Park Homes Advisory Service (IPHAS) - Age UK
• The National Caravan Council (NCC)
• British Homes and Holiday Parks Association (BHHPA)
• The Local Authority Site Licensing Officers’ Group (LASLOG)

We are grateful to all the stakeholder groups for their contributions. This document sets out a summary of the responses we received. We will consider all the responses together with those we receive to the call for evidence to clarify the rationale for the commission payment.

Part 1: recommendations on professionalism and enforcement

Professionalism of site owners

During the research, residents expressed a high level of dissatisfaction with some site operators’ behaviour in managing parks. The report recommended strengthening the professionalism of park operators to help improve their behaviour.

In our discussion paper, we set out 4 ways in which site owners could become more professional in managing sites and complying with legislation. The first option was by residents knowing and understanding their rights and effectively challenging site owners. We sought views on how well residents knew and enforced their rights.

Question 1

To what extent are residents aware of their rights and obligations?

Question 2

Are there any barriers to accessing advice about their rights from all the existing advisory services for residents or understanding those rights?

Question 3

If there are any barriers, what could be done to improve access and understanding of those rights?

Summary of responses

All respondents agreed that information about residents’ rights and obligations was available through a variety of sources, such as the websites of the national residents’ associations, trade associations, LEASE and GOV.UK. Those rights are also set out in residents’ written agreements and sometimes published in sector specific magazines. Specialist park home lawyers are also available to provide residents with advice.

Most residents were however not aware of their rights and obligations either because they did not read their written agreements before or after purchasing their home or because of difficulties accessing the information. This was because it was only available online, not in accessible formats and was difficult to navigate particularly for elderly, disabled or vulnerable residents. The park homes legislation is also ‘complex and piecemeal’, there are very few specialist lawyers available and some residents are often given inaccurate information when they seek advice. Voluntary organisations and residents’ associations play an important role in providing advice but they have limited capacity to support or reach a large number of residents.

Suggestions on how to improve access to information included providing a step-by-step guide on buying and selling a home and publishing a mandatory “Buyers Pack” for all park owners selling a park home. Information should be provided in plain English, accessible, and possibly include short video/audio formats.

The second option was for more residents to assert their rights through the First-tier Tribunal (FTT). We sought to identify the challenges residents had in accessing the Tribunals.

Question 4

What barriers do residents face in asserting their rights through the tribunals?

Question 5

If there are any barriers, what could be done to improve access and understanding of those rights?

Summary of responses

Residents are often deterred from going to the Tribunal because of possible intimidation or abuse from site owners or a site owner recovering their legal costs from them. Some residents were also deterred by the cost of seeking legal representation, a lack of understanding of the tribunal process or by the complexity of preparing and presenting cases.

Those challenges, it was suggested, could be addressed through better resourcing of the tribunal service, clear signposting to telephone-based advisory services and making FAQs and step-by-step guides to the tribunal process available. Additional support for residents with tribunal cases could be provided by tribunal officials or by funding residents’ associations or other bodies. Other suggestions were for a stakeholders’ group to be set up to raise awareness, share best practice and provide a neutral platform to resolve emerging issues.

The third option was for site owners to take up learning and development opportunities for themselves and their organisations. We wanted to understand how unprofessional site owners could be encouraged to take responsibility for their learning or how they could gain access to existing learning and development opportunities.

Question 6

Should unprofessional site owners be encouraged to take responsibility for their own learning and development or mandated to do so? Please give reasons for your answer.

Question 7

For the option you have chosen, how could it be implemented and monitored effectively?

Question 8

Are there existing learning and development opportunities available to all site owners? If yes, please give examples. If no, how could those opportunities be made available to those currently exempted?

Summary of responses

Some residents suggested that all site owners should be mandated to undertake learning or obtain specific qualifications before being granted a site licence by a local authority. A record of courses undertaken or qualifications gained could be published on the fit and proper person register. It was acknowledged that practices by rogue operators to deliberately frustrate effective regulation could not be easily addressed by mandated training.

Site owners did not support the introduction of additional requirements which could directly or indirectly increase the operating costs of responsible operators. Local authorities should instead be resourced and encouraged to use their site licensing and fit and proper person test powers more effectively.

The trade bodies added that their members have access to a range of learning and development opportunities and professional guidance. The significant number of operators who had made a business choice not to join a trade body would still have access to online information including general advice provided by national statutory bodies such as the Competition and Markets Authority, Chartered Trading Standards Institute, and the Chamber of Commerce on the operation of a business and meeting its obligations to its customers.

The fourth option we identified was through more robust local authority enforcement. Effective enforcement acts as a deterrent and would be more effective if local authorities worked together and shared knowledge. We wanted to understand the extent to which local authorities shared good practice and what the barriers and benefits of doing so were.

Question 9

Do local authorities routinely share good practice with other authorities either directly or seek primary authority advice?

Question 10

If yes, please provide an example(s). What benefits have authorities or other stakeholders derived from this practice?

Question 11

If no, what do you think are the barriers to doing so? 

Question 12

Do you have any additional suggestions on how the sector could be further professionalised? Please provide reasons for your answer.

Summary of responses

About 200 local authority site licensing officers have access to a secure ‘knowledge hub’ for sharing good practice, resources and advice. Some site owners had a primary authority relationship to encourage consistent site licensing enforcement across different local authority areas and promote consistent decision making which targets rogue operators.

Not all local authorities were, however, aware of their legal duties and, with limited resources, they often focussed their activities on minor matters regarding responsible operators rather than taking enforcement action against the rogues. Local authorities should be assisted to make greater use of existing enforcement measures and have more regular communications and engagement with residents and site owners. Local authorities should also be given additional powers to issue fixed or civil penalty notices or manage sites where a licence is revoked.

A national enforcement body

During the research, residents raised concerns about the effectiveness of the current local authority site licensing and enforcement regime. The report recommended that further consideration should be given to whether a national enforcement body could ensure a more consistent and higher quality of park operation. The discussion document set out how the existing site licensing system operates and provided a summary of local authority site licensing and enforcement powers. We asked for views on what a national enforcement body would look like and how it would be an improvement on the current system.

Question 13

What role, if any, do you think a national body could play to improve local authority site licensing and enforcement? 

Question 14

What challenges and opportunities do you foresee from a change to the current system?

Summary of responses

Some respondents did not see a need for a change from the current system as site licencing and enforcement can only be carried out effectively at a local level and requires knowledge of the park and its community. Where a local authority does not discharge its statutory functions, there is recourse to the Local Government and Social Care Ombudsman. As park operators are also not public bodies and not engaged in the provision of a statutory housing function, it would be inappropriate to subject them to a quasi-public sector regulatory regime. What is needed is better resourcing of local authorities and engagement with local trade body members.

Some suggested that a national body should be set up with responsibility for providing support and advice to residents as well as site licensing, contractual matters (between residents and site owners), holiday sites, consumer rights, trading standards and fire safety. A national body could have several advantages including greater understanding and sharing of information and a more consistent application of rules and procedures between local authorities. The body could be set up with a multidisciplinary team of officers including the Police and Trading Standards, to improve expertise and enable it to take robust enforcement.

Challenges with changing the current system would include the need for primary legislation to set up the body, adequate resourcing, recruitment, and migrating site licence and planning data from more than 300 local authorities.

Role of local authorities

Residents have often complained about not receiving assistance from their local authorities on site licensing issues.  We wanted to establish whether there was a clear understanding of a local authority’s role, what type of assistance was sought and how stakeholders sought redress when required.

Question 15

Do you know what a local authority’s site licensing role is and if so, what would you say it is? If no, what do you think or suggest their role should be?

Question 16

Have you ever been dissatisfied with the service you received from your local authority’s site licensing team and if so on what aspect(s) of their role?

Question 17

If you have been dissatisfied with a service you received from your local authority, did you raise your concerns with the local authority and if so, how, and what was the outcome?

Question 18

Should local authorities engage more with their service users and if so how and what about? If no, why not?

Question 19

Do you have any examples of good practice by your local authority site licensing team? If so, please provide an example(s).

Summary of responses

All respondents were generally clear that a local authority’s site licensing role is to license parks, carry out fit and proper person assessments and enforce the site licensing legislation. In terms of good practice, some local authorities actively engage with residents by organising meetings on site-specific issues or to explain changes in legislation. Others also conduct regular visits and inspections and proactively work with site owners to achieve good outcomes for all.

Examples given of unsatisfactory services provided by local authorities included lengthy delays in communications, complaints being ignored or no action taken because the issue was deemed to be outside their responsibilities. In a 2023 survey of residents by a representative body, most respondents indicated that it would be helpful if they could speak privately with a local authority official who understood the mobile homes legislation. Local authorities were also said to focus on minor matters regarding responsible operators instead of rogue operators whose behaviour had a significant impact on residents’ welfare. There was also a lack of consistency in how thorough park inspections are carried out. Stakeholders did not however provide any details of how they had raised concerns with their local authority when dissatisfied with the service they had received.

Other considerations

While all stakeholders have a shared objective to bring change to the sector, they had different objectives and ways of working which sometimes resulted in them working against each other. We sought views on what additional steps or actions each stakeholder could take to improve collaborative working and share good practice.

Question 20

Are there ways in which stakeholders could work together to develop and share good practice which would benefit their members equally and the sector as a whole?

Summary of responses

Successful collaborative working would require all those involved to be willing to work together and share resources. A forum could be set up for stakeholders to discuss emerging issues. DLUHC (as the department was called at the time of the discussion paper) could provide the site licensing officer’s group with a secretariat and also engage with National Trading Standards to address resourcing issues required to undertake investigations of national significance. The trade bodies would actively support greater engagement with local authorities and other stakeholders. A resident group suggested that local authorities should have a dedicated park home officer who was conversant with the mobile homes legislation.

Part 2: recommendations on the rationale and payment of comission

Rationale of the sales commission

From previous reviews and engagement with the sector, residents saw the commission rate to be arbitrary and the payment as unfair.  Park owners on the other hand saw the commission as a vital part of their income stream. From the 2021 research, it was clear that residents and site owners continued to have different views about the commission. The research report recommended that work was needed to explore the rationale of the commission and to clarify this rationale for park owners and home owners. Without clarity, a change to the commission rate would be predicated upon the impacts of the commission rather than the commission’s justified role in the park home sector. We sought views on what the rationale for the commission was and how it could be defined.

Question 21

What in your view is the rationale for charging a commission? Please provide your reason(s) for your response.

Question 22

If, in your view, there is a clear rationale(s) for the commission, how would you define it in a short sentence or paragraph that could be acceptable to others?

Summary of responses

Residents suggested that the payment of commission was not justified, and so did not offer any definition of the rationale. They further argued that site owners take account of all their costs, including any maintenance costs and add an amount of profit, when calculating the initial pitch fee.

Some site owners focussed their response on the commission’s role as an income stream. The commission, they explained, was effectively an advance payment by the buyer to help the operator maintain a viable business. The payment allows them to comply fully with their obligations to all homeowners whilst making a fair profit to compensate them for the time they spend in the business. It was a misconception to suggest that park operators do not provide a service to the buyer for the advance payment they make by way of the commission. There is also no evidence, as opposed to belief or assertion, that the park homes sales market is affected by the commission. Park homes are typically purchased as the person approaches or enters retirement. A home is then sold, not electively, but in response to life events such as the resident passing away or moving elsewhere. The Mobile Homes Act 1983 also affords the buyer unlimited security of tenure which is preserved during an unlimited number of further transactions. During that time, a site owner has no right to recover possession or make a new sale to generate additional income to meet ongoing obligations to other residents or a contribution to their own fair profit from the park business.

Some site owners also expressed views that the rationale for the commission has not changed and remains justified. Several arguments were advanced. It recognises the value of the park home itself alongside the value of the park on which it is placed, without which the park home would be valued at a lower price for re-sale. It ensures that pitch-fees remain at a lower ongoing rate particularly for those on a fixed low income throughout the duration of the agreement, and it compensates the park owner for the loss of the use of the land to ensure security of tenure to the residents for the duration of the agreement.

Summaries provided for the rationale for commission were:

• “in essence, the pitch fee covers a site owner’s running costs and the commission represents their profit”
• “it is a compensation payment to the park owner for the continued loss of the use of the land on which the home sites. In other words it is the price for security of tenure given to the park home resident”
• “it is a transfer fee on the private sale of a park home that recognises the value of the park home on the park with an agreement under the Mobile Homes Act 1983, maintains more affordable pitch fees, compensates the park owner for the use of their land and preserves park home owners’ security of tenure”
• “the commission payment is payable on the sale of a home and therefore site owners are able to offer lower on-going pitch fees to residents, with a one off payment being made to match an inflow of income for those residents at the point of sale”
• “an advance payment by the buyer to help the operator run a viable business which complies fully with its obligations to all homeowners whilst making a fair profit”

Financial support for small parks

The research report concluded that a reduction in the maximum commission rate would support residents’ mobility and would also result in an increase in the proportion of parks that make a loss in any year, which will disproportionally have a negative impact on smaller parks. The report recommended that a reduction in the commission remains desirable for park home owners, but only if park owners (in particular smaller site owners) are supported financially through mechanisms independent of the home owner to retain the viability of parks.

We assumed, for the purposes of the discussion, that the commission payment was justified in order to explore the recommendation further and understand in particular what financial support, through mechanisms independent of the home owner, could be provided.

Question 23

The report does not specify what financial assistance should be provided if the commission was to be reduced. What form do you think these could take and how would they be implemented?

Question 24

How would you define a ‘small park’?

Question 25

Should the financial support be given only to those ‘small parks’ or also to other park types and if so which other types? Please give reasons for your answers.

Summary of responses

Residents argued that no financial assistance should be given to site owners to unfairly provide them a guaranteed and regular income to replace the commission. In their view, site owners did not provide relevant accounting information during the research to show the commission payment was vital to the viability of park homes sites. Without any evidence, offering compensation would be an inappropriate use of taxpayer’s money. If site owners’ losses are a result of poor management, there will be no incentive for them to improve if taxpayer support is given indefinitely.

For site owners, there were no other options for them to generate additional income apart from increasing pitch fees or direct financial compensation from the government. If the commission is taken away as a source of revenue, site owners should be compensated for any loss of income. Financial assistance that could be provided to site owners include direct government support, loans, grants, a reduction in business rates and tax allowances.

Defining a small park could be done using, for example, the number of homes, annual turnover, or a combination of these. However, the risk to operators extends beyond ‘small parks’. Any methods of defining which businesses are at risk would need to consider several metrics including absolute size, available income streams, expenditure to operate in compliance with existing obligations, and any other risks/ expenditure for the particular park. It was acknowledged that trying to consider all these factors would likely make any test complex to administer.

Changing the commission rate - options

Previous reviews considered several options for calculating the commission in the event that changes had to be made to the commission rate. Some of these were: including commission payments in the initial purchase price; linking the commission rate to the length of time the resident had spent on their respective park (Sliding Rate); and applying the commission rate to other bases other than the sales price of the park home (Altered Base).

The government considered these options in 2007 following consultation with residents and trade bodies, but rejected them. We wanted to confirm that stakeholders positions had not changed and that those options should still be rejected.

Question 26

Do you agree that including commission in the initial purchase price, a Sliding Rate or an Altered Base should still be rejected as options? If not, why?

 Summary of responses

It was generally agreed that the previously considered options should still be rejected citing reasons such as being difficult and complicated to implement and having a detrimental market effect.

Pitch fee increase

An option previously put forward is for pitch fees to increase if changes are made to the commission rate, to compensate park owners for a reduction in the commission. The report however recommended that site owners should be assisted ‘through mechanisms independent of the home owner’. As this would exclude increasing pitch fees to compensate site owners as an option, we sought to explore what other options, if any, might be available.

Question 27

Apart from increasing pitch fees or receiving financial incentives, are there other ways site owners could generate additional revenues within the existing framework, to enable them to maintain and improve parks? If yes, what are they? If no, why not?

Question 28

If any loss of income resulting from a change in the rate of commission payable was relatively small in comparison to total income over a period of time, should the industry be able to accommodate such an outcome without seeking compensation? Please give reasons for your answer.

Summary of responses

Residents were of the view that no consideration should be given to changing their existing pitch fees to compensate site operators for the loss of the commission. Site owners should instead find more efficient ways to manage their businesses. As there is no limit on the amount of pitch fees charged by site owners when they sell a new home, they could incorporate any recoverable amounts into future pitch fees.

For site owners, with all three of their income streams being heavily regulated, there is no scope for additional revenue within the existing framework. Pitch fees can only be increased once annually within strictly defined factors and park operators are still adjusting to the recent change to the pitch fee review inflationary index from RPI to CPI. There is also no allowance for any increased expenditure (if this is to meet a site operator’s existing obligations), even though operating costs are rising by more than RPI, which in itself is around 2% higher than CPI. These and other challenges make the commission essential to maintaining a viable business which fully complies with its obligations. Site owners believe there is no possibility of the industry accommodating any change in commission without direct financial compensation from the government.

Other considerations

We sought stakeholders’ views on three other important issues related to the payment of commission.

The first was that if stakeholders continued to maintain their current views/positions, it was possible they would have to accept a decision they had previously argued against. We wanted to know what stakeholders would be prepared to accept as a compromise if the situation arose.

Question 29

Is there a compromise position around the rate or indeed the amount of commission paid, that you would accept and if so, what would that be? If no, please provide your reason(s).

Summary of responses

For residents, the commission should be abolished. The compromises that some could accept were if the rate was reduced gradually by 2% per year over 5 years or if it was set at 5% of the difference between the purchase and selling price of a home.

For site owners, there is no compromise position without appropriate compensation. The 2023 changes to the pitch fee review inflationary index could be seen as the compromise position as the change to the index attempted to balance the rights of residents and responsible operators. Residents should accept that the replacement of the pitch fee review inflation index represents a fair balance between the competing rights of residents and of responsible operators.

The second was that a change to the commission payment could result in a fall in a site owner‘s income and their ability to adequately maintain their site. Poor maintenance of sites could impact on residents’ health and wellbeing and lead to increased complaints to the local authority and increased enforcement action. The site owner may be unable to comply with compliance notices issued to them if they still did not have the resources to do so. We sought stakeholders’ views on how such a situation could be suitably addressed.

Question 30

In those circumstances and taking into account any answers you have given in Section One, what further action(s) if any, could the parties involved take to resolve any ongoing site maintenance and repair issues?

Summary of responses

Residents suggested that there should be a requirement for a reasonable percentage of the combined annual pitch fee and any sales commissions to be allocated to a site sinking fund, specifically for future site repairs, maintenance and improvements. This should affect only those who evade their obligations but not responsible site owners who already meet their obligations.

Site owners explained that the obligations on the parties relating to maintenance and repair of sites are set out in the ‘Implied’ and ‘Express’ terms of an agreement. A breach of an obligation could be enforced through the Tribunal. Operators may be compelled by a reduction in income to reduce the frequency and standard of some repairs, but will strive do so within the scope of their legal obligations. It is unlikely that residents simply being dissatisfied with this would be a breach of the site operators’ legal obligations. Licensing authorities would also need to be mindful that a reduction in income would mean there will be conditions of the site licence which could not be met.

Third, existing residents’ pitch agreements reflect what they were willing to pay to site the home on the pitch - together with future pitch fee payments and a maximum 10% commission. As the price was determined without coercion, it follows that the removal or reduction of the commission rate would be a retrospective change that would disadvantage the site operator.

Question 31

Is there any justification for applying any change to the commission payment to existing agreements? If so, what are your reasons?

Summary of responses

Most residents believe that any change should apply retrospectively, in the same way that the change to the pitch fee review inflationary index was applied to all existing residents. Site owners will be able to set pitch fees for new sales at whatever level they deem appropriate in response to the change in commission. Some suggested that existing residents should be bound by the contractual commitment as the onus is on the buyer to understand what they are agreeing to before accepting those terms.

For site owners, there is no justification for applying any change to the payment of commission without making a compensatory payment to recognise the loss of a recognised income stream and the commitment to the use of the land as a permanent housing tenure. Any change should not apply to any existing agreement (including those that have been assigned to a new owner by sale or gift) as the home will have first been sold by the operator at a price that reflects the current legislative framework. Many park operators will have made borrowing and investment decisions based on the existing legislation, entered into written agreements and set pitch fees with this in mind. A change in the commission rate will leave operators bound by contracts and agreements that they may not have entered into had the commission not been factored in.