Renters’ Rights Act 2025 – the impact on Integrated Care Boards

The Renters’ Rights Act 2025 (RRA) brings about huge changes to the Private Rented Sector (PRS), with phase 1 having come into force on 1 May 2026. While the role of the Integrated Care Board (ICB) in commissioning accommodation is not always straightforward, ICBs will at times need to deal with the PRS when commissioning accommodation for service users as part of their overall care arrangements, most often in the context of Continuing Healthcare or s117 aftercare packages. In this article we discuss some of the key impacts of the RRA that ICBs will want to be aware of when commissioning accommodation for service users. 

At a high level, the RRA:

• Ends fixed term assured shorthold tenancies. All current and new tenancies will now become periodic assured tenancies. Tenants will have the right to remain in the property on an ongoing basis until they either end their tenancy by providing two months’ notice, or the landlord follows the necessary eviction procedure under one of the statutory grounds;
• Abolishes section 21 “no fault” evictions, which gave the landlord the right to reclaim the property at the end of the tenancy’s fixed term. Landlords will now only be able to evict a tenant by relying on statutory grounds under section 8 Housing Act 1988 
• Limits rent increases to once per year on 2 months’ notice, with tenants having the right to challenge any increase they consider is above open market rent; 
• Landlords will only be able to request 1 months’ rent in advance; and
• Introduces stronger tenant protection, including a prohibition on discriminating against people in receipt of benefits.

Ultimately these changes operate to give tenants significantly greater security but may also reduce the flexibility which is often helpful when commissioning accommodation in the PRS. 

Key takeaways for ICBs

Overall, the changes are positive for service users and should help ICBs to commission stable care arrangements, and in particular provide:

• Greater stability - the new rules provide greater stability for placements as tenants (and those making decisions on their behalf where they lack capacity) will have greater control over the duration of the tenancy, making it easier for ICBs to commission appropriate care and properly manage transitions to new placements;
• More affordable accommodation with fewer upfront costs – the limitation on rental increases and advance rental payments, and the ban on rental bidding wars, should help to reduce escalating rental costs. However, rental costs will still be tied to market rates and subject to supply and demand; and
• The prohibition on discriminating against renters who receive benefits may increase the available housing options for service users, many of whom will be in receipt of housing benefits.

However, the impact of these changes may also result in:

• Reduced supply of accommodation – landlords in the private sector may be less willing to accept the risks involved in renting to vulnerable service users, and we may see an increase in landlords moving out of the PRS leading to even more competition for accommodation;
• Change in landlord behaviour - landlords may find alternative mechanisms to manage the risks of accommodating service users, such as stronger contractual terms around property damage, and an increase in requests for a guarantor; 
• If a placement deteriorates moving the service user may be slower and more complex; and
• We may also see an increase in rental prices as landlords seek to mitigate the additional administrative burdens and limitations on rent imposed under the RRA. 

Going forward ICBs may find themselves having to navigate the new rights and obligations for tenants and landlords under the RRA in order to ensure that service users are properly supported and their needs continue to be met. If you need assistance with matters involving the RRA and service users housing rights when commissioning care and accommodation, please get in touch with our team and we would be happy to help.

To support teams, we are providing up-to-date guidance, practical tools and commentary as the legislation is implemented. With our dedicated hub, you can understand the changes, assess impact and take practical steps to remain compliant.

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