Leasehold reform: Dates in the diary, changes on the ground

As we first mentioned in What changes will the Leasehold and Freehold Reform Act 2024 introduce to residential service charges?, preparing for leasehold reform means more than diarising commencement dates. For residential landlords and managing agents in England, the practical challenge is to adapt charging, information and dispute management processes across existing portfolios. While many of the reforms are procedural, they will increase the administrative burden and the scope for error. The changes to litigation costs, however, are likely to be of particular concern to landlord clients. The changes to insurance arrangements also warrant particular attention.

The Leasehold and Freehold Reform Act 2024 (Commencement No. 4 and Saving Provision) (England) Regulations 2026 made on 25^th October 2026 phase in most of Part 4 of the Leasehold and Freehold Reform Act 2024 (LAFRA). The Regulations establish when the reforms will take effect and set out further provisions determining compliance.

Key dates at a glance

• 6 November 2026: From this date the Government is able to make detailed regulations on prescribed forms, required information and timescales however no new obligations are imposed on landlords at this stage.
• 1 April 2027: Fixed service charges enter the statutory service charge definition (which currently only extends to variable charges), a new prescribed future demand notice replaces the existing s20B notice, and new rights to information and enforcement provisions take effect. The litigation costs regime also changes.
• 1 November 2027: Prescribed service charge demands and new requirements for accounts and annual reports introduced. Insurance commissions and other “excluded insurance costs” will no longer be recoverable through service charges. Landlords will also have to provide leaseholders with insurance information and publish schedules of administration charges.
• 1 November 2028: Demands, accounts, annual reporting and related enforcement requirements extend to specified social landlords.

What do these changes mean in practice?

Charging and information

The reforms will require landlords and managing agents to adopt more standardised and transparent service charge processes, with greater emphasis on providing leaseholders with clear and timely information. This is likely to mean reviewing existing systems, templates and procedures, ensuring that the necessary information can be readily extracted and provided, and maintaining better records to support service charge expenditure. The increased transparency is also likely to lead to greater leaseholder scrutiny, making accuracy, consistency and good record keeping more important than ever.

Dispute costs

In practice, landlords will carry greater financial risk when disputes arise, as they will no longer be able to assume that litigation costs can be passed through the service charge. Tenants may also have the ability to seek an order requiring the landlord to pay their costs. This makes early assessment of the merits, proportionality and likely costs of a dispute more important, alongside careful control of legal spend and clear record keeping. Managing agents will need to identify potential disputes early and be cautious about budgeting on the basis that litigation costs will ultimately be recoverable, while landlords may need to factor potentially irrecoverable legal costs into their wider asset management strategy.

Insurance

Landlords and managing agents will need to move away from commission-based insurance arrangements and towards a more transparent model in which any charge for arranging or managing insurance can be clearly identified and justified. Existing insurance and broker arrangements should be reviewed before the new regime takes effect, including who receives commission or other benefits and how these are ultimately funded. The reforms are also likely to increase leaseholder scrutiny of insurance costs, making transparency, record keeping and the ability to demonstrate the value of any insurance-related services increasingly important.

How we can help

The real estate team advises on all aspects of leasehold and property law.  If you would like further guidance on statutory reforms or any other aspect of this complex area of law, please get in touch.