This bill creates an Independent Regulator of Managing Agents (IRMA) and a statutory licensing regime for managing agents operating in England. It requires a Code of Practice, sets criteria and qualifications for licensable activities, and gives the regulator powers to supervise, discipline and maintain a register of licensed agents.
For professionals, the legislation marks a shift from soft-sector standards to statutory oversight: it formalises professional entry requirements, centralises enforcement mechanisms, and establishes a levy-funded regulator. That will affect operating costs, training requirements, complaint routes and the allocation of regulatory risk across managers, landlords and residents.
At a Glance
What It Does
The bill requires a new corporate regulator to oversee managing agents and to operate a licence scheme restricting certain activities to licensed agents. It mandates a Code of Practice and gives the regulator powers to monitor performance, take disciplinary action (including fixed penalties, suspension or termination of licences), and maintain a public register.
Who It Affects
Primary obligations fall on managing agents and any entities that carry out the specified licensable activities; landlords who use agents and residents in leasehold and commonhold properties will experience the practical effects. Training providers, accreditation bodies and local enforcement bodies (for complaint handling coordination) will also be affected.
Why It Matters
This is the first bill to put managing-agent standards into statute rather than voluntary codes. It will create mandatory qualification and governance requirements, change the route for resident complaints, and introduce a new levy-based funding model — all of which could alter costs, market structure and professional standards across the sector.
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What This Bill Actually Does
The bill sets up IRMA as a corporate regulator to supervise managing agents who operate in leasehold and commonhold residential property in England. The Secretary of State must establish IRMA within a year of the Act and lay regulations for its governance, funding and the licensing scheme.
The regulator must keep a register of licensed agents, oversee adjudication of complaints, and publish annual reports that assess performance and stakeholder satisfaction.
Licensing is central: the IRMA (under regulations the Secretary of State must make) will operate an application scheme and issue licences that are valid for three calendar years. Only licensed agents may undertake specified “licensable activities” such as charging, collecting and holding tenants’ money, ensuring compliance with health and safety law for managed dwellings, and carrying out legal obligations on behalf of landlords (explicitly including duties under section 20 of the Landlord and Tenant Act 1985).
The regulator can add further activities after notifying agents and taking representations.The bill gives IRMA powers to set required qualifications and syllabuses, encourages modular delivery and requires periodic reporting on accessibility and appropriateness of those qualifications. Compliance is governed by a statutory Code of Practice issued by the Secretary of State in agreement with IRMA; the Code lists conduct and governance principles (ethical behaviour, recordkeeping, money protection, conflict management, complaints handling, data protection and equality duties).
IRMA must publish guidance to help agents comply and must review the Code every five years with stakeholder consultation.On supervision and enforcement IRMA must monitor performance, publish a database of measures, and coordinate complaint routes — including setting out a relationship with Trading Standards. Where breaches occur IRMA must notify the agent and allow an opportunity to remedy; persistent non-compliance can lead to fixed penalties, licence suspension or licence termination.
Fixed-penalty proceeds go to the Consolidated Fund. A licensed agent may appeal enforcement decisions to the First-tier Tribunal, and the FTT can entertain judicial-review style challenges.
The Five Things You Need to Know
The Secretary of State must establish IRMA within one year of the Act receiving Royal Assent.
A managing agent may only carry out licensable activities (including holding tenants’ money and acting under section 20 LTA 1985) if it holds a licence that lasts for three calendar years.
The IRMA must specify required qualifications and publish syllabuses (with a duty to make qualifications modular and to report every three years on accessibility and appropriateness).
Regulations must create a levy to fund IRMA operations, and the bill requires that the levy not disproportionately affect defined “smaller agents”; monies raised by the levy are to be provided to the non‑executive directors of IRMA.
Enforcement options include fixed-penalty notices (proceeds to the Consolidated Fund), suspension and termination of licences; enforcement decisions are appealable to the First‑tier Tribunal and subject to judicial review.
Section-by-Section Breakdown
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Create IRMA and set governance and funding rules
This part requires the Secretary of State to create a corporate regulator within one year and sets out board composition, appointment routes and governance duties. It bars recent industry employees from non‑executive roles and requires at least half the executive members to be free of recent managing‑agent employment, aiming to reduce industry capture. Funding mechanics are left to statutory instruments but must include a levy, define “smaller agents” and provide transitional public funding until levy regulations take effect.
Licensing framework and licence lifecycle
These sections compel the regulator to run an application scheme, set entry criteria (fit and proper, required qualifications, and understanding of the Code) and issue three‑year licences. The Secretary of State makes regulations on application timeframes and renewals; licences lapse on disciplinary termination, non‑renewal or loss of threshold criteria. The text allows limited exceptions (e.g., Right to Manage companies) to be set by regulations, so the final scope will depend heavily on secondary legislation.
Statutory Code of Practice with principles and guidance
The Secretary of State issues the Code, agreed with IRMA, setting high‑level principles (ethics, money protection, recordkeeping, staff competence, fairness, conflicts, complaints and data protection). IRMA must publish guidance designed to be practical and review the Code every five years with stakeholder consultation. The Code is principles‑based, which gives IRMA discretion in enforcement but raises questions about measurable standards.
Supervision, enforcement and appeals
The bill requires IRMA to supervise compliance and keep a published performance database. Regulations will specify monitoring powers. Enforcement is stepwise: notice and opportunity to remedy, then fixed penalties, suspension or termination. The rules require the regulator to publish enforcement guidance and provide complaint routes; there is an express role for Trading Standards coordination. Disputes about enforcement are routed to the First‑tier Tribunal, which may entertain judicial-review style considerations.
Regulatory architecture, instruments and territorial scope
This final part sets out the parliamentary procedures for the many regulations the bill requires (affirmative procedure applies to core elements such as governance, licensing, the Code, supervision and enforcement). The Act extends to England and Wales but the regulatory powers and licensable activities focus on properties in England — that mismatch will need resolving in guidance or regulations. It also grants the Secretary of State the power to make consequential amendments by regulation subject to affirmative procedure.
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Explore Housing in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Leaseholders and commonhold residents — gain a statutory regulator, a published complaints route, and the prospect of binding standards and clearer redress when agents mismanage funds or fail basic safety duties.
- Professional or accredited managing agents — benefit from higher barriers to entry that can raise sector standards and reduce unfair competition from low‑quality operators, and from clearer, nationally consistent expectations for training and practice.
- Training and qualification providers — see new demand because IRMA must specify qualifications, publish syllabuses and favour modular delivery, creating a market for accredited courses and assessment.
- Mortgage lenders and property investors — gain better transparency on how buildings are managed through a regulator’s public register and performance database, which can reduce operational risk and support portfolio underwriting.
Who Bears the Cost
- Managing agents (all sizes) — face licensing fees, costs to meet qualification and recordkeeping requirements, and additional compliance activity; smaller agents will be particularly squeezed despite protections in the bill.
- Landlords and ultimately residents — agents are likely to pass compliance and licensing costs down through higher management fees or service charges.
- The Secretary of State and HM Government — bear upfront establishment costs and must resource secondary legislation and ongoing oversight until the levy is in place; public funding covers the initial establishment period.
- Local Trading Standards and consumer bodies — may need to coordinate with IRMA and handle transitional complaint flows, creating resource and interface costs while roles and responsibilities are clarified.
Key Issues
The Core Tension
The central dilemma is between raising professional standards and protecting residents (through licensing, qualifications and a statutory code) and imposing costs and operational complexity that can reduce competition, raise service charges, and push small specialist agents out of the market; the same regulatory tools that protect consumers also concentrate compliance burdens that may be passed onto the very people the bill aims to defend.
The bill is heavy on institutional design and principles but light on several operational details that will determine its practical impact. Key elements — the levy design and thresholds for ‘smaller agents’, the exact list of licensable activities, the syllabuses for qualifications and the supervisory metrics — are all left to secondary legislation or IRMA rules.
That means the policy effect will turn on implementation choices about fees, competency levels and how prescriptive the regulator will be.
Several drafting choices invite practical difficulties. The funding clause requires that monies raised by the levy “are provided to the non‑executive directors of the IRMA,” an unusual formulation that raises governance and public‑accountability questions about how levy income is controlled and audited.
The Code is principles‑based, which gives the regulator discretion but makes enforcement outcomes harder to predict and could invite litigation over interpretation. The interplay between Trading Standards powers, consumer law and IRMA disciplinary action is also under‑specified: overlap and duplication are likely unless the regulations set clear boundaries and enforcement protocols.
Accessibility and proportionality are also unresolved. The bill requires that qualifications be accessible and modular, but it gives no detail on cost caps, recognition of prior learning, or transitional exemptions for small or specialist operators.
Finally, the territorial wording is awkward: the Act extends to England and Wales, but many of the regulatory duties explicitly reference properties in England, which will require careful drafting in secondary legislation to avoid scope disputes.
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