$500 idea · Pattern break · United Kingdom · Edition 001
£341 of tribunal fees now buys a claim capped at 24 months’ rent.
From 13 July 2026 the First-tier Tribunal (Property Chamber) Fees (Amendment) Order 2026 charges a tenant £114 to apply and £227 to be heard for a rent repayment order — and charges a landlord £500 to appeal a council’s financial penalty. The state has priced a landlord’s defence £159 above a tenant’s two-year claim. On 6 March 2026 the same tribunal ordered Mio Real Estate Ltd to repay £31,436.23 to five tenants of one Bethnal Green flat, and refunded their fees under rule 13(2).
Two things happened to rent repayment orders this year and almost nobody has put them side by side. On 1 May 2026 the Renters’ Rights Act 2025 doubled the ceiling from 12 to 24 months’ rent and extended liability to superior landlords and company directors — legislatively reversing Rakusen v Jepsen [2023] UKSC 9, in which the Supreme Court had held that the landlord at the top of a rent-to-rent chain could not be touched. On 13 July 2026 the Ministry of Justice put a price on the application for the first time at this level: £341 all in.
The consensus read on the second event is that it shuts tenants out. The documents say otherwise. Rule 13(2) of the Property Chamber Rules lets the tribunal order the loser to reimburse the fee, and it routinely does: Haringey’s 26 August 2026 award of £7,884.84 came with £341 of fees on top — the new schedule refunded in full, to the penny. Meanwhile rule 14(1) says in terms that a representative need not be legally qualified, and a rent repayment order is not one of the five claim types in article 89F(2) of the Regulated Activities Order, so representing one falls outside the FCA’s claims-management perimeter.
So the interesting number is not the fee. It is the ratio. £341 is 1.1% of what one tribunal awarded against one landlord on one flat in March — and since May the same filing reaches twice as far. The people on the other side of this trade are rent-to-rent operators who, for three years after Rakusen, were structurally unreachable. They are reachable from 1 May, by anyone, at a cost the winner does not ultimately bear.
The evidence
8 findingsA tenant’s claim costs £341. A landlord’s appeal costs £500.
The First-tier Tribunal (Property Chamber) Fees (Amendment) Order 2026 sets a rent repayment order at £114 to apply and £227 for a hearing, and an appeal against a local authority’s financial penalty at £200 and £300. Sarah Sackman, Minister for Courts and Legal Services, told the Commons Delegated Legislation Committee on 27 April 2026 that “the estimated cost to the taxpayer of an average case brought to the property chamber is more than £900”; the Order was approved 11–3. Hansard, 27 April 2026 · draft Order
The ceiling doubled from 12 to 24 months’ rent, and reached the top of the chain.
MHCLG’s guide to the Renters’ Rights Act 2025 states that “the maximum amount of rent a landlord can be ordered to pay will double from 12 to 24 months” and that rent repayment orders are extended “to superior landlords and company directors to ensure criminal rent-to-rent arrangements can be properly held to account”. The implementation roadmap puts both in Phase 1, commencing 1 May 2026. Guide to the Act · roadmap
What the Act reversed: Rakusen v Jepsen [2023] UKSC 9.
Martin Rakusen held the head lease on a Finchley flat sub-let by a rent-to-rent operator; Mikkel Jepsen and two other occupiers sought a rent repayment order against him. The Supreme Court held unanimously that a rent repayment order can only be made against the immediate landlord under the tenancy, insulating superior landlords for the three years since. That insulation ended on 1 May 2026. UKSC 2021/0188
£31,436.23 against Mio Real Estate Ltd — argued by someone who is not a lawyer.
Phillipa May Toye, Shigemitsu Chihiro, Alexandra Marin, Nicoll Zachary and Ioanna Argypro Angelou, tenants of Flat 5, Paris House, Old Bethnal Green Road E2, won 70% of the maximum recoverable against their landlord for managing an unlicensed HMO. The tribunal took 25% off because unlicensed management is “a more minor offence”, another 10% because it was “not a serious offence of its kind”, then added 5% back for unprotected deposits. £777 of fees were reimbursed under rule 13(2). The applicants were represented by Mr Muhammad Williams of the London Borough of Tower Hamlets. Decision (PDF)
The new fee came back to the penny: £341.
A tenant of a property on Leaside Avenue, Muswell Hill was awarded £7,884.84 in rent against a landlord operating an unlicensed HMO — “plus £341 in application and hearing fees”, which is £114 + £227 exactly. The landlord had already been the subject of a separate rent repayment order on another property. Cllr Tammy Hymas, Cabinet Member for Housing: “This case sends a clear message to landlords: if you’re breaking the law, we’re coming after you.” Haringey Council
“A party may appoint a representative (whether legally qualified or not).”
That is rule 14(1) of the Tribunal Procedure (First-tier Tribunal) (Property Chamber) Rules 2013, verbatim. Rule 14(5) goes further: a person who turns up unannounced may, with permission, act as a representative at the hearing. Rule 13(2) is the reimbursement power the Paris House and Haringey awards were made under. Rule 14 · Rule 13
A rent repayment order is not a regulated claims-management activity.
Article 89F(2) of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 defines the claim types that bring a paid representative inside the FCA’s perimeter: personal injury, financial services, housing disrepair, criminal injury, employment. A rent repayment order under the Housing and Planning Act 2016 is none of them — it is a statutory repayment of rent, not disrepair of premises. The FCA Handbook defines “housing disrepair claim” solely by reference to article 89F(2)(e). Article 89F · FCA Handbook
Six five-bed houses a year is $5,000 a month.
Rate: Wise, 29 September 2026. $500 ÷ 1.3241 = £377.61; $5,000 ÷ 1.3241 = £3,776.15 per month, or £45,313.80 a year. Paris House recovered £31,436.23 ÷ 5 = £6,287.25 per tenant. At a 25% share of recovery that is £1,571.81 per tenant-claim, so £45,313.80 ÷ £1,571.81 = 28.8 tenant-claims a year — 5.8 properties at the Paris House shape of five applicants each, call it six. Fees: 6 × £341 = £2,046 a year, reimbursable under rule 13(2). Diagram coordinates: £6,287.25 ÷ 0.70 = £8,981.78 twelve-month maximum, ÷ 12 = £748.48 monthly rent, × 24 = £17,963.56 under the ceiling since 1 May 2026.
The ladder
From $500 to $5,000 a month · £377 → £3,770$500 at 1.3241 is £377.61. One rent repayment order application is £114 plus £227 on listing. That leaves £36.61 — and on a win rule 13(2) puts the £341 back, which is what funds application two.
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Hold £377.61 and spend £341 of it once.
$500 at 1.3241 is £377.61. One rent repayment order application is £114 plus £227 on listing. That leaves £36.61 — and on a win rule 13(2) puts the £341 back, which is what funds application two.
£377.61 − £341 = £36.61 · refunded on win -
Find the unlicensed HMOs from the council’s own register.
Every local authority in England publishes its HMO licence register under section 232 of the Housing Act 2004, and most publish the additional and selective licensing designations that define which streets need one. A property in a designated area that is absent from the register is the case. Haringey’s repeat offender was found this way.
designation area − licence register = the list -
Act for the tenants, not for yourself.
Rule 14(1) permits a representative “whether legally qualified or not”, and article 89F(2) of the Regulated Activities Order does not capture rent repayment work, so a fee arrangement does not require FCA authorisation. Tower Hamlets sent a council officer, Mr Muhammad Williams, and he beat an unrepresented company for £31,436.23.
rule 14(1) · outside art. 89F(2) -
File against the whole chain, not the name on the tenancy.
This is the rung that did not exist before 1 May 2026. Superior landlords and company directors are now in scope, which puts the rent-to-rent operator’s principal — usually the solvent one — on the order. For three years Rakusen v Jepsen made that impossible.
immediate landlord → superior landlord + directors -
Claim 24 months, expect 70%.
The ceiling doubled but the tribunal still discounts for the seriousness of the offence: Paris House came in at 70% of maximum after a 25% reduction, a further 10%, and a 5% uplift for unprotected deposits. Price the case off 70% of 24 months, not 100% of it, and the deposit point is worth finding.
£748.48 × 24 × 0.70 = £12,574.47 per tenant -
Six houses a year clears $5,000 a month.
At the Paris House recovery of £6,287.25 per tenant and a 25% share, each tenant-claim is £1,571.81. Twenty-nine of them is £45,313.80 — £3,776.15 a month, $5,000 at today’s rate. That is roughly six five-bedroom HMOs, and £2,046 of tribunal fees across the year, refunded on every win.
29 × £1,571.81 = £45,313.80/yr = £3,776.15/mo
Sources
13 primary documents- Draft First-tier Tribunal (Property Chamber) Fees (Amendment) Order 2026 — Commons Delegated Legislation Committee, Hansard, 27 April 2026
- The First-tier Tribunal (Property Chamber) Fees (Amendment) Order 2026 — legislation.gov.uk
- Guide to the Renters' Rights Act 2025 — MHCLG, updated 2026
- Implementing the Renters' Rights Act 2025: roadmap — MHCLG, 13 November 2025
- Rakusen v Jepsen and others [2023] UKSC 9 — UK Supreme Court, 1 March 2023
- FTT decision LON/00BG/HMF/2025/0727, Flat 5 Paris House — 6 March 2026 (PDF)
- Tenant awarded nearly £8,000 after unlicensed HMO case — Haringey Council, 26 August 2026
- Tower Hamlets tenants awarded more than £31,000 — Tower Hamlets Council, April 2026
- Tribunal Procedure (First-tier Tribunal) (Property Chamber) Rules 2013, rule 14 — SI 2013/1169
- Tribunal Procedure (First-tier Tribunal) (Property Chamber) Rules 2013, rule 13 — SI 2013/1169
- FSMA 2000 (Regulated Activities) Order 2001, article 89F — SI 2001/544
- FCA Handbook glossary: "housing disrepair claim"
- GBP to USD rate history — Wise, 29 September 2026