AST to Periodic Tenancy Conversion: Landlord Obligations Under the RRA 2025

Every fixed-term assured shorthold tenancy current on 30 April 2026 converted to a periodic assured tenancy on 1 May 2026 by force of RRA 2025 s.1 and the saving provisions in SI 2026/421 reg.2. The conversion is automatic and complete. What is not automatic is the contractual housekeeping that should accompany it: some clauses survive the conversion, some are voided, and some create landlord obligations (deposit position review, Right to Rent re-check assessment, rent-review-clause amendment offer) that should be worked through systematically across the portfolio.

This guide is the operational counterpart to the headline transition rule. For the substantive reform of the possession grounds catalogue that operates after conversion, see our companion guides on the operational mechanics of Section 21 abolition and the Schedule 1 grounds reform walk-through. For an RRA-compliant tenancy-agreement template covering new lettings, see our page on tenancy agreement clauses compliant with the RRA 2025. For the broader tax-implications framework, see the tax implications page.

The Conversion Mechanic in Plain Statutory Terms

The reform recasts the assured-tenancy regime in two steps. RRA 2025 s.1 amends Housing Act 1988 Part 1 so that all assured tenancies are periodic with a rent period not exceeding one month. RRA 2025 s.2 then omits Chapter 2 of Part 1 HA 1988 (the assured-shorthold-tenancy regime) entirely, removing the AST framework that previously sat alongside the periodic-assured regime. The combined effect is that every assured tenancy is now periodic by default; there is no remaining AST track on which fixed-term tenancies can sit.

SI 2026/421 reg.2 (Commencement No. 2 Regulations 2026) appointed 1 May 2026 as the commencement date for ss.1 and 2. The saving provisions in the same SI address transitional cases (pre-commencement Section 21 notices, in-flight possession proceedings, existing fixed-term ASTs). The effect is comprehensive: every fixed-term AST current on 30 April 2026 became a periodic assured tenancy on 1 May 2026, regardless of how much fixed term remained.

This is not a clause-by-clause conversion of the original tenancy agreement; it is a regime-level conversion of the underlying tenancy. The original agreement continues to govern the substantive obligations to the extent compatible with the new regime, but provisions that depend on the AST framework are no longer effective.

Which Clauses Survive the Conversion

The starting position is that substantive contractual obligations between the parties continue to bind. Specifically:

• Rent obligation. The amount and payment day continue to apply. Where the rent was payable in advance (typical: monthly in advance on the 1st of each month), that pattern continues. Any clause requiring more than one month's rent in advance is now constrained by RRA 2025 s.8 (which inserts HA 1988 s.4B making post-lease advance-rent provisions of no effect) and RRA 2025 s.9 (which amends the Tenant Fees Act 2019 to make pre-lease advance-rent demands prohibited payments).
• Deposit terms. The deposit continues in its existing Tenancy Deposit Scheme registration. No re-protection is required on conversion. The terms governing deductions, return at end-of-tenancy, and dispute resolution continue to apply.
• Repairing covenants. Landlord repairing obligations under LTA 1985 s.11 continue unchanged. Tenant repair obligations in the original agreement (typical: 'fair wear and tear' formulations, decorative obligations, garden maintenance) continue to apply.
• Permitted-occupiers list. Restrictions on who can occupy continue. Adding occupiers post-conversion still requires landlord consent (subject to reasonableness under the implied covenant).
• Use restrictions. No business use, no commercial activity, no antisocial behaviour clauses continue to bind.
• Pet provisions. Subject to the new statutory framework under RRA 2025 s.11 which inserts HA 1988 ss.16A/16B giving the tenant a right to request to keep a pet (with a narrow statutory reasonable-refusal test under s.16B(4)). Existing pet clauses prohibiting pets outright are constrained by the s.11 framework but specific reasonable conditions (cleaning at end-of-tenancy, named-pet-only restriction) may survive subject to consent reasonableness.
• Insurance obligations. Continue unchanged on both sides.
• Damage and dilapidation provisions. Continue to govern end-of-tenancy dispute resolution.

Which Clauses Are Voided by the Conversion

The clauses that do not survive are those that depend on the AST framework or that conflict with the post-reform statutory regime:

• Fixed-term-only break clauses. Contractual provisions allowing the landlord (or tenant) to end the fixed term at a specific milestone are redundant: the tenancy is now periodic and ends on the tenant's 2-month notice or the landlord's reformed Section 8 ground.
• Section 21-style termination clauses. Any clause referencing a Section 21 notice or a no-fault termination route is unenforceable. The Section 21 framework no longer exists.
• Fixed-term renewal mechanics. Automatic renewal clauses extending the AST for further fixed terms are inoperative. The tenancy continues indefinitely as periodic until terminated by tenant notice or landlord Section 8 ground.
• Rent-review clauses providing for above-statutory increases. Contractual rent-review clauses (typical: 'rent rises 3% each anniversary' or 'rent rises by RPI capped at 5%') are unenforceable for periodic-tenancy rent increases. All rent increases now run through the HA 1988 s.13 procedure as amended by RRA 2025 s.6.
• Bidding-wars and offer-acceptance clauses. RRA 2025 (Chapter 6 of Part 1) prohibits landlords from inviting or accepting offers above the advertised rent. Any clause referencing rental bidding or open-offer acceptance is unenforceable.
• Advance-rent clauses. Any clause requiring more than one month's rent in advance (typical 6-month-up-front or 12-month-up-front demands historically used for higher-risk tenants) is constrained by RRA 2025 ss.8 and 9.
• Tenant-notice provisions longer than 2 months. Contractual tenant-notice periods longer than the statutory 2-month minimum are unenforceable against the tenant.

The New s.13 Rent-Review Procedure

The single most operationally significant change from the conversion is how rent increases now work. The amended HA 1988 s.13 (as reformed by RRA 2025 s.6) provides:

• One rent increase per 12-month period maximum.
• 2 months' written notice of the proposed increase on the prescribed Section 13 form.
• Tenant can challenge the proposed increase at the First-tier Tribunal (Property Chamber) within the notice period.
• Tribunal can confirm or reduce the proposed rent; tribunal cannot increase the rent above the landlord's proposed figure (a procedural protection against tenants triggering self-harm by referring).
• Contractual rent-review clauses are unenforceable; the s.13 route is the exclusive mechanism.

The 'one increase per 12 months' rule applies per tenancy, not per landlord. For portfolio landlords with multiple tenancies, each tenancy has its own annual increase window. The window resets 12 months after the most recent s.13-effective increase date (not the notice date).

Practical Operating Mechanics

Landlords planning rent increases post-conversion should:

1. Confirm the current rent and the most recent rent-increase date for the property.
2. Identify the next eligible increase date (12 months from the most recent s.13 increase, or from the start of the tenancy if no prior s.13 increase has occurred).
3. Determine the proposed new rent. The figure should be defensible at FTT against market-rent evidence (comparable rental listings, agent valuations, RICS guidance). Reckless increases that exceed market are at high risk of FTT reduction.
4. Serve the prescribed Section 13 notice 2 months in advance of the intended increase date.
5. Track any tenant referral to FTT; the FTT decision binds for the relevant rent period.

Where Existing Rent-Review Clauses Sit

The cleanest approach to an existing contractual rent-review clause that conflicts with the s.13 procedure is to offer the tenant an amendment removing the clause (or replacing it with a clause confirming that rent increases follow the statutory procedure). The amendment is a positive paper-trail step; relying on the unenforceability of the clause produces the same legal outcome but leaves the original wording in place as a potential source of confusion or dispute.

Deposit Position Review

The deposit remains in its existing TDS registration; the conversion itself does not trigger a re-protection. However, the deposit position should be reviewed at the conversion for several scenarios:

• Current deposit higher than 5 weeks' rent. The Tenant Fees Act 2019 cap of 5 weeks' rent (for rents below £50,000 per annum) or 6 weeks' rent (above £50,000) was already in force pre-RRA-2025. If the deposit on an older tenancy exceeds the cap, it should have been refunded to the cap level when the cap took effect in 2019; conversion provides a fresh reason to audit compliance.
• Rent increases post-conversion. Where a future s.13 rent increase pushes the rent above its current level, the deposit cap recalculates against the new rent. The landlord can request a top-up to maintain the cap proportion, but the top-up itself triggers fresh prescribed-information requirements within 30 days of receipt.
• Deposit dispute resolution. The TDS dispute-resolution route continues to operate as before. End-of-tenancy claims for damage or unpaid rent are dealt with under the scheme's adjudication framework.

Right to Rent Position Review

The Immigration Act 2014 s.22 Right to Rent regime continues to apply unchanged. The conversion does not trigger a fresh check on the existing tenant. The position is:

• Original RTR check at the start of the tenancy continues to satisfy the obligation.
• Scheduled re-checks (for tenants with time-limited Right to Rent documents) remain on track per the original schedule.
• New tenants moving in post-conversion require the standard RTR check before occupation.
• Landlord records of original checks must be retained for the duration of the tenancy plus 1 year (the standard Home Office retention period).

The conversion does not create a new RTR audit risk, but it does provide a useful occasion for portfolio landlords to confirm that records are intact and accessible. Lost or missing RTR records are a separate enforcement risk under the IA 2014 s.21 civil-penalty regime.

Practical Action List for Portfolio Landlords

Working through the conversion systematically across a portfolio of 5+ tenancies, the standard sequence is:

1. Tenancy-agreement clause audit. Identify which clauses are voided by conversion and which survive. A template audit spreadsheet listing the clauses against survival status is the cleanest format.
2. Tenant communication. Issue a conversion confirmation letter to each tenant explaining the change in status and the continuing-terms position. A short paragraph confirming the new tenant 2-month notice right and the new rent-review procedure prevents later disputes about understanding.
3. Rent-review clause amendments. Where existing tenancies carry contractual rent-review clauses, offer an amendment removing the clause. The amendment is voluntary on the tenant's side; if declined, the unenforceability of the clause achieves the same legal outcome.
4. Future rent-increase timetable. Update the portfolio management system to track the next eligible Section 13 increase date for each tenancy.
5. Deposit cap audit. Confirm each deposit sits at or below the 5-week or 6-week cap. Refund any excess to the cap level if not already done.
6. RTR records audit. Confirm original RTR records are present and accessible; check scheduled re-check dates for time-limited document holders.
7. Template refresh for new lettings. Replace the AST-specific tenancy template with an RRA-2025-compliant template for any new lettings post-conversion. The RRA-2025-compliant clauses page provides a starting framework.
8. Insurance review. Confirm landlord insurance schedules continue to reflect the actual portfolio post-conversion (no specific cover change is triggered by the conversion itself, but it is a useful annual-review prompt).

What Happens If a Landlord Did Nothing on Conversion

For landlords who took no action on or after 1 May 2026 (no tenant communication, no clause audit, no rent-review system update), the legal position is still that the tenancies converted automatically and the post-RRA statutory regime applies. The risk is operational rather than legal:

• A landlord trying to enforce a contractual rent-review clause that conflicts with s.13 will find the clause unenforceable at FTT, with potential exposure on costs and a poor paper trail.
• A landlord serving a Section 21 notice post-1-May-2026 will find it has no statutory basis. Any possession claim issued on that notice will fail at the procedural stage.
• A landlord operating on the assumption that the fixed term still binds the tenant will find the tenant exercising the 2-month statutory notice-to-quit right with no contractual or statutory recourse.
• A landlord with deposit records not aligned to the cap may face civil penalty under the TFA 2019 framework, separately from the RRA conversion.

None of these consequences is catastrophic in isolation, but they accumulate at portfolio scale. The post-1-May-2026 environment rewards landlords who treated the conversion as a structured operational event and penalises those who waited for problems to surface.

Edge Cases: Where the Conversion Mechanic Becomes Nuanced

For most fixed-term ASTs the conversion is mechanically clean: the tenancy was AST on 30 April 2026 and became periodic assured on 1 May 2026. A small number of tenancy situations carry nuances worth understanding before relying on the default position.

Joint Tenancies

Joint AST tenancies (two or more tenants jointly named on the agreement) convert as a single tenancy. The tenants remain jointly and severally liable for rent and obligations under the converted tenancy. The 2-month tenant notice-to-quit right is exercisable by any one joint tenant on behalf of all, which is a structural feature carried over from the existing periodic-tenancy framework. Landlords with shared-tenancy portfolios should be aware that any joint tenant can end the tenancy by serving notice independently. Where joint tenants are in a shifting personal relationship (couples, shared houses), this raises practical management questions on whether to engage with one tenant or both at end-of-tenancy.

Tenancies Started Days Before Commencement

A tenancy granted as a fixed-term AST in late April 2026 (say a 12-month AST starting 25 April 2026) converted to periodic on 1 May 2026 only days later. The tenant gained the 2-month notice-to-quit right immediately on conversion. Landlords who granted late-AST tenancies in the run-up to commencement on the assumption that the fixed term would continue to bind found the term effectively converted within weeks. The transitional saving provisions in SI 2026/421 do not preserve the fixed-term character of tenancies caught by the commencement date; the conversion is mechanical, not equitable.

Sub-Let Arrangements

Where an AST tenant has lawfully sub-let part or all of the property to a sub-tenant under a sub-tenancy that is itself an AST, both tenancies convert on 1 May 2026. The head tenancy converts to periodic assured between landlord and tenant; the sub-tenancy converts to periodic assured between tenant (as sub-landlord) and sub-tenant. The two converted tenancies operate independently, with each governed by the post-RRA statutory regime. Possession on Ground 1A by the head landlord would terminate the head tenancy and put the sub-tenant in the position of dealing directly with the head landlord on the sub-tenancy's status, subject to the standard rules on sub-tenant rights at end-of-head-tenancy.

Company-Let and Business Tenancies

Tenancies granted to corporate tenants (typically for staff accommodation arrangements) and tenancies that fall under the Landlord and Tenant Act 1954 Part II business-tenancy regime remain outside the assured-tenancy framework. The pre-existing carve-outs in HA 1988 Sch 1 (paras 1, 4, 7, 10) continue to apply: tenancies to limited companies, holiday lets, lettings to students by specified institutions, and Crown lettings are not assured tenancies and are unaffected by the RRA 2025 reform. Landlords should check the original tenancy paperwork against the carve-out criteria; misclassified company-lets that should have been AST (because the company tenant was a sham and the real occupier was an individual) remain at risk on the historic position even though the conversion does not affect them substantively.

Pre-1989 Rent Act 1977 Tenancies

Tenancies granted before 15 January 1989 typically operate under the Rent Act 1977 regulated-tenancy regime, not under the HA 1988 assured-tenancy regime. The RRA 2025 reforms do not apply to Rent Act tenancies, which retain their pre-1989 statutory framework (fair-rent registration, succession rules, statutory tenancy on death of contractual tenant). Portfolio landlords with very long-standing tenancies should confirm the regime under which each tenancy operates; mistaken treatment of a Rent Act tenancy as an assured tenancy is an error that affects rent reviews, succession, and possession routes.

Worked Example: 3-Year Fixed Term Starting May 2024

A landlord granted a 3-year fixed-term AST starting 1 May 2024 and running to 30 April 2027 at a rent of £1,500/month. The original tenancy agreement contained a contractual rent-review clause providing for an annual increase at RPI capped at 4%, scheduled for 1 May each year. The first scheduled review on 1 May 2025 occurred and rent went up to £1,545/month. The next scheduled review was 1 May 2026.

On 1 May 2026 the tenancy converted to periodic assured. The contractual rent-review clause is now unenforceable for the 1 May 2026 review and any subsequent review. The landlord cannot increase the rent on 1 May 2026 under the contract. Instead, the landlord can serve a Section 13 notice giving 2 months' written notice of a proposed increase; the increase takes effect from the date specified in the notice (so realistically a 1 July 2026 effective date at earliest). The proposed rent must be defensible at FTT against market evidence. The tenant has 2 months to refer to FTT if they consider the proposed rent above market.

The landlord cannot retrospectively apply the contractual review to 1 May 2026. The next eligible rent increase is the s.13 notice route, and any s.13 increase resets the 12-month clock for the next eligible increase.

The Conversion Position in One Line

Every fixed-term AST converted to periodic on 1 May 2026 by force of statute; substantive contractual obligations survived (rent, deposit, repairs, occupier restrictions); AST-dependent clauses were voided (fixed-term break clauses, Section 21 termination, contractual rent-review); the practical follow-up for landlords is a clause audit, tenant communication, rent-review system update, deposit position review, and template refresh. The conversion is statutorily automatic, but the operational housekeeping is not.