This blog post is authored by Martin Blakey, the former Chief Executive of Unipol, a charity dedicated to student housing, as well as a member of the British Property Federation’s Student Accommodation Committee. On Wednesday, 22 October 2025, the Renters’ Rights Bill successfully completed its final stage in a sparsely attended Commons chamber, subsequently obtaining Royal Assent on 28 October. The Higher Education Policy Institute (HEPI) has closely monitored the implications of the Act on student tenancies, providing insights throughout the Bill’s progression, which are summarised at the end of this article.
The journey of this Bill has been lengthy, initially emerging under the previous Conservative government as the Renters’ Reform Bill in May 2023. Following some revisions, it was reintroduced by the newly elected Labour Government just ten weeks into its tenure in September 2024. Despite Labour’s substantial majority, the Bill took 13 months to navigate through the parliamentary process, encountering over 450 amendments along the way.
This comprehensive Act will be implemented in phases, introducing various provisions over time. It includes numerous enabling powers, which allow Ministers to roll out more detailed policies as further consultations occur. Key elements such as the right to redress, the landlord database, and the Decent Homes Standard are set to undergo consultation, with additional regulatory frameworks expected within the next year.
Even during the Bill’s final stages, the Government did not provide a clear timeline for implementation. However, it is reasonable to anticipate that reforms regarding tenure, which are not heavily reliant on secondary regulation, will be prioritised for early implementation. The Government must decide how long to allow for raising awareness among landlords and tenants about these significant changes, as well as the necessary time for those managing private sector housing to adjust to the new legal framework for existing and future tenancies.
Implications for Current Students
With the mechanics of the Act now established, it is possible to outline what the changes mean for student tenants and to provide an informed estimate of the timeline involved. Students currently enrolled for the 2025/26 academic year and those signing tenancy agreements for the 2026/27 academic year will experience alterations to their tenancy status.
As stated by Matthew Pennycook on 8 September 2025, the introduction of the new tenancy system for the private rented sector will occur in a single stage: “On this date the new tenancy system will apply to all private tenancies – existing tenancies will convert to the new system, and any new tenancies signed on or after this date will also be governed by the new rules. Existing fixed terms will be converted to periodic tenancies.” Thus, the long-standing fixed-term assured tenancy (AST) historically employed by most students renting from the private sector will be replaced with a new assured tenancy framework. This means that the fixed term associated with ASTs will no longer exist, and any rent payment periods exceeding four weeks will be unenforceable.
Depending on various sources, these changes are expected to take effect between April and June 2026, directly impacting today’s student tenants. The process for implementing these changes will be crucial and can be mapped out as follows.
Transitioning Tenancies: What to Expect
There will be no interim stages following the implementation of the Act. Consequently, landlords who have previously signed students up under the current system will continue to utilise fixed-term ASTs until the transition date. Both landlords and tenants entering into agreements during this period should view their contracts as general agreements for residential tenancy. The precise status of the tenancy will be determined at the moment the tenant takes possession and moves into the property, marking the official granting of the tenancy.
Now, let us explore various scenarios and their implications.
Students in Off-Street Shared Houses (HMOs)
Students currently residing in off-street shared houses will almost certainly be on joint or individual ASTs, most often featuring a stipulated fixed period within their agreements. Upon the Act’s tenure implementation, these arrangements will transition to assured tenancies, meaning the fixed-term stipulations in their contracts will dissolve.
The Government has recognised the necessity to maintain the lettings cycle for student shared houses in alignment with the academic year. Hence, landlords will be permitted to seek repossession of their properties using a newly established ground for possession, referred to as ground 4a. This provision allows landlords to notify tenants of their intention to pursue repossession on a specific date between June and September.
After the implementation phase, landlords must inform tenants within the first 30 days regarding their intention to invoke ground 4a. Following this transitional period, landlords will need to notify tenants of their intention to use ground 4a at the time of signing the contract. Under ground 4a, landlords can issue tenants with a four-month notice to vacate, which can be executed through the courts.
However, legal experts highlight a potential issue: if the implementation occurs between April and June, and many fixed terms expire in June or July, there may not be sufficient time to provide the requisite four months’ notice under ground 4a. Consequently, tenants could opt to remain in the property and give two months’ notice whenever they choose to vacate. This scenario presents a challenge for landlords, as they may find themselves unable to utilise ground 4a effectively, especially if they have already let the property to a new cohort of tenants without having secured vacant possession. Courts may not hold landlords accountable for any financial claims or compensation sought by incoming tenants needing to find alternative accommodation, particularly if the landlord has attempted to mitigate losses.
Landlords retain other methods for terminating tenancies during the implementation period. Until the date when ASTs convert to assured tenancies, landlords may still issue notices via the current ‘no fault’ eviction procedure under Section 21 (S21), which requires a minimum two-month notice period. A S21 notice can be dispatched any time after the first four months of the AST, meaning that most landlords will likely issue a S21 notice to their resident students while the tenancy remains an AST, assuring them a right to repossession at the conclusion of their fixed term. The Renters’ Rights Act does not invalidate a valid S21 notice. Only after the implementation of the tenure changes will it become impossible to issue an effective S21 notice.
It is crucial to note that serving a notice of intention to seek repossession does not equate to an immediate eviction; only a court can carry out such an action. Typically, students tend to vacate at the end of their tenancy, suggesting the absence of major anticipated issues.
Students in Smaller Off-Street Houses
The situation mirrors that of shared houses concerning the requirement for a valid S21 notice. However, once the Act is implemented, ground 4a cannot be invoked for smaller off-street houses, as its application is limited to off-street HMOs. Thus, once the tenure reform is enacted and the window for issuing S21 notices has elapsed, tenants in these properties can remain indefinitely until they provide two months’ notice to vacate. This may lead landlords of smaller houses and flats to house non-student tenants.
Efforts to extend ground 4a to encompass all properties occupied by students were firmly rejected by the Government during the Bill’s discussions. Baroness Taylor of Stevenage clarified the Government’s stance on 15 October 2025, stating, “The Government recognises that the new tenancy system will impact the operation of the student market. While we believe the ground covers the majority of the market, there is no one-size-fits-all solution that addresses all circumstances. We think it is reasonable that the ground will apply to full-time students in larger house-share situations. Removing this restriction could lead to students who need more security of tenure – such as single parents living with their children or postgraduate couples living together who have established roots in the area – being evicted more frequently.”
It is anticipated that some properties previously occupied by students may remain tenanted, resulting in this stock transitioning from the student market to the general rental market.
Post-Implementation Scenarios for Students
Students residing in off-street housing after the Act’s implementation will have assured tenancy status, fully subject to the new provisions. Except for ground 4a in shared student houses, they will be entitled to remain in their properties as long as they wish and can provide a two-month notice at any point during the year to vacate.
Currently, these students are signed under ASTs, but following implementation, numerous conditions will be replaced by the new legislative provisions.
Students in Purpose Built Student Accommodation (PBSA)
The Government has opted to exempt private PBSA that adhere to government-approved codes of practice (namely the ANUK/Unipol Code) from the effects of the Act by amending the definition of ‘specified educational institutions’ to ‘specified institutions’ within the provisions of the 1988 Housing Act. This technical alteration designates PBSA providers as specified institutions (similar to most educational institutions), which means their tenancies will be classified as common law tenancies, allowing fixed-term tenancies to persist in these properties.
However, existing contracts in private sector PBSA will experience a ‘transitional period,’ as only tenancies granted after the specified status has been established will be classified as common law tenancies. The Government has articulated that retroactively applying the exemption could pose significant risks, potentially transforming existing PBSA tenancies into common law tenancies, which are primarily governed by the tenancy agreement’s terms. This could inadvertently lead to PBSA tenancies offering significantly fewer rights to tenants than the assured shorthold tenancies they originally signed. Therefore, the Government believes it is inappropriate to simply exempt existing PBSA tenancies from assured tenancy status.
Consequently, existing AST tenancies in PBSA will transition to assured tenancy status. Following the designation of specified status (effective from the date of tenure implementation), future tenancies will revert to common law tenancies.
The Government has instituted certain concessions to alleviate the ‘transitional effects’ of this change. For instance, properties are not required to be HMOs to utilise ground 4a repossession, and the specific July to September timeframe associated with ground 4a will not apply. PBSA providers will still be able to issue S21 notices (as previously described) before implementation, and subsequent to that, they will be able to employ the new ground 4a across all PBSA properties. This flexibility is likely to prove beneficial as tenancies concluding in September (primarily concerning studios) will provide ample time to issue tenants with four months’ notice under the new Act.
While there may be apprehensions if a student does not receive a S21 notice and opts to remain in the property, they may still receive four months’ notice under ground 4a after implementation. However, the likelihood of this occurring is considerably diminished in PBSA, where the availability of alternative accommodation within the same building or nearby can mitigate potential inconveniences for incoming tenants.
Future Tenancies in PBSA
Currently, students will continue to be placed on ASTs, given that this is the prevailing system. As previously indicated, the status of any new tenancy will be determined by the timing of the tenant ‘taking possession’ and moving in (which signifies the formal granting of the tenancy). If the move-in date occurs after the PBSA provider has secured specified status, tenants will be subject to common law tenancies. This common law tenancy format dictates that the terms of the letting are governed by the tenancy agreement between the tenant and landlord, placing them outside the tenure provisions of the Act, which primarily apply to assured tenancies. Common law tenancies permit fixed-term arrangements, wherein repossession can be conducted based on the terms outlined in the tenancy agreement.
While tenants in PBSA may possess fewer rights under the Act compared to other tenants, membership in the Approved Code will ensure continued deposit protection and allow tenants to provide four weeks’ notice if they fail to achieve their required grades, discontinue their studies, or withdraw due to illness. The complaints system within the Code has also been enhanced. Consequently, tenants renting from PBSA will experience an improvement in tenure flexibility.
Challenges and Market Repercussions
Assuming implementation occurs between April and June 2026, the annual summer changeover in 2026 should proceed relatively smoothly. Landlords are likely to make extensive use of S21 notices, ensuring that most tenancies are concluded appropriately. Should implementation occur earlier than April, the four-month notice period provided under the new ground 4a can still be utilised.
A notable concern pertains to off-street non-HMOs and how many of these students, or former students, will elect to stay, potentially diminishing the supply of housing available to future students. It is anticipated that, over subsequent letting cycles, a significant portion of this type of housing will transition into the mainstream rental market, thereby disrupting the timing of the academic cycle. Educational institutions and students’ unions should closely monitor this shift and assess how it impacts admissions.
Another interesting aspect of ground 4a is that it will not apply to future signings if students enter into contracts six months prior to their move-in date. This raises questions about whether this stipulation will affect ‘early letting’ in the off-street market and its repercussions on current PBSA practices.
Supporting Smooth Implementation of the Act
Given the complexities surrounding tenure, it is imperative that all efforts are made to inform students about the implications of this change. Current information suggests that awareness among students regarding the Act is alarmingly low, with a survey by StuRents indicating that 69% of students have never heard of the Renters’ Rights Bill, while only 15% understand how it could impact them. Additionally, a recent study conducted by Unipol revealed that 62% of students were unaware of the Bill.
Students will benefit significantly from the assured tenancies that the Act provides, which include the ability to give two months’ notice and, perhaps most notably for financially constrained students, only needing to pay rent four weeks in advance. Over the longer term, they will also benefit from minimum standards enshrined under the Decent Homes Standard and a right of redress through an ombudsman.
However, some individuals may temper these immediate benefits by predicting a potential decrease in the availability of student housing, leading to rent increases, a growing reliance on guarantors, and rising deposit levels to mitigate the risks associated with shorter rent payment periods. Moreover, since many shared student houses (HMOs) are already subject to licensing, it is expected that they are maintained to safety and quality standards.
The implications of the Act on the market and student experience remain uncertain. Therefore, it is crucial for institutions to monitor how the Act affects their students in the local property market. In the PBSA sector, the Act’s impact may be less pronounced; however, it coincides with a period of rapid transformation characterised by a slowdown in development, challenges related to maintaining ageing stock, the rise of commuter students, increased regulation following the Grenfell tragedy with the establishment of the Building Safety Regulator, and issues surrounding elevated rent levels and affordability.
These market and legislative changes will lead to significant transformations within the student housing landscape over the coming years, necessitating that advice regarding housing rights and supply reflects these shifts and that assumptions regarding the continuity of the status quo are set aside.
For further reading on this topic, the following HEPI publications provide valuable insights:
- Renters (Reform) Bill and the Impact on Higher Education – 24 May 2023 by Rose Stephenson
- How the Renters (Reform) Bill Can Deliver for All Tenants – Including Students – 13 November 2023 by Calum MacInnes
- Students and the Renters (Reform) Bill: The Government Has Listened But It Needs to Listen Some More (Part I) – 29 January 2024 by Martin Blakey
- Students and the Renters (Reform) Bill: The Government Has Listened But It Needs to Listen Some More (Part II) – 30 January 2024 by Martin Blakey
- The Renters Reform Bill: After the Fall – Where Should Student Housing Go From Here? – 19 June 2024 by Martin Blakey
- Renters’ Rights Bill and Student Accommodation: The Final Stretch? – 9 October 2024 by Martin Blakey
- Renters’ Rights Bill Update – Into the Lords – 2 February 2025 by Martin Blakey