Cross-Council Enforcement: Sharing Intelligence

Rogue landlords frequently operate across multiple local authority areas. A landlord who receives a civil penalty in one borough can continue operating unchecked in the next. A managing agent based in one area may manage properties in five others. Until now, the siloed nature of local authority enforcement has been one of the private rented sector's biggest regulatory weaknesses. The Renters' Rights Act 2025 and the PRS Database begin to address this by creating a national register with enforcement history. But technology alone is not sufficient. Effective cross-council enforcement requires formal collaboration arrangements, data sharing agreements, and a culture of cooperation that many authorities have not yet developed.

Several models for cross-council enforcement collaboration are in use across England: 1. Informal intelligence sharing: The simplest model. Officers in neighbouring authorities share information about specific landlords or properties on an ad hoc basis, usually by phone or email. Effective for individual cases but unsystematic. 2. Regional enforcement groups: Regular meetings (monthly or quarterly) of enforcement managers from authorities in a region. These groups share intelligence, discuss common challenges, and coordinate on cross-boundary landlords. Examples include London borough housing groups and county-wide environmental health partnerships. 3. Shared service arrangements: Two or more authorities formally share enforcement staff, systems, or legal capacity. This provides specialist capability that individual authorities cannot afford alone and is particularly suited to rural areas. 4. Joint enforcement operations: Coordinated enforcement activity targeting a specific landlord, agent, or area across multiple authority boundaries. These require careful planning and legal agreements but can be highly effective. 5. Sub-regional enforcement hubs: A dedicated enforcement team serving multiple authorities, funded through pooled resources or external grants. The Mayor of London's Rogue Landlord and Agent Checker is a London-wide example of shared infrastructure.

Sharing enforcement data between councils requires a sound legal basis. The key frameworks are: GDPR Article 6(1)(e): Processing is necessary for the performance of a task carried out in the public interest. Housing enforcement is a clear public interest task, supporting lawful data sharing between councils for this purpose. Digital Economy Act 2017 (Part 5): Provides explicit legal gateways for data sharing between public authorities to improve public services. Housing enforcement falls within the "better targeting of resources" objective. Section 17 of the Crime and Disorder Act 1998: Places a duty on local authorities to consider crime and disorder implications. Sharing intelligence about criminal landlords supports this duty. The Rogue Landlord Database (Housing and Planning Act 2016): Provides a statutory framework for sharing specific enforcement information nationally. Councils must enter banning orders and may enter other enforcement outcomes. In practice, formal data sharing agreements should be established between participating councils. These agreements should specify: - What data will be shared - The legal basis for sharing - Who can access shared data - How data will be stored and protected - Retention periods - Responsibilities of each party Template data sharing agreements are available from the Local Government Association and regional groups.

Effective intelligence sharing focuses on actionable information: Landlord portfolios: When a council identifies a problematic landlord, sharing their name and property addresses with neighbouring authorities enables those councils to check their own records for properties under the same ownership. Managing agent intelligence: Agents often operate across wide areas. Sharing concerns about a specific agent's compliance record helps multiple councils identify whether failures are systemic. Enforcement outcomes: Sharing civil penalty decisions, prosecution outcomes, and tribunal results helps other councils calibrate their own enforcement and provides evidence for fit and proper person assessments. Trend data: Sharing anonymised trend data (complaint volumes, common hazard types, licensing compliance rates) helps all parties understand the regional PRS picture and plan resources. The PRS Database will automate much of this sharing from late 2026, but it will not replace the need for operational collaboration. A national database shows what is recorded; local intelligence sharing reveals what is not yet recorded but should be.

Starting a cross-council collaboration does not require permission or formal structures. Practical first steps: 1. Identify your neighbours' enforcement leads: A simple phone call or email to introduce yourself and suggest a meeting. Most officers welcome the opportunity to share knowledge. 2. Attend or establish a regional group: If no regional housing enforcement group exists, create one. Even a quarterly video call with three or four neighbouring authorities is valuable. 3. Share one case: Start with a single landlord or agent who operates across boundaries. The practical experience of working a joint case reveals where formal agreements are needed. 4. Draft a data sharing agreement: Use an LGA template. This does not need to be complex. A signed agreement gives officers confidence to share information. 5. Coordinate with the PRS Database launch: As the late 2026 launch approaches, cross-council groups can prepare together for data matching, enforcement prioritisation, and shared training. The £18.2 million enforcement fund can support collaboration activities. Councils that can demonstrate cross-boundary working are likely to be viewed favourably for future funding allocations.