Purpose-Built Student Accommodation (PBSAs) and the Transition Period
The student accommodation sector has been of particular interest throughout the Bill’s progression because of its unique operating model. The Government’s intention from the outset has been to exempt PBSA providers from the core provisions of the Bill. However, defining what constitutes a PBSA for exemption purposes and navigating a potential transition period has been a source of ongoing discussion.
The scope of the PBSA exemption has been widened. Crucially, the exemption, which hinges on membership of a Government-approved code of practice (such as ANUK/Unipol and UUK), will now apply not only where the landlord is a member but also where they have appointed a managing agent who is a member. This extension benefits smaller, non-member landlords by providing a pathway to exemption through professional management.
While the Lords recognised concerns about the transition period for existing PBSA tenancies, they concluded that retrospective application of the exemption would risk diminishing students’ existing tenancy rights. Therefore, PBSA providers must plan for this transition, understanding that relevant tenants will, among other things, be able to terminate their tenancy on two months’ notice.
In recognition of PBSA providers’ need to guarantee vacant possession, Possession Ground 4A has been significantly extended. Previously limited to HMOs and specific timeframes, this ground will now apply to all properties. Remove the July to September time frame limitation and the prohibition on its use where the tenancy was signed more than six months before commencement.
These sector-specific changes highlight the Government’s attempt to strike a balance between providing broad tenant protections and acknowledging the distinct operational requirements of specialist housing sectors like student accommodation.