Member representation: Consultation responses and position papers

Propertymark has responded to proposals on how future changes to the Welsh Tax Acts should be made, recommending that the Welsh Government should adopt a Land Transaction Tax (LTT) system that promotes accessibility, simplicity, and predictability, while avoiding excessive surcharges or complex rules that could slow transactions.

We have responded to the Competition and Markets Authority (CMA) on its draft price transparency guidance under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). From 6 April 2025 the DMCCA replaced the Consumer Protection from Unfair Trading Regulations, so the CMA’s approach will shape day‑to‑day advertising for every agent. Our message is clear: property is different, and the guidance must reflect that.

Propertymark has responded to the Welsh Government’s consultation, which looks at changes to the way holiday lets are assessed for business rates and Council Tax. The consultation considers averaging days let over multiple years, recognising charitable donations, and introducing transitional arrangements for properties moving from non-domestic rates to Council Tax.

Propertymark has responded to the Welsh Government’s Draft Budget for 2026–27 with a warning that without tax reform, the continued loss of landlords will deepen affordability issues for tenants and increase pressure on local authorities to house more people in the social sector. A vibrant private rented sector (PRS), alongside investment in social and affordable housing, is essential to meet demand and ensure all people in Wales have access to decent and secure homes.

Responding to the Office for National Statistics’ (ONS) consultation on the Price Index of Private Rents (PIPR), Propertymark urges better alignment of UK-wide rental data, the use of achieved rather than advertised rents, and faster income statistics to strengthen affordability analysis. Clearer explanations of methodology are needed, as well as greater transparency around Rent Officer data, and quicker publication to make the index more useful.

Propertymark has responded to HMRC’s consultation on plans to increase the fees it charges businesses it supervises under the Money Laundering Regulations, warning that higher costs could affect small, independent agents hardest and risk undermining compliance. Proposals include raising the annual premises fee from £300 to £400, reintroducing a £400 application fee, and restructuring penalty charges into a new sanction regime with fines of up to £2,000.

Stage 1 scrutiny of the Bill is underway in the Senedd Local Government and Housing Committee, and Propertymark is set to give evidence in person on 9 October. We have also submitted written feedback, outlining how the legislation can be improved to ensure it achieves its aims.

Propertymark has submitted a detailed response to the UK Government consultation based on roundtables and surveys with agents across England. Our engagement shows that most properties managed by our members are already largely compliant. However, the extension of the Decent Homes Standard (DHS) will bring new obligations, particularly around damp and mould, safety measures, and clearer repair thresholds. We support a data-driven, proactive approach to property management that considers tenant experience.

The Housing, Communities and Local Government (HCLG) Committee inquiry into housing conditions in England focuses on the proposed extension of the Decent Homes Standard and the application of Awaab’s Law across social housing and the private rented sector (PRS). Evidence gathered from Propertymark members demonstrates why current initiatives do not go far enough to drive up standards or consistently protect tenants. Reforms must be proportionate, backed by strong enforcement, and packaged with meaningful support for agents and their landlords.

Propertymark has responded to the Scottish Government’s consultation on how powers in the Housing (Scotland) Bill could be used to exempt properties from rent control, allow rents to rise above the cap in certain circumstances, and change the way joint tenancies are ended.

Propertymark has responded to the Scottish Government’s plans to require private rented homes to meet a new EPC Heat Retention Rating of band C — from 2028 for new tenancies and 2033 for all lets — focusing on a property’s fabric and heating system to better link upgrades with reduced emissions. Whilst we support the principle of improving energy efficiency, we are concerned that the proposals place significant financial and practical pressures on landlords.

The Scottish Government has launched a consultation on proposals to align reliefs on Land and Buildings Transaction Tax (LBTT) for investor schemes with those available in England and Northern Ireland, making Scotland more attractive to large-scale investors. Propertymark supports this move but urges Ministers to give equal priority to incentives for individual landlords to ensure a diverse and sustainable property sector.