Housing Rights broadly welcomes the proposals outlined in this consultation and considers them a positive step forward. We especially welcome increased data sharing and believe this can support the functions of the Department, LCCC and HSENI. We further believe that it will benefit tenants directly and indirectly through improved targeting and enforcement, and by fostering positive policy development moving forward.
While respecting the Department’s desire to amend the regulations in a proportionate and balanced manner, we believe the Proposals fall slightly short of achieving this balance, not through what is included in the Proposals, but by what is omitted. While the proposals to amend the regulations are positive, we believe they lack the necessary ‘teeth’ to achieve the goal of enabling more effective action against those who fall short of legal standards. We have made recommendations to address this.
Housing Rights believes these recommendations to be reasonable and that they will serve to strengthen and improve the regulations, achieving the goal of proportionate and balanced amendments to support good landlords, while enabling effective action against those who fall short of their legal obligations. Most importantly, we believe they will deliver better outcomes for the PRS as a whole and the tenants who call it home.
Recommendations:
- Adjust the fee for landlord registration in line with inflation from its 2014 base to enable revenue raising and reinvestment back into the Landlord Registration Scheme.
- The submission of additional information required of landlords regarding the safety and standard of the home should be publicly confirmable by tenants or prospective tenants.
- It should be a mandatory requirement for landlords to provide the additional information outlined in the consultation document.
- Increase the maximum penalty for renting out a property while failing to register with the Landlord Registration Scheme to £50,000, in line with what is in place in Scotland.
- Include an additional proposal to amend the regulations to insert a fit and proper persons test for landlords.