This is no longer just about certificates
Most landlords and letting agents still think compliance means having:
- Gas Safety Certificate
- Electrical Safety Report
- Energy Performance Certificate (EPC)
- Smoke and carbon monoxide alarms
Those are still required — but they are no longer enough on their own.
The biggest change under the Renters’ Rights Reform is how enforcement now works.
Before, enforcement usually happened after something went wrong. Now, enforcement can happen because a risk exists.
From “something happened” to “this could happen”
Under housing law, enforcement officers do not wait for accidents. They assess risk.
This comes from the Housing Health and Safety Rating System (HHSRS), introduced under the Housing Act 2004.
- Category 1 hazards – serious risk (mandatory action)
- Category 2 hazards – less serious, but still enforceable
A key point many people miss:
A hazard does not require injury.
It only requires the potential for harm.
Real example: a stairway handrail
A stairway with a loose or short handrail, poor lighting, a bend in the stairs, and a family with a young child living there.
No one has fallen. No one has complained. Yet under HHSRS, this can still be a Category 1 or Category 2 hazard because the potential for serious injury exists.
“But it’s never been a problem before”
That thinking is now dangerous.
Local authorities already had powers under:
- Housing Act 2004
- Environmental Protection Act 1990
- Homes (Fitness for Human Habitation) Act 2018
The Renters’ Rights Reform strengthens and accelerates how those powers are used.
- Investigate earlier
- Focus on prevention
- Apply risk-based judgement
- Use civil penalties more readily
Risk is judged — not tick-boxed
The same issue can be low risk in one property and high risk in another.
- Cracked tiles → trip hazard
- Poor ventilation → damp and mould
- Loose paving → slip risk
- Faulty lighting → fall risk
Individually, these look minor. Together, they become enforcement issues.
Why letting agents are now directly exposed
Letting agents are not just administrators anymore.
Agents:
- Advertise properties
- Inspect properties
- Advise landlords
- Hold compliance records
That brings professional expectations.
That brings professional expectations. Under investigatory powers,
councils can:
- enter business premises
- request records including accounts and banks statements
- review inspection files
- assess whether advice given contributed to non-compliance
Liability can sit with:
- the landlord
- the agent
- or both, depending on responsibility
This is now clear in government guidance.
Why this matters for evictions and disputes
With the removal of Section 21 under the Renters’ Rights Reform:
- possession now requires grounds
- tenants can challenge
- non-compliance becomes leverage
Under the Homes (Fitness for Human Habitation) Act 2018, tenants can:
- raise counter-claims
- delay possession
- seek compensation
No-win-no-fee solicitors understand this well.
Compliance failures now create:
- enforcement risk
- litigation risk
- financial risk
The biggest trap of all
The biggest mistake landlords and agents make is thinking:
“I’m a good landlord.”
“I’ve never had a complaint.”
“Nothing has gone wrong.”
The law does not assess intent.
It assesses:
- risk
- condition
- systems
- evidence
Being a good person does not make you compliant.
Being compliant is what protects you.
Our approach
Angel Moves does not teach shortcuts.
Our work is shaped by:
- daily interaction with local authorities
- understanding how officers assess risk
- experience with enforcement, inspections, and disputes
- HHSRS-based thinking used by inspectors themselves
We design compliance from the enforcement officer’s point of view.
We do not teach avoidance.
We teach compliance — so enforcement never becomes the problem.
One simple question to ask yourself
If an enforcement officer inspected one of your properties tomorrow: could you clearly explain how risks were identified, managed, and evidenced?
If you’re unsure, education is the safest place to start.