Enforcement Against Slum Landlords: A Report and Recommendations (Part 2)
In this article we will review a new report which focusses in on the problem of so-called slum landlords and, specifically, at the issues surrounding taking enforcement action against them. It looks at the difficulties slum landlord enforcement involves, as well as at some working practices which have aimed to improve the situation. It concludes by making some recommendations for improvements both to the law and to working practices in housing enforcement against these types of landlords.
Background to the report
We have already looked at the first report from this project, with our thoughts published on our website here.
This is another report from the Criminality in the PRS project. It ran between April 2023 and December 2025 and was funded by the Economic and Social Research Council.
The project involved several work packages which looked at landlord behaviour, tenant experience and enforcement activity. The results of their research was made up into several reports, of which this is the second one.
The project involved cross-institutional research with the University of York, University of Sheffield, Northumbria University, the Safer Renting organisation and a number of advisory board members. This report was led by the University of York.
The project overall uses the Yorkshire and the Humber area as the basis for its study – saying that this had the highest crime rate of all English regions in 2023-24. The project overall used information from 15 regional authorities, although this report uses information from just three or four.
Some key findings from the report
There is an issue with identifying slum landlords
The report starts by pointing out that there is no formal definition of what it calls slum landlordism. It says that this is a fundamental problem which hinders attempts to tackle these landlords.
The authors suggests a slum landlord is one who: Breaks housing law persistently, operates properties that harm tenants and deliberately engages in behaviour to try and avoid enforcement.
It says that slum landlords operate this way as an intentional business model. This distinguishes them from landlords who break the rules occasionally or accidentally and are amenable to changing their ways.
It suggests that recognising slum landlords as a sub category within the landlord population – and perhaps channelling them off into a dedicated enforcement pathway – could make enforcement against them more effective.
There is an issue with statistics
Another obstacle to better enforcement, according to the report, is the difficulty of knowing how many slum landlords there are and so the extent of the problem. (This is likely to continue to be a problem in the short term, at least until the new landlord database to be created by the Renters’ Rights Act comes into operation.)
As with other kinds of housing enforcement local authorities find it difficult to be proactive in slum landlord enforcement. They are highly reliant on complaints being made about landlords.
Much more than this, however, the report suggests that the vast range of different enforcement tools available to local authorities makes collecting statistics on the use of them, and their success or otherwise, difficult too. It points out that a majority of offences do not lead to prosecutions, for which statistics are available. They say there is no – or at least no reliable, consistent national data – on the use of informal enforcement measures, enforcement notices or civil penalty notices (CPNs).
There is an issue with enforcement culture and strategy
The authors put forward the argument that, as housing legislation hands local authorities a great deal of discretion, this has led to different local authorities having different enforcement cultures. Additionally the wide range of enforcement tools varies from light touch to heavy touch. These factors are contributors to making enforcement patchy.
An interesting aside is that local authorities covered by the study appeared to be moving towards more formal enforcement approaches.
The authors explain that, amidst this environment, local authorities have to make their own individual strategic choices when it come to enforcement. In effect, authorities choose from a ‘legislative buffet’ depending on their particular circumstances.
Some interesting insight is provided on the use of civil penalty notices versus prosecuting landlords. The report says that local authorities whose enforcement strategies centre on the use of civil penalty notices appear less likely to draw on other powers – especially when enforcing under the Housing Act 2004.
Local authorities also find themselves in a ‘catch 22’ situation when it comes to strategy. With prosecution, considerable work is involved but fines are often small and so ineffective. Civil penalty notices (CPNs) are more efficient and give more control to local authorities. However they don’t provide a direct route to banning or removing slum landlords from the market. They have limited use against other parties.
What’s needed to tackle slum landlords?
The authors offer some thoughts on what seems to improve enforcement work against slum landlords, based on cases they studied.
A sound enforcement policy and culture
Effective enforcement depends on good leadership, a consistent enforcement culture and sound working practices coupled with good legal oversight.
Effective service resourcing
The report confirms, as anyone with a knowledge of the sector will already know, that a shortage of both financial and human resources has increasingly impacted enforcement in recent years.
Interestingly, the research suggests that funding which enables targeted, proactive enforcement might be helpful. For example, one local authority had a ring-fenced budget for works in default (urgent repair works carried out by local authorities) which they had found beneficial.
When it comes to staff, the study confirms that hiring and retaining experienced environmental health officers is an issue. However, it suggests there are benefits in having an enforcement team with a broad skillset alongside a strong working culture who can collaborate closely on a case. For example, one case study authority reported that access to a dedicated, inhouse solicitor had increased the effectiveness of their work.
Effective partnership and interagency working
The report suggests that some external agencies currently have difficulty in recognising slum landlordism, or do not see it as a priority, and this can hamper enforcement teams.
It says that better partnership working, both internally between local authority services and with external agencies – alongside effective information sharing – could improve the power and efficacy of housing enforcement.
The report talks about how landlords and tenants impact the enforcement process. (Again these are things that those in the sector will be aware of.) It says tenants that are often reluctant to cooperate with investigations. It says that slum landlords frequently obscure property ownership. They also use piecemeal repairs as a deliberate delaying tactic to avoid effective enforcement.
The Renters’ Rights Act
Unlike the first report in the series, this study addresses the possible impact of the Renters’ Rights Act 2025 head on. It suggests that the new enforcement powers for local authorities and widened civil penalty regime should prove helpful. However, it says the Act does not offer a prosecution pathway as an alternative to the new CPNs and that this is a potential flaw. It also suggests that making use of the new measures could strain resources and prove to be an enforcement challenge.
Recommendations
The authors outline their own twelve point plan as to how enforcement against slum landlords could be improved:
The government should acknowledge and adopt slum landlordism as a concept.
All agencies involved with the PRS should be taught to recognise slum landlordism.
Slum landlordism should be regarded as a priority for enforcement.
Regional governments (such as those in devolved areas) should play a coordinating role between local authorities.
The Housing and Planning Act 2016 should be amended so that civil penalty notices issued for banning order offences can be used to support a banning order application.
Housing enforcement officers should prepare evidence for civil penalty notices to the same standard as for criminal prosecutions.
Housing enforcement policies should contain a policy objective of eliminating slum landlordism.
Housing enforcement policies should recognise that slum landlordism is harmful to tenants, and that they are victims. Local authorities should allocate a share of their service revenue towards developing support systems for tenants
Housing enforcement policies should be structured through a series of informal and formal measures with a clear process for moving between them.
Local authorities should publish their enforcement policies online.
Local authorities should make sure their officers are able to use the full range of enforcement powers, and build service capacity to enable this.
The government should consider facilitating the use of management orders by piloting ring-fenced funding for this.
Some thoughts
Firstly we have to mention that this is a very lengthy report indeed. The full version covers 115 very closely set pages (although a short summary is available). The authors are certainly to be commended for the many, many hours they must have devoted to it. However, it could be argued that the sheer volume of the report makes it somewhat harder to digest and so reduces its impact.
A fair proportion of the report is devoted to explaining housing law. This is a professional-level report and professionals in the sector will (or should) know much of this already.
As with the first report from the same organisation, this report is also based on experiences from a fairly limited geographical area. We do wonder if the situation is similar across the country, or widely different.
There are, however, some really useful elements to this report. Firstly the information based on case studies which shows how enforcement against slum landlords works – or in some cases how it doesn’t. There is some really interesting learning (mostly found in the full length version of the report) to be had here.
Secondly, the suggested improvements to enforcement against slum landlords have been well thought out and deserve some credit. The idea of identifying slum landlords as a sub-category and making special provisions for tackling them throughout the system is a standout. (Though all this would probably take a considerable amount of legislation to effect and a lot of resources to make use of. Getting 300+ local authorities and many other agencies to sing from the same hymn sheet would be no mean feat either.)
As with the first report we reviewed, this report confirms that housing enforcement is complex and about to become more so. Can it even be simplified?
More information
This report can be read in full here: Enforcement against slum landlords
Find out more about how Surrey Property Licensing can help you here.
