Registration numbers on property adverts: what the PRS database means for how you market a let
Section 82 of the Renters’ Rights Act 2025 says a rental cannot be marketed unless the landlord and the property both have active entries on the PRS database, and that written adverts must carry both identifiers. The rule binds whoever markets, which makes it a letting-agent rule before it is a landlord one. It has not yet been confirmed as in force.
On this page
- Do adverts need a PRS database registration number?
- Is the advertising rule in force yet?
- What counts as marketing a rental?
- Who commits the breach when an agent markets a property without entries?
- How will portal listings change?
- What about a property that is empty between tenancies?
- What about new landlords and new instructions?
- What should a letting agent change in its listing workflow?
- Frequently asked questions
Do adverts need a PRS database registration number?
Property adverts in England will need two PRS database identifiers once section 82 of the Renters’ Rights Act 2025 is in force: one allocated to the landlord and one to the dwelling. The Act requires both in any written advertisement. It also bars marketing a dwelling at all unless both entries are active.
The wording is short. A person “must not market a dwelling for the purpose of creating a residential tenancy” without both active entries (s.82(1)). Section 82(2) then requires the unique identifiers, allocated by the database operator, in any written advertisement. Section 82(3) puts a separate duty on the landlord to keep both entries active.
What the Act does not say is what an identifier looks like. The draft Regulations do not define a format, and we have found no published specification.
Source: Renters’ Rights Act 2025, s.82
Is the advertising rule in force yet?
The advertising rule in section 82 is not confirmed as in force. The Act is brought into force by commencement regulations. Section 82 is in force only for making regulations. We have found no commencement regulation that switches on the marketing duty itself, and the government has said it will apply at a later stage of the rollout.
| What | Status as at 6 October 2026 | Source |
|---|---|---|
| s.82 (marketing, identifiers on adverts) | In force for making regulations only. Not commenced for substance. | Act, s.82 note and s.145(2) |
| Commencement Nos 1 to 3 (Dec 2025, Apr and Jun 2026) | None of the three lists s.82 or the database chapter | SIs 2025/1354, 2026/421, 2026/638 |
| s.91 (the £7,000 penalty) | In force “for specified purposes” only | Act, s.91 note |
| s.92 (repeat-breach offences) | Not in force | Act, s.92 note |
| Draft PRS Database Regulations 2026 | Draft; open from 15 December 2026, region by region | draft Reg 1 |
The gov.uk Housing Hub says that, under future legislation, unoccupied properties will need registering before you or your agent markets them, and that identifiers will go on adverts at that point. It adds that further guidance will come ahead of the requirement.
Read together, the sources point to marketing rules arriving after the first registration phase. That is our reading, not a confirmed date. The draft Regulations’ catch-all date for entries not tied to a region’s let homes is 15 September 2027, and it is the earliest date we can point to for entries on homes that are not yet let. It does not, on its own, commence section 82.
Sources: Housing Hub, Get ready to register · Commencement No. 3 Regulations 2026 · Draft Regulations, reg 1
What counts as marketing a rental?
Marketing a rental, for the Act’s purposes, means advertising that a dwelling is or may be available to let, or telling someone so in the course of lettings agency work. That definition sits in section 99, which was brought into force for another chapter’s purposes in December 2025. Its wording is broad, so it reaches more than the portal listing.
Two limbs matter to agents. Advertising that a home “is or may be available” covers the portal ad, the website, the brochure, the social post and the window card. The second limb covers a negotiator who tells a waiting applicant, in the course of agency work, that a home may be coming up. A “coming soon” message to a mailing list is the awkward case: it is a statement that the home may be available.
Two carve-outs matter for the supply chain. A publisher that is not a lettings agent and only publishes an advertisement provided by someone else is not treated as marketing under the first limb. Passing on a landlord’s brief to a portal does not move the duty to the portal; it stays with the agent who supplied the advert.
- Portal listings and your own website
- Window cards, boards and printed brochures
- Social posts, paid and organic
- “Coming soon” emails and applicant-list messages
- Off-market conversations with registered applicants
The Act says “written advertisement” for the identifier duty. It does not define the term. Whether a video-only post or a spoken advert counts is untested.
Source: Renters’ Rights Act 2025, s.99
Who commits the breach when an agent markets a property without entries?
The person who markets or advertises commits the breach under section 82, so an agent that markets without active entries is in breach in its own right. Section 82(1) and (2) are drafted on “a person”, not on the landlord, and a council can penalise any person who breaches them. Section 82(3) is the landlord’s own duty.
| Duty | Who it falls on | Penalty route |
|---|---|---|
| s.82(1): no marketing without both active entries | Anyone who markets, including the agent | Civil penalty up to £7,000 (s.91), once in force |
| s.82(2): both identifiers in written adverts | Anyone who advertises, including the agent | Civil penalty up to £7,000 (s.91), once in force |
| s.82(3): keep both entries active | The landlord | Civil penalty up to £7,000 (s.91), once in force |
Three points of detail follow from the text. A council may impose more than one penalty for conduct that continues. A later, different breach within five years of a penalty is a criminal offence under s.92(3), as is any breach within five years of a conviction or a penalty for a s.92 offence. And a breach does not make the tenancy void: s.82(5) says the contract stays valid and enforceable.
The Secretary of State may by regulations move the s.82(3) duty to someone other than the landlord, or disapply a duty for a period (s.82(4)). The draft Regulations do not use that power. So, on the current drafting, an agent cannot point at the landlord’s duty to answer its own.
For the full penalty table, see what happens if a property is not registered. For what councils can do with the data, see the PRS database and property licensing.
Sources: s.91 · s.92 · s.82(4)-(5)
How will portal listings change?
Portal listings will need two extra fields populated for every rental, one for each identifier. We have found no announcement from Rightmove, Zoopla or OnTheMarket, or from the main lettings CRM suppliers, of a registration-number field or a validation rule. Until one exists, an agent’s feed has nowhere to put the numbers.
The Act places the written-advertisement duty on a person who advertises, and “advertises” is not defined in the way “markets” is. Some commentary expects portals to be bound as well. We do not read the text that firmly: section 99 carves out a publisher that only publishes someone else’s advert. Either way, the agent who supplies the listing is the safe party to assume is responsible.
What to prepare, whatever the portals do:
- Hold both identifiers against the property record in your CRM, not in a note or a spreadsheet.
- Make “both entries active” a status your team can see rather than only a number.
- Decide who owns the advert text on brochures and social templates, since a feed field will not reach those.
For how CRM-held data feeds portals, see the integrations page. We make no claim here about any CRM’s support for these fields.
Sources: Housing Hub, Get ready to register · Renters’ Rights Act 2025, s.99(4)
What about a property that is empty between tenancies?
A property between tenancies is a dwelling that is intended to be let, and it needs both entries active before it is marketed once the rule applies. The first registration phase covers homes that are let or become let during the rollout. The government has said that unoccupied properties come later.
The draft Regulations already provide for this case. A dwelling entry can be made for a dwelling “intended to be let”, with Part 1 of Schedule 3 only. The tenancy-specific Part 2 information (the rent, the tenants and the safety documents) is then due within 28 days of a tenancy starting (draft Regs 6 and 9). That is the route a void-period listing will use.
There is one trap in the draft Regulations. An entry becomes inactive the day after its renewal date if it is not renewed, and renewal needs the fee to be paid (reg 10). The draft does not switch an entry off when a tenancy ends. Our reading is that an entry for a home that goes void stays active until its renewal date, so a void is a reason to keep renewing, not a reason to let the entry lapse. An agent who lets it lapse during a void would have to reactivate before marketing the re-let.
Who pays the renewal fee in a void is a question for your terms of business: see what agents should put in their terms of business.
Sources: Draft Regulations, regs 6, 9, 10
What about new landlords and new instructions?
A new instruction needs two entries before the home can be marketed, and the landlord is the one who has to create them. Under the draft Regulations, a landlord, or a person who intends to become one, makes the entry. An appointed agent provides some information once the entry exists (draft Reg 4).
That order creates a dependency that agents do not control. The landlord must create the landlord entry, then create the dwelling entry and pay the fee, before the dwelling entry is made (draft Reg 6(5)). Only then does an identifier exist to put on the advert. A landlord who instructs you on Friday and expects a listing on Monday may not have started.
Four other points from the draft Regulations are worth knowing:
- A landlord entry becomes inactive if no dwelling entry is made against it within three months.
- A dwelling entry becomes inactive if the operator is told the intended landlord has changed and the home is not let.
- A sale of a let home can allow a second, buyer-named entry so the buyer can market before completion (draft Reg 6(7)).
- A landlord subject to a banning order cannot make an entry.
For how to nominate an agent and what an agent can and cannot do on the service, see what can a letting agent do on the PRS database? For what a landlord must have ready, see what information do I need to register?
Sources: Draft Regulations, regs 4, 6, 11
What should a letting agent change in its listing workflow?
A letting agent should move registration status from an after-the-event check to a gate on the listing process. The goal is simple: nothing is published, printed or posted until both entries are confirmed active and both identifiers are on the advert. Most of the work is deciding who checks, and where.
Instruction
Ask for the landlord’s identifier, or start the landlord on registration.
Property record
Store both identifiers and the entry status in the CRM.
Pre-listing check
Confirm both entries are active before any advert is approved.
Publish
Identifiers go on the portal ad, the website, the brochure, the board, the card and the post.
Monitor
Pull the listing if either entry goes inactive; diary each renewal date.
-
Add two fields to the property record, and make the listing sign-off refuse to complete without them
-
Name one role who owns the pre-listing check, with a second person covering holidays
-
Put the identifiers in every template: brochure, board, window card, social post
-
Diary each entry's renewal date, with a reminder well ahead of it
-
Add a “registration status” line to the instruction checklist for new landlords
-
Keep a dated record of each check, in case a council asks
-
Train negotiators on the second limb: telling an applicant a home “may be available” counts
The check belongs with whoever signs off the advert, which is usually a lettings manager, not a negotiator. Making it a named duty matters more than the tool used for it. A rule that “everybody checks” is checked by nobody.
Do this work in order of effort, not of deadline. The data model change (two fields and a status) is quick. Chasing landlords is the slow part. Both are the same across every region.
What's changed
-
First draft. s.82 commencement unconfirmed; no portal announcement found.
Frequently asked questions
Not on current information. Section 82 is not confirmed as in force, and the government has said the marketing rule comes with the later stage of the rollout. Check the commencement status above before you act.
Under section 82(1), no: both entries must be active before you market. That applies once the rule is in force. Until then, the question is about preparation, not compliance.
The Act requires the identifiers in any written advertisement. A social post with text and a window card are both written. Whether video or audio-only adverts count is untested.
The Act puts the marketing and advertising duties on “a person” who markets or advertises, which includes the agent. Whether a portal that only publishes someone else’s advert is also bound is unclear from the text.
No. Section 82(5) says a breach does not affect the validity or enforceability of the tenancy. A council can still penalise the breach.
No. They are separate duties. See does registering on the PRS database replace a property licence?
The database operator allocates it when the entry is created. The format and whether a public lookup will exist are not yet published. See is the PRS database public?
Not sure which of your managed homes will be marketed into a licensing area next year?
The licence status of a home is the next question after its registration status. To check one address, use the free licensing checker.
