That:

a)     The Justice for Tenants (JFT) Housing Enforcement Policy be adopted;

b)     The JFT Civil Penalty Policy and matrix be adopted;

c)     The JFT standard HMO licence conditions be adopted as the Council’s standard conditions for HMO licensing; and

d)     Authority be given to enter into the JFT Group Services Contract, subject to legal review and agreement prior to execution.

The JFT policies have been selected because they are specifically designed to align with the new statutory enforcement duties and accompanying guidance under the Renters’ Rights Act 2025. Adoption of the policies does not require entry into a support contract. Any engagement with JFT support services contract would be subject to legal review and compliance with the Council’s Contract Procedure Rules.

1.         Adopt the JFT policies and licence conditions without entering into the JFT support contract.

This option would achieve formal legislative  compliance but would require all implementation, training, quality assurance and appeals preparation to be managed internally. This option is legally permissible; however, officers consider it would increase early stage delivery and legal risk. This would increase operational risk during the early stages of the new regime and place additional pressure on officer capacity. This option is not recommended.

2.         Undertake limited engagement with JFT (e.g. training or tools only) without adopting the full policy framework.

This option would result in misalignment between adopted policy, statutory duties and operational tools, increasing the risk of inconsistent enforcement outcomes and successful challenge. This option is not recommended.

3.         Retain the existing enforcement framework and make incremental changes once the Act is live.

This option would leave the Council operating under policies that do not adequately reflect the statutory duty to enforce and would expose the authority to increased legal, operational and reputational risk. This option is not recommended.