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Compliance & Regulation 6 min read

Managing agent regulation in 2026: what the Committee, the Act and the RICS Code now require of the scheme record

Between March and July 2026 the standard a residential scheme record has to meet was raised on several fronts, from the RICS Code to the government response on the Leasehold and Freehold Reform Act 2024. From 2027, the record is what leaseholders and any regulator will test.

Between 17 March and 15 July 2026 the standard a residential scheme record has to meet was raised on several fronts. RICS published the fourth edition of its Service Charge Residential Management Code. The Housing, Communities and Local Government Committee recommended that an independent regulator for property managing agents, with enforcement powers, be established within the Commonhold and Leasehold Reform Bill. The government published its response on leaseholder protections under the Leasehold and Freehold Reform Act 2024, with statutory instruments to follow later this year. Leaseholders see the changes from 2027. Each measure tests something different. All of them are answered by the same thing: whether the scheme record can produce what is asked of it.

What happened

On 17 March 2026 RICS published the fourth edition of the Service Charge Residential Management Code. It has applied since 7 April 2026 to landlords, managing agents, resident management companies and right to manage companies, and it is the edition now in force for any scheme under management.

The draft Commonhold and Leasehold Reform Bill was published on 27 January 2026. On 27 May 2026 the Housing, Communities and Local Government Committee published its pre-legislative scrutiny report and recommended that an independent regulator for property managing agents, with enforcement powers, be established within the Bill. The recommendation returns to ground covered by Lord Best's 2019 Regulation of Property Agents report, which proposed an independent regulator able to fine agents and revoke licences. The King's Speech 2026 committed the Bill to the 2026-27 parliamentary session.

On 15 July 2026 Matthew Pennycook MP, Minister for Housing and Planning, published the government response to the consultation on strengthening leaseholder protections over charges and services under the Leasehold and Freehold Reform Act 2024. At least five statutory instruments are to be laid later in 2026. Leaseholders see the changes from 2027, with 12 months' notice for private landlords and 24 months for social landlords. Two measures bear directly on the scheme record. Landlords must provide leaseholders with an annual report on the building's health, condition and planned major works. Building information, including fire safety information and invoices, must be supplied on request within set timeframes, going back up to six years. A separate response on mandatory qualifications for managing agents, consulted on between 4 July and 25 September 2025, is still to come.

Two further dates sit alongside these. The Property Institute reviewed its F07 Management Handovers guidance on 3 June 2026: members must deal with any handover in a "professional, competent and efficient manner" with agreed timescales. The Social Tenant Access to Information Requirements commence in October 2026.

Why it matters for managing agents and housing providers

None of these measures asks how diligent the agent was. Each asks what the record can produce. A leaseholder who requests the fire strategy in 2028, for a building whose management changed hands in 2025, is entitled to it within the set timeframe. The answer comes from the record, not from the recollection of whoever was managing the scheme at the time.

The six-year look-back is the detail that changes the onboarding calculation. Six years is longer than many management appointments. The look-back therefore spans changes of agent, and the incoming agent inherits the job of answering for invoices and safety documents it did not collect. Whatever it received at handover is what it will answer from. A pack accepted with gaps in 2026 is a request that cannot be answered in 2029.

The annual report has a similar effect. A report on the building's health, condition and planned major works has to draw on the O&M manuals, the test certificates, the warranties and the maintenance history. Where those documents were never mapped to the building they describe, the report is compiled from whatever can be found in the time available, and the agent signs off a picture of the asset it cannot fully evidence.

The Committee's recommendation raises the stakes on handover conduct itself. The Property Institute's Changing Managing Agents advice note already sets the professional expectation: all relevant information reaches the landlord within four weeks of the handover date, including as a minimum leaseholder contact details and information about contractors and insurance, and reconciled accounts with schedules of arrears, creditors and debtors follow within three months. The note states that documents relating to the affairs of a landlord, RMC or RTM are not the property of the agent, and that managing agents have no general right of lien over client documents. A regulator with enforcement powers would be able to test those expectations against what actually happened on a given transfer.

Moving leaseholders between agents is among the sector's most persistent complaints, and the four-week expectation is where it is felt. An outgoing agent can hand a scheme on inside four weeks only if the record was assembled when the scheme arrived. Reconstructing a pack at the point of exit, from email threads and a former client's data room, is where the four weeks go. Offboarding is the same transfer as onboarding with the parties reversed, and the record that was accepted on the way in is the record that leaves on the way out.

An incomplete pack at onboarding becomes an unanswerable request two years later. The regulation arriving in 2027 does not ask who caused the gap.

What to watch

The obligations arrive in sequence. Each date below is as published by the source linked at the end of this article.

  • October 2026: the Social Tenant Access to Information Requirements commence.
  • Later in 2026: at least five statutory instruments laid under the Leasehold and Freehold Reform Act 2024. Read them for the set timeframes on information requests and the content of the annual report.
  • 2026-27 session: the Commonhold and Leasehold Reform Bill introduced to Parliament, as committed in the King's Speech. Watch whether the Committee's recommendation for an independent regulator with enforcement powers appears in the Bill as introduced.
  • Pending: the government response on mandatory qualifications for managing agents, consulted on between 4 July and 25 September 2025.
  • 2027: leaseholders begin to see the changes. The response provides 12 months' notice for private landlords and 24 months for social landlords.

The RICS Code, fourth edition, and the TPI F07 guidance are already in force. Nothing in the list above is waiting on them.

How Guided Home helps

When the annual report and the six-year information request both read from the same scheme record, and a regulator may soon read from it too, the quality of that record is fixed at the moment the scheme arrives. That is the moment Guided Mobilise is built for. It runs in Deal Room, and it makes your onboarding checklist the template for every transfer: workstreams, milestones, tasks and named owners, a live view of what is on track, at risk, overdue or done, and a board-ready PDF for every stakeholder update. External partners join by secure link, so the developer or outgoing agent uploads into your structure from the first day.

The pack itself moves through the document modules in order. Document Sourcing requests and chases every item on the checklist through structured workflows, so nothing depends on an inbox. Document Intelligence classifies each document as it arrives and maps it to deal, site, building and plot, which is what turns a raw filestore into a record that can answer a request for the fire strategy of a specific block. Document Assurance then checks every document against your acceptance and compliance rules. Gaps and non-compliant items surface before the scheme is accepted, with a named owner against each one.

For the directors accountable for the portfolio, the Executive Dashboard shows mobilisation progress and handover risk across every live scheme, including document completeness for each. For the team answering questions day to day, Hugo answers from the scheme record itself, with the source alongside. "Do we have the fire strategy?" is the question a leaseholder will be entitled to ask from 2027. It is worth being able to answer it now.

Offboarding is a deal type on the same template. The incoming agent's checklist becomes an added workstream, and anything that happened outside the platform is added to complete the picture. The transfer is evidenced item by item against the four-week expectation, and the record that onboarded the scheme is the record handed on. If you are taking on or handing back a scheme this year, bring one to us and we will configure your checklist as the template.

Sources

See how Guided Home supports this in practice.

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