Member representation: Consultation responses and position papers

The States Assembly in Jersey has unveiled proposals to reform the island’s residential tenancy law, which has been in place since 2011. Propertymark supports the intention to provide renters with greater protection and security, but we have serious concerns about the practicality and potential consequences of some of the proposals, including rent controls and restrictions on fixed term tenancies.

Ciara Ferguson, MLA, has proposed a Private Members’ Bill banning letting fees charged by landlords and agents in Northern Ireland. Propertymark has responded robustly to the proposals, calling for a fair and balanced approach that protects both tenants and the viability of property businesses. We met Ferguson on 13 May 2025, along with some of our members operating in Northern Ireland, to discuss her aims and to raise concerns from agents.

Proposals from the Department for Energy Security and Net Zero (DESNZ) to introduce higher Minimum Energy Efficiency Standards (MEES) for the private rented sector (PRS) raise serious concerns about the practicality, affordability, and likely impact on housing availability. In Propertymark’s response to consultation, informed by input from over 350 members from England and Wales, we insist the UK Government must work closely with the sector to design a fair and sustainable route to energy efficiency.

Propertymark’s response to the Ministry for Housing, Communities and Local Government (MHCLG) consultation on reforms to the Energy Performance of Buildings (EPB) regime addresses the wide-ranging proposals, covering changes to Energy Performance Certificates (EPCs), Display Energy Certificates (DECs), and Air Conditioning Inspection Reports (ACIRs). We welcome many of the proposed reforms but have also raised concerns, especially around commercial and heritage buildings and HMOs, and made recommendations to ensure the final policy is fair, practical, and effective.

The UK Government’s proposed disability and health-related benefits system reforms could significantly reshape support for vulnerable people. Propertymark responded to the Work and Pensions Committee’s inquiry on these plans and welcomed many proposals. We made it clear, however, that housing must be central to any efforts to ‘Get Britain Working’.

A major consultation for a new Land Use Framework aims to balance the need for 1.5 million new homes, expansion of energy infrastructure, and the creation of new towns, alongside the protection of the environment and the transition to a low-carbon economy. Propertymark supports a balanced approach to changes in land use, however, we believe the UK Government has significantly underestimated the land required for residential development.

Plans are afoot to strengthen HMRC (HM Revenue and Customs) to act quickly and robustly against professional tax advisers who help clients avoid paying the correct tax. Propertymark welcomes this because it aligns with our calls to the Treasury, and we support HMRC’s ambition to ensure the financial sector upholds the highest standards and integrity of the tax system.

Propertymark urges the UK Government to make access to housing a central part of its welfare system reform. Without suitable affordable housing options, it will be much harder to address other barriers to work, such as improving physical and mental health or engagement with education and training. Proposals in the Pathways to Work Green Paper will overhaul the existing system and introduce new initiatives, including unemployment insurance, to create sustainable health and disability benefits and employment support.

The UK Government has published proposals to reform planning committees in England as part of its broader planning reform agenda, setting out significant changes that could affect how planning decisions are made locally. Propertymark supports reform to improve the consistency and speed of decisions but warns that the current proposals may miss the mark, especially around delegation and local flexibility.

Propertymark has submitted a response to the House of Commons Public Bill Committee's call for evidence on the Bill, focusing on key areas that affect the property sector, particularly anti-social behaviour (ASB) and the protection of vulnerable tenants from exploitation such as cuckooing and county lines activity. Our key message is clear: no matter how strong the tools , they will only work if landlords and property agents are informed and engaged in the implementation.

The Digital Markets, Competition and Consumers Act (DMCC), which passed into law on 24 May 2024, contains provisions to prohibit unfair commercial practices, replacing and updating the Consumer Protection from Unfair Trading Regulations 2008 (the 2008 regulations). The legislation hands direct enforcement powers to the Competition and Markets Authority (CMA), giving them the authority to act on breaches of consumer protection rules, including requirements for providing material information.

The Scottish Government has launched a technical consultation on proposed changes to lodgement fees and penalty charges as part of its ongoing reform of Energy Performance Certificates (EPCs). This follows the publication of the Scottish Government’s response to a 2023 consultation on EPC reform and outlines plans to introduce new EPC regulations in 2025, with enforcement scheduled for 2026.