Disclaimer: This article is for general information only and does not constitute legal, tax, or financial advice. Always consult a qualified solicitor, French notaire, avocat, or chartered accountant before acting on anything you read here. The English Investor accepts no liability for decisions taken on the basis of this article.
The largest reform of the English residential rental market in nearly four decades came into force at one minute past midnight on 1 May 2026. The Renters’ Rights Act 2025, which received Royal Assent on 27 October 2025, abolishes the section 21 “no-fault” eviction notice that has shaped the relationship between English landlords and tenants since the 1988 Housing Act. Fixed-term assured tenancies disappear. All tenancies become periodic. The mandatory rent-arrears threshold for eviction goes up from two to three months. Tenants gain a default right to keep a pet. Rental bidding wars become illegal. The list goes on.
For British investors who hold residential property in France as well as the UK, the Act is interesting on two levels. First, because it changes the home market, and several of you are letting in both jurisdictions. Second, because the Westminster reform brings English law substantially closer to a tenant-protection model that France has had since the loi du 6 juillet 1989 — the same statute we wrote about in detail in our Q1 2026 IRL guide and our guide to evicting a French tenant. There is, for once, a small upside to the dual-jurisdiction headache: British landlords with property in France are unusually well prepared for what the UK has just legislated, because the French regime they have been navigating for years is the regime English tenants are now starting to live under. This article walks through what the Renters’ Rights Act actually does, the concrete differences between the new English regime and the equivalent French rules, and what it means in practice for a non-resident landlord operating in both markets.
What the Renters’ Rights Act actually does
The Act applies only to England. Wales (which already has its Renting Homes (Wales) Act 2016), Scotland (which abolished no-fault evictions in 2017), and Northern Ireland are unaffected. The BBC has a useful tenant-and-landlord-facing summary of the headline reforms. According to the government’s implementation roadmap published on 13 November 2025, the Act will commence in three phases. The first and most consequential phase — the tenancy reform itself — comes into force on 1 May 2026. The second phase, in late 2026, brings in the Private Rented Sector Database. The third phase, scheduled for 2027 and beyond, completes the remaining provisions.
The headline reform is the abolition of section 21. Since 1988, an English landlord on an assured shorthold tenancy could give two months’ written notice and recover possession at the end of any fixed term — without giving any reason. From 1 May 2026, that route disappears. Every notice to vacate must rely on a specified statutory ground. The ground must be supported by evidence. Some grounds (sale, the landlord moving in, family member moving in) are mandatory — meaning the court must grant possession if proven. Others (anti-social behaviour, persistent late payment, breach of tenancy terms) are discretionary — meaning the court considers whether eviction is reasonable.
The second structural change is the end of the fixed-term assured tenancy. Where landlords and tenants previously signed for, typically, a 12-month fixed term followed by a statutory periodic tenancy, all tenancies will now be periodic from day one. Tenants can give two months’ notice to leave, at any time. Landlords have no equivalent unilateral right — they need a ground.
The Act also adjusts the rules around rent arrears. The mandatory ground for possession on rent arrears (the old “ground 8”) moves the threshold from two months’ arrears to three, and the notice period from two weeks to four. Tenants in temporary financial distress get more breathing room. Discretionary grounds for persistent late payment continue to exist alongside the mandatory ground.
Beyond eviction reform, the Act does several other things in one piece of legislation:
- Rent increases are limited to once per year, must be at market rate, and can be challenged by the tenant at the First-tier Tribunal (Property Chamber). The tribunal cannot impose a rent above the market rate but can refuse a rent above what the property merits.
- Rent in advance is capped at one month — landlords cannot demand more than that as a deposit-style upfront payment.
- Rental bidding wars are banned. Landlords and letting agents must publish an asking rent and cannot solicit or accept offers above it.
- Pet ownership becomes a default right that tenants can request and landlords cannot unreasonably refuse. Landlords can require the tenant to take out pet damage insurance.
- Discrimination against tenants in receipt of benefits or against tenants with children is prohibited explicitly in statute.
- A new Private Rented Sector Landlord Ombudsman is created with mandatory landlord membership; tenants can refer disputes to the Ombudsman without going to court.
- The Decent Homes Standard, previously a social-housing concept, is extended to the private rented sector.
- Awaab’s Law — named after the toddler who died from mould exposure in 2020 — sets statutory timelines within which a landlord must investigate and remedy hazards like damp and mould. Originally introduced for social housing in 2024, it now extends to the PRS.
The mirror across the Channel: what France already has
For a reader of this site, the striking thing about almost every item on that list is how familiar it sounds. France’s loi du 6 juillet 1989 — the loi Mermaz, the foundational statute of French residential tenancies — has provided most of these protections to French tenants for nearly forty years. Where Westminster has just legislated, Paris has been there since the Mitterrand era. The Renters’ Rights Act is, in substance, a long-delayed catch-up rather than an innovation.
The most direct parallel is the abolition of section 21. France has never had an equivalent. Under article 15 of the loi du 6 juillet 1989, a French residential landlord can only give notice to terminate at the end of the lease, and only for one of three justified grounds: reprise (the landlord or a close relative wishes to occupy the property), vente (the landlord intends to sell, with the tenant’s pre-emptive right of purchase), or motif légitime et sérieux (a serious legitimate ground, including sustained rent arrears or anti-social behaviour). Six months’ notice is required for unfurnished tenancies under article 15; three months for furnished tenancies under article 25-8 of the same statute. The English landlord giving a section 21 notice in April 2026 had a legal right that no French landlord has ever had since 1989.
The fixed-term-versus-periodic distinction is resolved differently. French residential tenancies are nominally fixed-term: three years for an unfurnished lease (or six years where the landlord is a legal person), one year for a furnished lease (nine months for a student-only let). At the end of the contractual term, the lease is automatically renewed (tacite reconduction) for the same duration unless the landlord gives a justified-ground notice within the statutory window. From the tenant’s side, the apparent fixed term is in practice asymmetric: a French tenant can leave at any time during the lease, with three months’ notice for an unfurnished tenancy (reduced to one month in zone tendue or in several other circumstances such as job loss or social-housing offer) and one month for a furnished one. The lease is not periodic in the English sense, but the practical security of tenure for the tenant is greater than under the old English regime — and arguably greater than under the new one too.
On rent revision, France goes further than the new English Act. The indice de référence des loyers (the IRL) caps rent increases during the lease at the year-on-year change in a national index — currently +0.78% for the Q1 2026 reference quarter, as we covered in our IRL guide. The Renters’ Rights Act introduces no such national cap; it requires market rate and offers the tribunal as a backstop, but does not set a ceiling. A French tenant’s rent revision is a fixed cap; an English tenant’s is a tribunal-tested floor.
On pets, France’s loi du 9 juillet 1970 (article 10-1) has, since 1970, given tenants a default right to keep a non-dangerous pet — a right English law has only just acquired. On rental discrimination, the French Code pénal at article 225-2 has criminalised discrimination on the basis of family situation, source of income, or other protected characteristics for many decades. On rental bidding, French market practice already involved a published asking rent and frowned on overbidding — although the explicit statutory prohibition the Renters’ Rights Act creates does not exist in France in the same form.
Side-by-side: England (post-1 May 2026) vs France (current law)
| Topic | England (post-1 May 2026) | France (loi du 6 juillet 1989, current) |
|---|---|---|
| Default tenancy structure | All assured tenancies periodic; tenants can leave with 2 months’ notice. | Nominally fixed-term: 3 years unfurnished (6 if landlord is a legal person), 1 year furnished, 9 months for student-only. Tacite reconduction at end of term unless landlord gives a justified-ground notice. Tenant can leave at any time during the lease with the relevant tenant notice period. |
| No-fault eviction | Abolished. Landlord must rely on a specified statutory ground. | Has never existed under the loi du 6 juillet 1989. Landlord must rely on reprise, sale, or serious legitimate ground. |
| Notice period to terminate | 4 weeks for rent arrears at the mandatory threshold; longer for other grounds. Tenants give 2 months. | Landlord (only at end of term, on a justified ground): 6 months for unfurnished (art. 15), 3 months for furnished (art. 25-8). Tenant (any time during the lease): 3 months for unfurnished — reduced to 1 month in zone tendue or for specific personal circumstances; 1 month for furnished, always. |
| Rent arrears threshold for mandatory eviction | 3 months’ arrears + 4 weeks’ notice (raised from the previous 2 + 2). | No fixed threshold; landlord can issue a commandement de payer after default and seek termination via the courts on serious legitimate ground. |
| Rent revision during tenancy | Once per year, market rate, tribunal challenge available. | Once per year, capped at the year-on-year change in the IRL national index. Q1 2026: +0.78%. F/G energy-rated properties: revision blocked entirely. |
| Rent at re-letting / new tenancy | Market rate. Bidding above asking is prohibited. | In zone tendue (Paris, Île-de-France, major cities): capped at previous rent indexed by the IRL. |
| Pets | Tenant request, landlord cannot unreasonably refuse. Landlord may require pet damage insurance. | Default right under the loi du 9 juillet 1970 (art. 10-1) since 1970. Dangerous breeds excepted. |
| Discrimination on benefits / family | Explicitly prohibited from 1 May 2026. | Already prohibited under Code pénal art. 225-2 (broader scope including origin, family, source of income). |
Read across, the table makes the underlying point clear: the Renters’ Rights Act is England catching up to France on the major structural questions, while remaining looser on rent regulation. France caps rent indexation; England trusts the tribunal. France has zone tendue rent ceilings on re-letting; England has none. France has had pet rights since the Pompidou era; England gets them in 2026.
What is genuinely new in the English Act
Two pieces of the Renters’ Rights Act go beyond what France currently has and are worth flagging.
The first is the Private Rented Sector Landlord Ombudsman. Membership is mandatory for all PRS landlords, and tenants can refer disputes — over repairs, deposit handling, rent revision, conduct — to the Ombudsman without a court action. The Ombudsman’s decisions are binding on the landlord. France has a more fragmented landscape — disputes go to a commission départementale de conciliation at first, then to the courts — and there is no single national tenancy ombudsman.
The second is Awaab’s Law. Named after Awaab Ishak, the two-year-old who died in 2020 from mould exposure in his Rochdale flat, the law sets statutory timelines within which a landlord must investigate damp and mould reports and complete remedial works. France regulates housing decency through the décret du 30 janvier 2002 (n° 2002-120) and through the diagnostic de performance énergétique regime — but it has no statute imposing specific timelines on individual repair categories. The English Act is genuinely more granular here.
What this means for British investors with property in both markets
Several practical implications follow for the dual-market landlord.
The “I’ll just give them notice” option disappears in England too. If you held a UK rental on the assumption that you could regain possession with two months’ notice for any reason, that assumption no longer holds from 1 May 2026. The mental model that British investors typically applied to their French rentals — i.e., that you cannot evict without a justified ground — now applies symmetrically. Coordination across portfolios becomes simpler in this respect: the same defensive due diligence (pricing the encumbrance correctly, holding leases that you have actually read, screening for tenant fit) applies to both jurisdictions.
Sale-led repossession remains available in both jurisdictions, with similar mechanics. The Renters’ Rights Act keeps a mandatory ground for sale; the loi du 6 juillet 1989 has always had a congé pour vendre. In both cases the tenant has procedural protections (in France, a pre-emptive right of purchase; in England, longer notice and limits on misuse). British landlords who hold property in France for buy-to-sell purposes will recognise the French regime; they now need to recognise its English mirror.
Rent indexation remains the meaningful structural difference. A French landlord’s rental income tracks the IRL — a slow-moving, deliberately conservative index that runs below headline inflation. An English landlord’s rental income tracks market rate, with a tribunal as backstop. For a buy-to-let investor planning real-terms cash flow over a 10-15 year hold, the English market remains structurally more inflation-protective than the French one — even after the Renters’ Rights Act. This is not a question of tenant rights; it is a question of how the rental income series is constructed.
Compliance load goes up in England, narrowing the gap with France. The PRS Landlord Ombudsman, the Decent Homes Standard, Awaab’s Law, the new Database when it comes online in late 2026, the renewed enforcement powers given to local authorities — these all amount to a meaningful increase in the administrative burden of being an English landlord. French landlords have been operating under the loi du 6 juillet 1989 framework, the DPE regime, and the various local enforcement bodies for decades. The English regime is moving towards a similar density of regulation, and a similar requirement to actually read the law before letting a property out.
If you’re holding French property and considering moving an investment back to the UK, the previous “England is lighter-touch” argument has weakened materially. It hasn’t disappeared — the rent indexation and zone tendue caps are still meaningfully tighter in France — but the historical gap between the two jurisdictions on possession, eviction, and security of tenure has narrowed substantially. The right framework for thinking about an English vs French letting investment is now closer to “different rules, similar ceilings of regulation” than “open vs closed market”.
What’s still to come (Phase 2 and Phase 3)
The implementation roadmap published in November 2025 sets out a three-phase commencement. Phase 1 (1 May 2026) is what we’ve covered above and is the substantive tenancy reform. Phase 2 launches in late 2026 and brings in the Private Rented Sector Database — a central register of PRS properties and landlords, with information available to tenants, landlords, and councils. Among other things, it will allow a tenant to verify a property’s compliance status before signing a lease. Phase 3, scheduled for 2027 and beyond, completes the remaining provisions — including the mandatory Ombudsman, the rent repayment order extensions, and various secondary regulations.
For investors planning their 2026-2027, the practical takeaway is that the bulk of the regime change took effect on 1 May 2026; the supporting infrastructure (Database, Ombudsman) follows over the next 12-18 months. None of this is comparable to the long, multi-year DPE renovation roadmap that French landlords are still working through under the loi Climat — which we covered in our DPE 2026 guide. But for the tenancy-side regime, England moves in one decisive phase rather than the staggered French approach.
Frequently asked questions
When does the Renters’ Rights Act come into force?
The Act received Royal Assent on 27 October 2025. The substantive tenancy reforms — abolition of section 21, end of fixed-term assured tenancies, and the revised possession grounds — come into force on 1 May 2026 in England only. A second phase covering the Private Rented Sector Database launches in late 2026, and remaining provisions follow in 2027 and beyond. Wales, Scotland, and Northern Ireland have their own separate regimes.
Does the Act apply to existing tenancies, or only new ones?
It applies to both. From 1 May 2026, all existing assured shorthold tenancies automatically convert into the new periodic assured tenancy structure. Section 21 notices served before that date and still in their notice period will need to be reviewed under transitional rules; section 21 notices not yet served cannot be served from 1 May 2026 onwards.
Can I still evict a tenant who is not paying their rent?
Yes. The Act keeps mandatory and discretionary grounds for rent arrears. The mandatory threshold rises to three months’ arrears (from two), and the notice period rises to four weeks (from two). Discretionary grounds — for persistent late payment that does not meet the mandatory threshold — continue to exist. The court still adjudicates the possession order.
Can I increase the rent on my English tenant?
Yes, once per year, at market rate. The tenant can refer the proposed increase to the First-tier Tribunal (Property Chamber). The tribunal cannot impose a rent above the market level for the property but can refuse a rent above what the property merits. There is no national index-based cap as in France’s IRL system.
How does this compare to French law?
France has had broadly equivalent tenant protections under the loi du 6 juillet 1989 since 1989. France never had a section-21 equivalent: a French landlord has always needed a justified ground (reprise, sale, or serious legitimate ground) to terminate. France caps rent indexation at the IRL national index — currently +0.78% for Q1 2026 — which is structurally tighter than the new English regime. France has had pet rights since 1970 and rental discrimination has long been criminalised. The Renters’ Rights Act narrows the historical gap; it does not close it.
Does the Act apply to short lets / Airbnb?
No. The Act regulates assured tenancies — the long-term residential rental market. Short-term lets and holiday rentals operate under separate licensing and planning rules, which were tightened by the Levelling-up and Regeneration Act 2023 and through subsequent statutory instruments on short-let registration. France’s equivalent short-let regime (the loi Le Meur framework on meublés de tourisme) is the subject of our guide to Airbnb in France.
What is the new Private Rented Sector Database?
A central register of properties and landlords in the English private rented sector, scheduled to launch in late 2026 as part of phase 2 of the Act’s implementation. Information will be available to tenants (to verify property compliance before signing), to landlords (to demonstrate compliance), and to councils (to target enforcement). It is not yet live and the supporting secondary legislation is still being prepared.
Can I evict my English tenant to move in myself?
Yes — under a specified mandatory ground. The Act introduces safeguards (more notice, restrictions on misuse, and a moratorium on re-letting after a sale or own-occupation eviction) but the right itself survives. France has the equivalent congé pour reprise under article 15 of the loi du 6 juillet 1989, with similar but not identical safeguards.
