Service charge reforms now have start dates: the Commencement No. 4 Regulations, decoded

What was made, and when

The Leasehold and Freehold Reform Act 2024 (Commencement No. 4 and Saving Provision) (England) Regulations 2026 were made on 25 October 2026 and signed by Housing Minister Matthew Pennycook under section 124 of the 2024 Act (legislation.gov.uk, SI 2026/1128). It is the fourth commencement order under the Act. The first three switched on a handful of earlier measures, including the abolition of the two-year ownership rule for lease extensions and freehold purchases on 31 January 2025, and the right to manage reforms on 3 March 2025 (legislation.gov.uk, SI 2025/57; legislation.gov.uk, SI 2025/131).

This order is different in scale. It covers almost all of Part 4 of the Act, the service charge, insurance, administration charge and litigation costs package that the government confirmed in its 15 July 2026 consultation response (Government response, GOV.UK). We covered what that response decided in The service charge transparency reforms, decoded. This order is the timetable that turns it into law.

Two points before the detail.

A commencement order switches law on. It does not fill in the detail. Most of these sections say a landlord must use a "specified" form or provide "specified" information, meaning specified in regulations (Leasehold and Freehold Reform Act 2024, Part 4, legislation.gov.uk). Those regulations have not been published yet. The government has said there will be at least five, at least two of them under the affirmative procedure, which needs a vote in both Houses (Government response, GOV.UK).

The dates match what was promised in July. The government promised private landlords 12 months' notice for demands, accounts, annual reports, insurance and administration charges, and 24 months for social landlords. It promised future demand notices and information rights "as soon as possible in 2027", and a three-month lead-in for litigation costs once the regulations are made (Government response, GOV.UK; Anthony Collins Solicitors). Powers from 6 November 2026, private landlords from 1 November 2027 and social landlords from 1 November 2028 give exactly that 12 and 24 months. A 1 April 2027 start for litigation costs, with three months' lead-in, suggests the litigation costs regulations should be made by around the start of January 2027. That last point is our reading, not a published date.

The four dates at a glance

Date	What starts	Who it applies to	2024 Act sections
6 November 2026	Powers to make the detailed regulations	Government only	54 to 63 (regulation-making powers only), 68, Schedule 11 Part 1
1 April 2027	Fixed service charges brought in; prescribed future demand notice; right to information on request and tribunal enforcement; new litigation costs rules for proceedings issued from this date	All landlords	53, 54, 57, parts of 58, 62, 63, 69, 71
1 November 2027	Prescribed service charge demands; standard accounts and annual reports; tribunal enforcement for those	Private landlords, including RTM companies and RMCs	55, 56, 58
1 November 2027	Limits on insurance commissions; insurance disclosure duty; published administration charge schedules	All landlords, including social landlords	59, 60, 61
1 November 2028	Prescribed demands, accounts and annual reports	Social landlords	55, 56, 58

Source: SI 2026/1128, regulations 2 to 5, legislation.gov.uk.

6 November 2026: the regulation-making powers

Regulation 2 brings sections 54 to 63 into force "for the purposes of making regulations" (SI 2026/1128). Before this date, ministers had no legal power to make the forms and rules that the reforms depend on. From it, they can make regulations under the new sections of the Landlord and Tenant Act 1985 covering:

• the future demand notice (section 20B)
• service charge demands (section 21C)
• accounts, annual reports and the definition of a qualified accountant (sections 21D, 21E and 28)
• information on request (sections 21F and 21G)
• the definition of a "permitted insurance payment" (section 20G)
• insurance information duties (paragraphs 1A to 1C of the Schedule to the 1985 Act)
• the format of administration charge schedules (paragraph 4A of Schedule 11 to the Commonhold and Leasehold Reform Act 2002)
• litigation costs, in both directions (sections 20CA, 20CB and 30J of the 1985 Act, and paragraphs 5B and 5C of Schedule 11 to the 2002 Act)

Section 68 also starts on this date. It sets out how those regulations are approved in Parliament and confirms that the Secretary of State makes them for England and the Welsh Ministers for Wales (Leasehold and Freehold Reform Act 2024, section 68).

What changes for leaseholders on 6 November: nothing yet. This date starts the clock on the drafting.

1 April 2027: information, future demands and litigation costs

Fixed service charges come into the regime

Section 53 changes the definition of a service charge in the Landlord and Tenant Act 1985. The existing rules on reasonableness (section 19), major works consultation (section 20) and the 18-month rule (section 20B) are relabelled so they apply to "variable service charges". The new demand, information and insurance rules apply to service charges generally, including fixed ones (Leasehold and Freehold Reform Act 2024, section 53). Fixed service charges are common in retirement housing and some social and shared ownership leases. For those households, this is the first time much of the statutory information regime will reach them.

The prescribed future demand notice

Today, if a landlord wants to recover costs more than 18 months after they were incurred, it must have told the leaseholder in writing within those 18 months that the costs had been incurred and would be charged. There is no set form. From 1 April 2027, section 54 replaces that with a "future demand notice" in a prescribed form, containing prescribed information and served in a prescribed way (Leasehold and Freehold Reform Act 2024, section 54). The government has said it will include the estimated costs, the leaseholder's share, the expected demand date and a statement of rights (Government response, GOV.UK).

The Act allows ministers to limit what a landlord can recover if it later goes over its own estimate or misses its own date. The government has said it will not use that power for now (Anthony Collins Solicitors). So the notice gives leaseholders warning. It does not cap what they pay.

The right to information on request

Section 57 replaces the current rights to a summary of costs and to inspect supporting documents (sections 22, 23 and 24 of the 1985 Act) with a new right in sections 21F to 21H. A leaseholder, or a recognised tenants' association acting with their consent, can ask for any information on a prescribed list covering service charges and the services, repairs, maintenance, improvements, insurance and management of the building (Leasehold and Freehold Reform Act 2024, section 57).

The landlord must provide what it holds. If someone else holds it, for example a managing agent, a superior landlord or a broker, the landlord must ask them and they must provide it. The duty runs down the whole chain. Leaseholders can ask to inspect documents in person and take copies. Landlords cannot charge for inspection, but can charge for copies (Leasehold and Freehold Reform Act 2024, sections 21F and 21G). The government has said the list will reach back up to six years, with a sliding scale of response times and a 15-day limit for the landlord to ask a third party (Government response, GOV.UK).

Enforcement through the tribunal, not the criminal courts

The current rules are backed by a criminal offence under section 25 of the 1985 Act, which is rarely prosecuted. Section 58 replaces it with a tribunal route. From 1 April 2027, anyone who has made an information request that is not met can apply to the First-tier Tribunal. The tribunal can order the information to be provided within 14 days and award damages of up to £5,000 (Leasehold and Freehold Reform Act 2024, section 58).

Three protections attach to those damages. The landlord cannot set them off against anything the leaseholder owes. Paying them out of service charge funds held on trust is a breach of trust. And they cannot be added to anyone's service charge (Leasehold and Freehold Reform Act 2024, section 58).

On 1 April 2027, the order repeals section 25 except so far as it relates to section 21, the existing right to a summary of costs (SI 2026/1128, regulation 3(d)). Our reading is that the offence stays for that one duty until section 21 itself is repealed on 1 November 2027, or 1 November 2028 for social landlords.

Litigation costs: both directions, from 1 April 2027

Section 62 reverses the default on a landlord's legal costs. The landlord's costs of court or tribunal proceedings with a leaseholder are not recoverable through the service charge or as an administration charge unless the court or tribunal orders otherwise on the landlord's application. It can only do so if it considers it "just and equitable" (Leasehold and Freehold Reform Act 2024, section 62). For costs of enfranchisement and right to manage proceedings, no such order is available at all. That replaces today's system, in which the leaseholder has to apply under section 20C of the 1985 Act or paragraph 5A of Schedule 11 to the 2002 Act to stop the costs being passed on.

Section 63 gives leaseholders a matching right. They can apply for an order that the landlord pays some or all of their own litigation costs in a defined set of proceedings (Leasehold and Freehold Reform Act 2024, section 63). The government has said this will cover the main cases where a leaseholder defends enforcement action or brings a claim, including lease variation (Government response, GOV.UK).

The detail will sit in regulations still to be made: the threshold below which an administration charge for costs needs no approval, and the temporary suspension that lets resident-led companies and tribunal-appointed managers fund litigation from the service charge pending approval (Government response, GOV.UK).

The saving provision: proceedings issued before 1 April 2027

Regulation 6 is the "saving provision" in the title. The litigation costs changes in sections 62 and 63 "do not have effect" for proceedings issued before 1 April 2027 (SI 2026/1128, regulation 6). A case started before that date runs to the end under the old rules, including the existing section 20C and paragraph 5A applications. A case started on or after it gets the new regime.

That makes the issue date matter. A landlord with a dispute in prospect may prefer to issue before 1 April 2027. A leaseholder who wants to recover their own costs under section 63 will need proceedings issued on or after it. Anyone in that position should take legal advice on timing.

Existing leases are covered

Section 71 applies every section of Part 4 to leases "whether the lease was entered into before or after the section comes into force", and the order switches section 71 on alongside each measure (Leasehold and Freehold Reform Act 2024, section 71; SI 2026/1128). The rules do not depend on what your lease says. Section 69 also makes the 1985 Act's service charge provisions bind the Crown.

1 November 2027: demands, accounts, reports, insurance and admin charges

Prescribed service charge demands

From 1 November 2027, section 55 inserts a new section 21C into the 1985 Act. A landlord "may not demand" a service charge unless the demand is in the specified form, contains the specified information and is served in the specified way (Leasehold and Freehold Reform Act 2024, section 55). The government's plan is for three forms: an initial demand with a budget and a comparison against the previous year, an interim demand where amounts change during the year, and a reconciliation demand issued with the final accounts (Government response, GOV.UK).

The sanction is significant. If a demand does not comply, any lease provision "relating to non-payment or late payment" of service charges "does not have effect" for that charge (Leasehold and Freehold Reform Act 2024, section 55). In practice, late payment interest and arrears charges in the lease cannot be relied on against a non-compliant demand. The leaseholder can also apply to the tribunal for an order that a compliant demand be issued within 14 days, and for damages of up to £5,000 (Leasehold and Freehold Reform Act 2024, section 58).

Section 55 also repeals sections 21, 21A and 21B of the 1985 Act, including the current requirement to send the summary of rights and obligations with every demand. The prescribed form takes its place.

Standard accounts and the annual report

Section 56 inserts sections 21D and 21E. Where a variable service charge is shared with tenants of three or more other dwellings, the landlord must provide a statement of account in a prescribed form within six months of the end of each accounting period. It must come with a report by a qualified accountant, including a statement that the accounts are "a faithful representation of what it purports to represent" (Leasehold and Freehold Reform Act 2024, section 56). Where the lease does not set an accounting period, it runs from 1 April.

The annual report under section 21E is new. The government has said it will cover the building's condition, surveys, major works planned over the next two years, whether the reserve fund covers them, and declarations of relationships between the landlord and third parties (Government response, GOV.UK). Which accounting periods the first reports and accounts must cover will depend on transitional rules in the regulations.

Insurance: commissions limited, disclosure required

Section 59 is the part most likely to change commercial arrangements. From 1 November 2027, "excluded insurance costs" cannot be included in a variable service charge. These are costs of arranging or managing insurance, including commissions and other incentives, that are not a "permitted insurance payment" as defined in regulations (Leasehold and Freehold Reform Act 2024, section 59). Those regulations need approval by both Houses.

If a leaseholder pays a prohibited amount, the tribunal can order it returned. It can also order damages of at least the amount paid and up to three times it, against the landlord or anyone who benefited, such as a broker or managing agent (Leasehold and Freehold Reform Act 2024, section 59).

Section 60 adds a duty on landlords to obtain and provide prescribed insurance information within a set period after a policy is bought or renewed. Brokers and others must supply it to the landlord on request. Failure can lead to a tribunal order and damages of up to £5,000 (Leasehold and Freehold Reform Act 2024, section 60). Both insurance measures apply to social landlords from the same date.

Published administration charge schedules

Section 61 requires a landlord to produce and publish an administration charge schedule for each building, listing each charge it may make and either the amount or how it is worked out. An administration charge is only payable if it appeared on a published schedule throughout the 28 days ending on the day it is demanded. The tribunal can order compliance within 14 days and award damages of up to £1,000 (Leasehold and Freehold Reform Act 2024, section 61).

This is separate from the 29 September 2026 announcement of new powers to cap permission and administration fees, which needs new primary legislation (GOV.UK). Section 61 makes fees visible. The planned caps would limit how much they can be.

1 November 2028: social landlords

Demands, accounts, annual reports and their enforcement (sections 55, 56 and 58) start a year later for "social landlords" (SI 2026/1128, regulation 5). The order defines these as:

• private registered providers of social housing
• local housing authorities
• "joint venture landlords", meaning a landlord whose dwelling is managed by a social housing provider or its wholly-owned subsidiary under an arrangement with it

The joint venture definition matters for mixed-tenure schemes. Some privately owned freeholds where a housing association manages the building will be on the 2028 track, not 2027. The insurance and administration charge measures are not delayed for social landlords.

Who counts as a "landlord"

The order defines "landlord" to include "any person who has a right to enforce payment of a service charge" (SI 2026/1128, regulation 1). That catches freeholders, intermediate landlords, and RTM companies and resident management companies that demand service charges. RTM and RMC boards are duty-holders under this regime, on the private landlord timetable, not just beneficiaries of it.

What this order does not do

• It does not publish the forms. Every prescribed form, information list, deadline and exemption still has to be made in regulations.
• It does not commence sections 65 to 67. The tribunal's power to vary manager orders of its own motion, the new redress-scheme ground for appointing a manager, and leasehold sales information requests all remain uncommenced (legislation.gov.uk, sections 65 to 67).
• It does not touch section 20 major works consultation. The government deferred that to a separate response (Anthony Collins Solicitors).
• It does not cap service charges. This is a transparency and challenge regime, not price control.
• It does not apply in Wales. Welsh Ministers will make their own decisions (Government response, GOV.UK).
• It does not start the enfranchisement reforms. The 990-year extensions and the end of marriage value still wait on the valuation rates and the Commonhold and Leasehold Reform Bill. See Enfranchisement, explained.

What boards and managing agents should do, by date

Now to 31 March 2027

• Set up a request log that records the date of each request, the deadline and any third-party chasers. The 15-day third-party deadline will need tracking.
• Check you can retrieve six years of invoices, contracts, insurance documents, surveys and safety records.
• Ask your managing agent, broker and any superior landlord in writing how they will meet onward requests.
• If you are in, or expect, a dispute with a leaseholder or landlord, take advice on whether proceedings will be issued before or after 1 April 2027.

By 31 October 2027 (private landlords, including RTM companies and RMCs)

• Settle a stable set of budget headings so this year's figures can be compared with last year's.
• Engage an accountant who meets the new qualification rules, and agree the timetable for the six-month account deadline.
• Review every insurance commission, fee and incentive against the "permitted insurance payment" rules once they are published. Unwind anything that will not qualify.
• Draft and publish your administration charge schedule well before 1 November. Charges must have appeared on it for the 28 days before they are demanded.
• Collect leaseholders' consent to digital delivery, because post is the default.
• Get a written plan from your software supplier for the prescribed forms.

By 31 October 2028 (social landlords and joint venture landlords)

• The same demand, accounts and annual report preparation, with a further year to do it.

What to watch next

• The regulations. Watch for draft affirmative instruments on insurance and litigation cost exceptions, and the negative instruments on forms and information lists. Read them for the final forms, the administration charge litigation threshold, response times and exemptions.
• Transitional rules. Which accounting periods the first accounts and annual reports cover.
• The Commonhold and Leasehold Reform Bill. The Prime Minister has pledged to introduce it before Christmas 2026, carrying the fee caps and agent regulation announced on 29 September (Labour Party, conference speech).
• Wales. Whether the Welsh Government follows the same timetable.

We track every step on the Bill Tracker.

Frequently asked questions

When do the new service charge rules start in England?

They start in stages. Ministers can make the detailed regulations from 6 November 2026. Information requests, the future demand notice, fixed service charges and the new litigation costs rules start on 1 April 2027. Prescribed demands, standard accounts, annual reports, insurance commission limits and administration charge schedules start on 1 November 2027 for private landlords. Demands, accounts and annual reports start for social landlords on 1 November 2028.

Do RTM companies and resident management companies have to comply?

Yes. The order defines a landlord as anyone with a right to enforce payment of a service charge, which includes RTM companies and RMCs. They follow the private landlord timetable, so prescribed demands, accounts and annual reports apply to them from 1 November 2027.

Can my landlord still add its legal costs to my service charge?

For proceedings issued on or after 1 April 2027, only if a court or tribunal orders that it can, and never for enfranchisement or right to manage proceedings. Proceedings issued before 1 April 2027 stay under the old rules, where the leaseholder has to apply to stop the costs being passed on.

What happens if I get a service charge demand in the wrong format after 1 November 2027?

If your landlord is a private landlord, the lease's late payment and non-payment provisions do not apply to that charge. You can also apply to the First-tier Tribunal for an order that a compliant demand is issued within 14 days, and for damages of up to £5,000.

Have the new forms been published?

Not yet. SI 2026/1128 only sets the dates. The prescribed forms, information lists and detailed rules will be made in separate regulations, which the government can make from 6 November 2026.

Does this apply in Wales?

No. SI 2026/1128 applies to England only. The Welsh Government will decide its own approach and timetable.

Does this cap service charges?

No. These reforms are about transparency and the right to challenge. They do not limit how much a service charge can be. Separate plans to cap permission and administration fees were announced on 29 September 2026 and need new legislation.