Renters’ Rights Bill Debate
Full Debate: Read Full DebateBaroness Scott of Bybrook
Main Page: Baroness Scott of Bybrook (Conservative - Life peer)Department Debates - View all Baroness Scott of Bybrook's debates with the Ministry of Housing, Communities and Local Government
(2 days ago)
Lords ChamberMy Lords, fines must be proportionate, yet, as the Bill stands, the threshold for imposing fines on landlords is worryingly low, and the scale of those fines is notably high. This combination is troubling. Setting fines at such significant levels, in some cases representing a substantial portion of a landlord’s rental income, or even exceeding it, risks driving honest, well-meaning landlords out of the market, not because of any wilful negligence but out of fear.
I thank my noble and learned friend Lord Keen of Elie for leading this group from the Back Benches today and bringing two considered amendments to the attention of the House. The group continues the discussions we had in Committee, as we remain unclear on how the scale of the fines has been determined. Frankly, they appear to be arbitrary, with no transparent methodology or rationale behind them, and we would welcome clarification from the Minister on how these amounts were determined and why those particular values were chosen. Without a clear explanation, it is difficult to support their inclusion in the Bill.
Amendments 98 and 99 seek to clarify that fines should be issued only for persistent breaches. Including this in the Bill would provide much-needed reassurance. It would make it clear that significant penalties will not be levied for the first offence. That is especially important when many landlords may not be immediately aware of their new obligations, either those set out in the legislation or those introduced later through regulations. Imagine a landlord renting out a cottage for many years in their village in rural Wales. They are entirely unaware of this Bill and the proceedings of this House. They do not register on any new database, not out of malice but because they simply do not know what is required. Is it right that they should face a steep fine for this? Surely not. That is why “persistently” must be in the Bill—to protect landlords like them and ensure that the legislation is proportionate, fair and enforceable.
Ministers may say that, in practice, individuals such as in the example I have given will not be fined, and that discretion will be used and enforcement will be reasonable, but warm assurances are not enough. We need to ensure that this protection is guaranteed in law, not simply assumed in guidance or left to future interpretation. We need this clarity in the Bill, and without it, the risk remains that well-intentioned landlords—those who may simply be unaware of new requirements—could still find themselves facing disproportionate penalties.
If the Minister cannot accept the premise that we must embed this protection clearly within the legislation, I regret to say that we will be minded to test the opinion of the House.
My Lords, the noble Baroness was so quick to leap up—
Noble Lords will realise by now that I am a bit messianic about the database. I listened very carefully to what the Minister said at the end of Committee about the database, which is that much of it will be given to us in guidance and by statutory instrument. I look forward to the opportunity to contribute to that, but the reason for continuing to press this case is to put on the record just how important this is as a plank of this Bill—and how transformative it could be. So I will speak to my Amendments 94, 95 and 96 and speak against Amendment 97.
The private rented sector database presents a major opportunity to drive up standards through empowering tenants to make informed decisions before entering into a new tenancy, while giving local authorities the information they need to proactively enforce the new regulations. Those are two really important prongs.
The database will only be as useful as the information it stores. My amendments seek to ensure that it is as useful as possible. It is probably my shopping list of things that I would like to see, but I am sure that interested bodies and people other than myself will be putting into that further guidance and further information.
Renters will not be reading it in bed at night, or on holiday; they will look for it when searching for a new home. If it has useful information that helps them make informed choices—such as, past enforcement actions taken against the landlord in question, accessibility features of the home or rent levels for similar properties in the area—they will be able to choose a home that is right for them. For example, a recent Generation Rent survey found that more than three-quarters of renters would support including any prior prosecutions of a landlord on the database, as per my Amendment 94. Having this information will help foster more of the long, stable tenancies that both renters and landlords alike want, while discouraging landlords from attempting to sidestep the Bill or exploit tenants. Furthermore, renters who have used the database will tell their family and friends about it. In my experience, this kind of word-of-mouth marketing is the most effective.
My Amendment 96 would ensure that actual rents are recorded on the database. The Government have put much trust in the First-tier Tribunal, protecting renters from unaffordable rent hikes. At the moment, however, the tribunal uses advertised rents to see whether a rent increase is fair. Often, these are inflated and could become even more so with the end of bidding wars. So, recording actual rents will allow the tribunal and tenants to have a better understanding of the local market.
The issue of local authority finances has been debated many times as the Bill has progressed. We are right to be concerned about their capacity to proactively enforce the Bill. Having key information in one place, such as Section 8 eviction notices, as per my Amendment 95, would be a massive help to enforcement when the Bill comes into action—cutting out much of the proactive fact-finding work that local authorities often lack the capacity to do.
Outside the renting process, the database could also be of use to both national and local policy-making. Recording rents, for example, would help inform national decisions on housebuilding and crack down on landlords’ tax avoidance, which the think tank TaxWatch estimates to be as high as £1.7 billion a year.
We oppose Amendment 97, to limit costs related to the database, given that some areas of the Act inevitably may turn out to need more enforcement than others. It makes sense for the Government to have some wriggle room to set some costs at a later date. The legislation’s success relies heavily on enforcement, and therefore having the ability to raise funds through the database feed written into primary legislation is an important mechanism in case it is needed in future to cover costs, such as an awareness campaign or guidance and training to tenants and landlords.
Finally, I will end on a positive note. Much of this debate often pits landlords against renters, seeing the issue like a see-saw. But findings from Generation Rent’s survey of its supporters in April this year found that the more information about a landlord that renters have, the better their relationship with them. Nearly a quarter of renters who had a direct contact line to their landlord rated them five out of five, compared with fewer than one in 10 of those who did not. With the right information, the database will help foster more of these relationships. I beg to move.
My Lords, I thank the noble Baroness, Lady Thornhill, for her expansive and constructive thinking on what more the database could do to support a rental market that works fairly and effectively for both landlords and tenants alike. During Committee, we had a thoughtful and wide-ranging discussion about the purpose, function and future potential of this database, and many noble Lords suggested that it could, and perhaps should, do more. I agree: in time, that may well be prudent. But, from my experience as a Minister, I have learned the value of taking one step at a time. Let us focus first on getting this system up and running and getting it right.
I am very much reminded of the Second Reading of the pensions Bill in the other place. When the Minister, Torsten Bell, began to explain its provisions, he was met with laughter from both sides of the House. The joke was all in very good faith and the Minister joined in at the moment, but it speaks to a deeper truth. We cannot allow this database to become the next pensions dashboard—a project weighed down by scope creep and plagued by delay. So, although I welcome the noble Baroness’s ambitious vision and her efforts to think beyond the immediate text of the Bill, we must begin with the basics, especially if additional functionality comes at the cost of higher system complexity and, crucially, higher financial burdens on those who provide rental homes to millions across this country.
That brings me to Amendment 97, which concerns limited relevant costs. This cannot become a system that imposes unlimited and never-ending costs on landlords. They need certainty—clear and reliable reassurance from the Government—that relevant costs will not spiral every time a new Minister has a bright idea.
It is that word again—balance—and I know that noble Lords are probably sick of hearing it by now, but it remains the guiding principle. We must strike the right balance between the cost of this system and the functions that it is expected to perform. Only then can we ensure that the database succeeds, not just in theory but in practice, for those who depend on it. Despite this, I will not seek to test the opinion of the House on Amendment 97.
My Lords, I thank the noble Baronesses, Lady Thornhill and Lady Scott, for their amendments concerning the database. I thank the noble Baroness, Lady Thornhill, for all the thought and work she has put in and the assistance she has given us to aid our thinking around what may or may not be in the database. I appreciate that the intention behind Amendment 94 is to empower tenants with more information and to support their decision-making before they decide to rent a property. As the noble Baroness helpfully outlined in Committee, that forms part of a broader and more ambitious vision for the database. We need to ensure that the database is helpful to both landlords and tenants.
I hope that the noble Baroness is pleased that Clause 84 mandates that we will indeed record banning orders on the database. This clause specifies that we will record relevant banning order offences and related financial penalties on the database. We intend to make this offence information available to the public, using the regulations set out in Clause 87. Furthermore, the Bill includes the regulation-making power at Clause 84(6) for the database to record other housing-related offences committed by landlords. We will specify which offences will be recorded through secondary legislation, but I hope the noble Baroness is encouraged to hear that rent repayment orders are among those we are actively considering for inclusion.
Our approach to recording offences will consider the necessity and proportionality of recording this information, alongside making sure, of course, that it complies with data protection and human rights legislation. We need to give that careful consideration as well. As we discussed in Committee, we intend to retain flexibility regarding the information the database records and makes public, so that it can evolve in response to the changing needs of the sector, including those of tenants and landlords—enough information to be helpful but not so much that only Torsten Bell can understand what is on it.
Amendment 95 seeks to record historical Section 8 notices on the database to enhance tenant awareness and promote responsible landlord practices. I recognise that this would be a positive addition to improve the database and help it be a driver of higher standards and tenant protection, built on comprehensive and reliable foundations, so I thank the noble Baroness for the thoughtful amendment. The Government are currently considering recording possession information on the database and whether that information should be made available to the public. Any decision on what information will be recorded on the database has to take into account both the benefits and the burdens for different users, and we will ensure that the information collected remains necessary and proportionate.
As the noble Baroness will be aware from our previous conversations about what information the database will record, we place significant importance on the flexibility of the database for future circumstances. We therefore believe that the information collected on the database should be set out in secondary legislation, as stated in Clause 78.
Amendment 96 aims to make the commencement of rent and historical rent increase information visible on the database, to improve transparency for prospective tenants and support informed decisions in the private rented market. The Government are still considering whether to collect rent data on the database. However, we recognise the potential value the information could provide to tenants, by allowing a more informed rental experience. We are also aware that other government departments and bodies, such as HMRC and the NAO, may find this data useful. We believe, however, that for the database to remain flexible, the information it collects should be specified through regulations.
Amendment 97 would restrict the calculation of PRS database fees to be set with reference to costs associated with the operation and enforcement of the database only, not by reference to the costs of wider PRS enforcement activity. I appreciate the need to keep the fee at a manageable level and to justify any new costs to landlords. However, I draw the noble Baroness’s attention to what we have heard in previous debates regarding the challenges that local authorities face in resourcing their enforcement actions.
We believe it is appropriate that, as far as possible, costs of enforcement should be met by those individuals who break the rules. However, a well-regulated and well-enforced PRS benefits all good landlords, as well as tenants, and clearly local authorities must be properly resourced to achieve this. This clause provides Ministers with the option of using a proportion of fee income to provide revenue to fund private rented sector enforcement activities beyond those relating to the database.
As I have set out previously, database fees will be determined and fixed at a later point, via secondary legislation. I assure noble Lords that fee calculations will be reasonable and will bear in mind the cost to landlords, among other factors. Given what we have heard about the importance of local authority resourcing, I do not think it would be prudent to limit the calculation and use of database fees in this way.
I thank the noble Baroness for saying that she will not press her amendment, and ask the noble Baroness, Lady Thornhill, to withdraw her amendment.
My Lords, I have no confidence in the response I had from the Minister on my Amendment 98 that landlords would be protected in law against unfair fines. I therefore wish to test the opinion of the House.
My Lords, in moving Amendment 107, I will also speak to Amendment 108. These amendments would remove unnecessary barriers to the use of licensing schemes to improve housing standards. Licensing raises housing standards: it can help to regenerate areas that are blighted by poor housing and other social problems. Licensing provides a means for local authorities to inspect privately rented housing using enforceable conditions, and to identify and resolve problems without the need for tenants to have complained.
Licensing schemes pay for themselves through the fees that are charged and enable local authorities to target regulation where it is most needed: in other words, at tackling the worst landlords and supporting the most vulnerable tenants. My amendments would remove unnecessary barriers to the effectiveness of licensing schemes and increase the maximum duration of schemes from five years to 10 years.
Amendment 107 would permit local authorities operating selective licensing schemes to use licence conditions to improve the physical state of the licensed properties. It would remove a peculiar disconnect in current legislation, highlighted by the Chartered Institute of Environmental Health, whereby local authorities are permitted to introduce selective licensing schemes to address poor housing but are not permitted to include in the licences themselves conditions requiring the physical state of the licensed properties to be improved. The amendment would give local authorities the same discretion in relation to the licence conditions used in selective licensing schemes as they already have in relation to licence conditions used in additional HMO licensing schemes.
In Committee, the Government implied that the introduction of a decent homes standard and Awaab’s law to the private rented sector will make this amendment unnecessary. However, I do not accept that view. Neither the decent homes standard nor Awaab’s law will remove the need for local authorities to be able to use licence conditions to deal proactively with general disrepair in areas with poor housing conditions.
There are four reasons why the decent homes standard will not remove the need for local authorities to be able to use licence conditions in this way. First, when licence conditions are in place, if a breach of these conditions is proved, local authorities can serve a civil penalty notice on the landlord without first having to issue an improvement notice and/or take other action that involves unnecessary delay. However, they will be able to do this for breaches of the proposed decent homes standard only in more serious cases—possibly only where there is a serious and immediate risk to a person’s health and safety—and only where they can prove that the landlord has failed to take reasonably practicable steps to address the issue. Licence conditions would therefore give landlords a much stronger incentive than the decent homes standard to address general disrepair.
Secondly, the enforcement of licence conditions can be funded by licence fees. The cost of enforcing the decent homes standard will fall on council tax payers. In practice, therefore, the use of licence conditions would lead to local authorities undertaking a much higher level of enforcement.
Thirdly, licence conditions give local authorities a clear justification as well as sufficient funding for entering properties to carry out inspections without the tenant having complained. It seems likely that, outside of licensing schemes, the vast majority of inspections under the decent homes standard will be in response to complaints. Fourthly, licence conditions could deal with items of disrepair that would be difficult to address using the decent homes standard.
With regard to Awaab’s law, it will not remove the need for local authorities to be able to use licence conditions to deal proactively with general disrepair in areas with poor housing conditions. The enforcement of Awaab’s law will depend on the ability and willingness of tenants themselves to seek redress and ultimately to take legal action through the courts. It is often difficult for tenants to use legal remedies themselves; areas with poor housing conditions contain many poor and vulnerable tenants, who are particularly badly placed to do so. Licensing would clearly be a much better way of targeting support at them.
Amendment 108 would permit local authorities to implement longer additional HMO licensing schemes and selective licensing schemes without repeating the time-consuming and expensive designation process. Local authorities introduced these schemes to bring about large-scale improvements, but those are unlikely to be fully achieved within five years. This amendment would allow them to advertise longer-term posts for staff and to include training of new staff in these schemes. It would also provide more time for local partnerships formed through such schemes—for example, to resolve anti-social behaviour—to become embedded and effective.
The Government suggested in Committee that a maximum duration for licensing schemes of five years strikes the right balance between the needs of local authorities and the needs of landlords. But that does not take proper account of the time and money wasted through councils being unnecessarily required to repeat the designation process.
In conclusion, the removal of these unnecessary barriers to the effectiveness of licensing schemes would make a major contribution to the regeneration of some of the most deprived areas of the country. A new general approval to establish selective licensing areas came into effect last December, and local authorities are no longer required to obtain confirmation from the Secretary of State before implementing a selective licensing scheme of any size. That is most welcome, but it needs to be accompanied with the powers identified in my amendments, and I hope the Government will now understand the importance of them. I beg to move.
My Lords, I thank the noble Lord, Lord Shipley, for bringing these two amendments once again to the attention of the House. However, we on these Benches do not consider them to be necessary. We recognise and wholeheartedly share the noble Lord’s ambition to see housing conditions improved. When I was in government, I was proud to support the decent homes standard and helped to lay the groundwork for what has now become Awaab’s law. The Government’s approach should be focused on delivering tangible improvements to living conditions. This includes tackling poor-quality housing wherever it exists, not slowly within selective licensing areas.
My Lords, I hesitate to follow when Sodom and Gomorrah have both been mentioned. However, the noble Baroness, Lady Thornhill, has made a powerful case for her amendment, and I associate myself with everything she has said and with the passionate defence of this amendment by my noble friend Lady Lister of Burtersett.
As has been said, the amendment seeks to repeal the right-to-rent provisions introduced by the Immigration Act 2014. I remember being a newbie here in 2014 and sitting on the Benches opposite, hearing those speeches against the clauses and provisions in the Immigration Act that we now seek to repeal. At its core, as we know, this scheme turns landlords and letting agents into immigration officers. It was part of the hostile environment created at that time, and I am sad to say to the Minister on the Front Bench that this is a continuation of that hostile environment. There is no excuse for this provision. It is a policy that has enabled and indeed legitimised discrimination, and I believe that it has no place in a housing system that should be fair and should treat everyone equally and with dignity.
Landlords and letting agents are making judgments based on what they think will fall within protecting themselves. They are immigration officers. It has been shown—I thank Shelter for its briefing—that a prospective white tenant is 36% more likely to get a positive response than a black tenant. Renters with south Asian names get 25% fewer replies than those with white-sounding names—evidence of the consequences of this pernicious piece of legislation.
The courts recognised this reality. In 2019, the High Court found that the policy causes discrimination. That ruling was later overturned on appeal, not because the discrimination was not happening but because it was deemed justifiable. That, I believe, is not acceptable. I could go on, but the noble Baroness, Lady Thornhill, has pointed out that the Home Office has never produced evidence on which we should legislate that the scheme reduces irregular immigration or improves enforcement.
Discrimination, particularly when sanctioned by the state, is never justifiable. There are many reasons to accept this amendment, but I urge the Front Bench to accept the decent, just and fair case. I see the realities of the discrimination in the housing sector in my own borough, the London Borough of Tower Hamlets. Now is the time to do the decent thing. I urge the Government to listen, reply and do the decent thing and repeal the right-to-rent provisions introduced by the Immigration Act 2014.
My Lords, I will be brief. On these Benches, we find the argument for full repeal unconvincing. The right-to-rent scheme was designed to serve a clear and important public interest, ensuring that access to the private rented sector is not used as a back door to unlawful residence in the United Kingdom. That principle remains relevant. The Bill is not the right vehicle to reopen immigration law. Any reform of the right-to-rent scheme must be considered in the round and as part of a wider conversation about enforcement, fairness and social cohesion in our immigration system. For those reasons, we cannot, and I will not, support this amendment.
My Lords, I thank the noble Baroness, Lady Thornhill, for Amendment 115, which would abolish the right-to-rent scheme that applies in England. I thank the noble Baronesses, Lady Lister and Lady Scott, the noble Lord, Lord Cashman, and the right reverend Prelate the Bishop of Manchester for their contributions.
The scheme was introduced to ensure that only those lawfully in the United Kingdom can access the private rented sector and, importantly, to tackle unscrupulous landlords who exploit vulnerable migrants, sometimes in very poor living conditions. Some landlords who rent to those who are here illegally are criminal operators. We all have a shared objective to drive them from the rental market and to deter unscrupulous landlords from entering into exploitative practices.
We have always been absolutely clear that discriminatory treatment on the part of anyone carrying out right-to-rent checks is unlawful. The checks apply equally to everyone seeking private rental accommodation, including British citizens. The scheme has been independently evaluated twice. Although some examples of discriminatory attitudes were found, there was insufficient evidence to claim that there was any systematic, unlawful discrimination as a result of the right-to-rent scheme. There are therefore no current plans to end the scheme.
It is our view that it is wrong to seek to abolish right-to-rent legislation in its entirety by simple notice of amendment. This immigration legislation was designed to address those who are disqualified from living in the UK by virtue of their immigration status, and that remains an important priority for this Government. The Government will continue to support legitimate landlords and letting agents who continue to act properly by carrying out the prescribed checks in legislation and published guidance. We have made big strides to improve the digital capability of the systems involved.
I emphasise that the Home Office has listened to and taken on board concerns expressed about right to rent during the progress of the Renters’ Rights Bill and from wider stakeholder engagement. As a result, officials will actively engage further with tenants and their representative groups to ensure that the right-to-rent scheme works fairly and inclusively for all. Early engagement has helped the Home Office identify individuals who may struggle to prove their identity and, in consequence, face barriers to accessing housing and other services. The Home Office has begun to work with local authorities to understand how individuals can overcome these barriers, with the aim of extending successful approaches across the UK.
As we move forward, we remain committed to working with stakeholders, including community-based initiatives and the third sector, to strengthen the inclusivity and accessibility of the right-to-rent scheme. I thank the noble Baroness, Lady Thornhill, for her interest in the scheme and would be happy to facilitate a meeting with the appropriate Home Office officials to discuss how to ensure that the scheme can operate inclusively and fairly for all tenants, landlords and letting agents. In the light of these reassurances, I ask that the noble Baroness, Lady Thornhill, withdraws the amendment.
My Lords, this amendment was spoken to earlier on Report. In our view, it is a very important amendment because it asks that there be an annual report on the Bill laid before Parliament. The reason for this is that we are beginning to see problems within this sector; we would want to see published the availability of homes, the rents charged as a result of a lack of available homes, house prices in and around the same sector, and, very importantly, requests for social housing, because as the rented sector starts to cool down, the social housing sector hots up.
We think that the Government should accept this type of annual report so that if anything goes badly wrong in this sector, something can be done about it very quickly. The Government are offering some sort of review with figures that will come out, but that is not what is wanted by this side of the House. We want an annual report—not a review—to be laid before Parliament so that it can be debated properly and, if needed, amendments can be proposed to change things and bring the sector back up to what it is at the moment. I know it is late, but I intend to test the opinion of the House on what we consider a very important amendment.
I am hoping that some of the larger players will have ones that are off the shelf for the noble Lord to use. I am sure the Minister will be able to help out with that. Basically, we do not want to delay things any more. We genuinely believe that the trailing of the key planks of the Bill has been so public and so out there. But I say to the Minister that some definite timescales would be helpful.
My Lords, we think that the amendment from the noble Lord, Lord Carrington, is sensible and measured. The amendment provides for a minimum of three months’ notice before new tenancies are treated as Section 4A assured tenancies and a further three months before existing tenancies are reclassified in the same way. This introduces a clear and reasonable transitional period, giving landlords and tenants time to prepare for the significant legal and practical implications of these changes.
Crucially, it gives banks time too. As the noble Lord, Lord Carrington, noted, Amendment 122 is supported by UK Finance, including lenders such as Nationwide and Paragon. Banks need time to adjust. Any change to how a landlord can evict a tenant makes lenders more cautious about the security of their investments. These lenders will want to have seen it in writing before they start to make too many changes.
Additionally, lenders will need to reassess their understanding of rental income flows. Lenders will have to adjust their risk models, and potentially their loan terms, to accommodate the risks under the new regime, not only in relation to individual properties but with regard to the broader market stability. It is vital to understand how the regime affects overall demand in the rental market.
I take this opportunity to raise the specifics of buy-to-let mortgages. Flexibility in increasing rents in these cases is especially important and an area where sufficient time for adjustment will be needed. Lenders must evaluate the continued attractiveness of buy-to-let properties as collateral for loans.
Operational readiness matters too. Quite simply, new systems and processes will need to be adapted to the framework. Earlier today, we discussed systems such as the database and the pensions dashboard. Of course, many private companies are often more agile when responding to challenge and change, but even they need time.
This is a complex Bill, and I have said several times that its implementation will require careful communication and a phased approach. I see this amendment as a practical way of helping the Government ensure that no stakeholder is caught off guard by the shift to the assured tenancy regime.
I would welcome clarity from the Minister on the Government’s plans for commencement—so, I am sure, would landlords and tenants—and all stakeholders will need time.
My Lords, I thank the noble Lord, Lord Carrington, for his amendment and for his engagement generally on the Bill. Subsequent to our meeting earlier this week, I had a detailed response prepared for the noble Lord on Clause 145. Unfortunately, it arrived in my inbox just as I was coming into the Chamber this afternoon. It probably has not reached him yet, but that is on its way to him.
On Amendment 122, the Government are committed to introducing the new tenancy system for the private rented sector in one stage to bring to an end Section 21 no-fault evictions as soon as possible. These evictions cause utter misery for the tenants on the other end of them and a huge amount of cost to local government in picking up the pieces when people get evicted at very short notice. A single implementation date for both new and existing tenancies will enable all tenants to benefit from the reforms as soon as possible and prevent a confusing two-tier system during transition.
We are continuing to work very closely with stakeholders. The noble Lord, Lord Carrington, referred to meetings between my honourable friend the Minister for Housing and financial institutions. He has also met with many landlords’ associations and other stakeholders to ensure that the sector is prepared for the reforms in the Bill. I want to be very clear that we are committed to providing sufficient notice to ensure that all parts of the private rented sector have time to prepare. Implementation will not be immediate, as we have secondary legislation to pass. We are making good progress on drafting that and the necessary guidance that goes alongside it. All this will help us to implement in a timely manner.
In addition, the Bill makes specific provision to ensure a smooth transition to the new system and avoid unnecessary cliff edges. For example, the Bill will ensure that notices served by landlords before the commencement date remain valid after that date. Based on our ongoing work to ensure a smooth transition to the new system, we consider that there will be no benefit to requiring arbitrary minimum time periods after Royal Assent before the tenancy reform measures in the Bill can come into force.
With these reassurances that we are committed to a smooth and responsible approach to implementing the Bill, I respectfully ask the noble Lord, Lord Carrington, to withdraw his amendment.