RRA Phase 2: the PRS Database, the Landlord Ombudsman, and getting your portfolio registration-ready

The first phase of the Renters' Rights Act has settled into routine. Periodic tenancies are the default, Section 21 is gone, and the inbox panic of May has eased into business as usual. So the question we hear most from agencies now is the right one to be asking: what's next, and when do we need to be ready?

The answer has firmed up. In its implementation roadmap the government confirmed that Phase 2 of the Act - the part that builds the sector's new infrastructure - begins from late 2026, and it reaffirmed that window again this month. Two things arrive in this phase: a mandatory PRS Database and a new Landlord Ombudsman. Neither is live yet. But the work that gets your managed portfolio ready for them is a data exercise, and data exercises take months, not weekends.

This is operational guidance for letting agents, not legal advice. Registration duties and penalties ultimately bind landlords; where a specific case is contentious, point the landlord to a solicitor.

What Phase 2 actually is

The Act is being switched on in three phases. Phase 1 (1 May 2026) was the tenancy regime. Phase 2, from late 2026, introduces two pieces of permanent infrastructure:

• A Private Rented Sector Database - a register of landlords and rented properties in England, so tenants can check who they're renting from, councils can target enforcement, and landlords can evidence compliance.
• A Landlord Ombudsman - an independent redress service for tenants' complaints against private landlords, intended to settle disputes without the cost of court.

Neither went live on 1 May. Both need their own commencement and secondary legislation, and the government has been explicit that the database will roll out gradually, area by area, from late 2026 - not as a single national switch-on. Treat anyone telling you these are already in force with suspicion; they aren't.

The timeline, as it stands

Dates in Phase 2 are firmer than they were, but still staged and still moving. Here's the shape of it.

Late 2026: the PRS Database starts rolling out. Registration will be mandatory for all private rented sector landlords, who will pay an annual fee set closer to launch. The rollout is regional, so your area's go-live date won't be the same as the national headline.

After the database: the Landlord Ombudsman. The government has confirmed the ombudsman follows the database rather than arriving alongside it, partly so the two can share data and cut duplicate sign-up. Mandatory membership is expected in 2028, funded by landlords through what the government calls a fair and proportionate charging model. The intention is for the Housing Ombudsman Service - which already runs social landlord redress - to operate it.

22 June 2026: the redress regulations reached the Commons. MPs debated the draft Private Landlord Redress Schemes (Approval and Designation) Regulations 2026. These set the conditions a scheme must meet; they do not themselves designate a scheme or require any landlord to join one yet. The government has said it intends a single designated scheme, not a marketplace of competing ones.

Phase 3, later: Awaab's Law and Decent Homes. The extension of Awaab's Law to the private rented sector and a modernised Decent Homes Standard sit in a third phase, with timescales subject to consultation.

A word on certainty: the government's stated position is "from late 2026", but the database is a build-and-rollout programme and the exact date your region opens - and the fee - aren't confirmed. Plan for late 2026 to 2027, and don't quote a hard local date to a landlord until gov.uk gives one.

The PRS Database is really a data-quality job

Strip away the policy language and the database is a structured record of three things, per property: who the landlord is, what and where the property is, and whether it's safe. The roadmap indicates landlords will need to provide contact details, property information, and core safety records - gas safety, electrical (EICR) and EPC certificates among them.

Here's the operational reality for an agent. Registration is the landlord's legal duty, but you hold the data and you'll do the admin. When the database opens in your area, the bottleneck won't be the form - it'll be whether you can pull a clean, current, complete record for every managed property without a week of digging through emails and shared drives. The agencies that struggle will be the ones whose certificate expiry dates live in someone's head and whose landlord contact details were last confirmed two years ago.

The same discipline you built for selective licensing applications applies here, at portfolio scale: one authoritative record per property, kept current, ready to export.

The Landlord Ombudsman - and how it differs from your agent redress scheme

Don't confuse this with the redress scheme you already belong to. As a letting agent you've been required to be a member of a government-approved redress scheme since 2014 - that covers complaints about your agency. The new Landlord Ombudsman is separate and landlord-facing: it handles tenants' complaints about the landlord, and membership will be mandatory for landlords, not agents.

But you'll feel it, because you're the one handling the tenant on the landlord's behalf. An ombudsman judges process: did the complaint get acknowledged, investigated, and answered in reasonable time, with a record to show it? That makes complaint-handling a workflow, not an afterthought. Practically:

• Log every complaint the moment it lands, with date, channel and substance.
• Acknowledge and set expectations quickly, in writing.
• Keep the audit trail - what you did, when, and why - so an outcome can be evidenced later.

This is the same record-keeping muscle the DSAR obligations already demand: if you can't produce the trail, you can't defend the decision.

Get registration-ready now: the audit

You don't need the database to be live to do the work that matters. Build the per-property record now. For every managed property, confirm you hold and can export:

• Landlord identity and contact details - current name, address, email and phone, verified within the last 12 months.
• Property address and specifics - the full, correct address and property type; flag any HMOs and licensing status.
• Gas safety certificate - present, in date, with the next renewal diarised.
• EICR (electrical) - present, in date, renewal diarised.
• EPC - present, in date, and note the rating against the EPC C direction of travel for later phases.
• Deposit protection - scheme, reference and prescribed information served.
• Tenancy paperwork - the written statement of terms and your Phase 1 records.
• Complaint history - any open or past complaints, with their audit trail.

Mark each property green, amber or red. The reds - missing certs, stale landlord details, gaps in the trail - are your work list for the rest of 2026, and they're easier to fix now than in a queue when registration opens.

Keeping that single, current, exportable record across a whole portfolio is exactly what OdjoAI Property is built to hold - landlord details, property records, certificate dates and the full communication trail in one place. But the principle is process, not product. If you're doing this manually, do it religiously: one record per property, owner assigned, renewal dates diarised, reviewed monthly.

A sensible prep timeline

This quarter

Run the audit above across the full managed book. Triage to green/amber/red and assign owners to the reds.

Before rollout reaches your region

Chase missing and expiring certificates, re-verify landlord contact details, and close the gaps in your complaint-handling trail. Brief your landlords now that registration and a fee are coming so it isn't a surprise conversation later.

As the database opens locally

Register managed properties as your area goes live, working from the clean record you've already built rather than assembling it under time pressure.

Frequently asked questions

Do my landlords need to register on the PRS Database now?

No. The database is not live. Government rollout begins from late 2026, area by area, and registration becomes mandatory for landlords once it reaches them. Preparing the data now is sensible; presenting registration as a current obligation is not.

Is the Landlord Ombudsman the same as my agent redress scheme?

No. Your agency's membership of an approved redress scheme (mandatory since 2014) covers complaints about you. The Landlord Ombudsman is a separate, landlord-facing scheme for tenants' complaints about the landlord, with mandatory membership for landlords expected around 2028.

What information will the database hold?

Per property: the landlord's identity and contact details, property information, and core safety records including gas, electrical (EICR) and EPC certificates. It's designed so tenants can check landlords, councils can target enforcement, and landlords can evidence compliance.

How much will it cost?

Both the database registration and ombudsman membership will be funded by landlords. The government has said fees will be set closer to launch and described the ombudsman charge as a fair and proportionate model - no confirmed figure yet, so don't quote one.

What happens if a landlord doesn't register?

Registration will be a legal requirement backed by civil penalties under the Act, and an unregistered property is expected to create knock-on problems for letting and compliance. The detail will come with the commencement regulations.

The takeaway

Phase 2 is no longer a vague promise - it's a dated programme, and it turns compliance into a data problem. The database wants a clean, current, exportable record for every property; the ombudsman wants a complaint process you can evidence. Neither is live yet, which is exactly why now is the time to act: audit the portfolio, fix the reds, and brief your landlords before the fees and forms arrive. The agencies that register without drama will be the ones who treated late 2026 as a deadline they set themselves.