Tenant Fees Act in 2026: which letting journey is still asking for the wrong payment?

A tenancy can be lost before it begins because one email, portal field or payment request uses yesterday’s process. The Tenant Fees Act 2019 banned most tenant-paid letting fees in England and limited holding and tenancy deposits. Since 1 May 2026, the Renters’ Rights reforms have also changed when rent in advance can be requested and accepted. That means a policy written in 2019 is no longer enough: the website, application form, referencing script, tenancy agreement, payment link and staff decision must all tell the same current story. The first commercial opportunity is a one-journey payment audit that follows a prospective tenant from advert to signed tenancy and tests every request for money. This reading explains how a letting, compliance or property-operations specialist can package that decision, protect legitimate revenue without inventing tenant charges, control holding-deposit deadlines and build recurring assurance across branches, agents and software without promising that an audit replaces legal advice or enforcement judgement.

The Tenant Fees Act prohibits landlords and letting agents in England from requiring payments connected with a covered tenancy unless the payment is expressly permitted. A service may be useful, but that does not make it chargeable to the tenant. The real test is what the person must pay, purchase or enter into to secure or continue the tenancy.

The review therefore includes third-party contracts, deposit alternatives, insurance, reference services and portal wording—not only amounts labelled “fee”. Optional products must be genuinely optional and separated from access to the home.

Permitted payments include rent within the current timing rules, capped refundable tenancy and holding deposits, certain tenant-requested changes or early termination costs, specified utilities and limited default payments. Each category has conditions and evidence. A permitted label cannot rescue an inflated, premature or unrelated charge.

A paid audit should reconstruct one current letting journey, inventory every monetary request, test the legal and operational basis, identify inconsistent documents and issue a correction plan with owners. It should finish with approved wording, payment timing, refund decisions and staff escalation—not a generic compliance checklist stored away from the live process.

The first purchase can cover one branch, brand or software configuration in ten working days. Complex tenancy scope or disputed entitlement is escalated to qualified legal advice rather than concealed inside a traffic-light score. The close-out should show which request must stop immediately, which wording needs clarification and which permitted payment requires stronger evidence.

A holding deposit should be capped at one week’s rent for the tenancy, with only one active holding deposit accepted at a time. The process needs a documented agreement deadline, refund route and written reason where retention is lawful. Staff must distinguish tenant withdrawal or material false information from ordinary administrative delay.

The control should start the clock automatically, block duplicate collection and preserve the evidence used for the decision. A refund can be applied to rent or the tenancy deposit only with the tenant’s agreement and at the permitted stage.

Branch teams also need a route for borderline cases. Where a reference is delayed, information is corrected or several applicants share one tenancy, staff should not improvise retention rules under sales pressure. The escalation record should capture the facts, decision-maker, deadline and tenant communication.

For assured periodic tenancies covered by the new rules, a landlord or agent cannot request, encourage or accept rent before the tenancy agreement is signed. After signature and before the tenancy starts, the required advance payment is limited by the current rules; the tenant may later choose to pay early, but cannot be compelled through the agreement.

This affects application scripts, affordability workarounds and automated payment links. A prospective tenant offering several months upfront does not automatically authorise the agent to accept it before the permitted point.

The payment provider should enforce the same sequence as the tenancy platform. If a payment link can be issued before both parties sign, policy and technology disagree. Testing should include mobile journeys, partner referrals and manual links sent outside the main workflow.

Hidden risk appears when application portals make an optional product mandatory, staff reuse old templates, branches configure different deposit amounts, payment providers trigger too early or referral partners present their service as a condition. The audit must test the tenant’s actual screen and conversation, not rely only on head-office policy.

Mystery-path testing and transaction sampling reveal what a tenant experiences. The correction may involve software configuration, supplier terms, training or removal of a revenue-sharing mechanic that cannot be separated from the tenancy.

The sustainable model charges landlords for clearly defined letting and management value, improves operational efficiency and sells optional tenant services without coercion. It does not hide the former tenant fee in rent, a compulsory third-party product or an inflated permitted payment. Margin redesign should begin with cost-to-serve and service value.

Buying intent rises after a software migration, branch acquisition, complaint, enforcement contact, deposit dispute or failed mystery shop, and before a new tenancy-process rollout. The 2026 rent-in-advance change is another concrete trigger. Broad fear about fines is weaker than evidence that live customer journeys disagree.

Channels can include property-software partners, deposit schemes, landlord networks, direct branch research, targeted calls, workshops and search. Qualification confirms transaction access, an operational sponsor and authority to change scripts or systems.

The recurring service samples applications and payment events, monitors holding-deposit decisions, checks supplier and software changes, refreshes approved wording and investigates complaints. Its cadence follows transaction volume and change. It earns a fee by keeping the live journey aligned, not by resending the same policy each quarter.

The campaign is ready when the partner can inspect a real tenant journey, distinguish permitted payment from legal advice and implement corrections across people, suppliers and software. GetFishNet’s free eligibility test checks the addressable agent cohort, buying trigger, first-purchase value and recurring assurance capacity before channels are activated.

The strongest proposition is operational: show the agent exactly where the wrong request enters the journey, then replace it with a process that protects the tenant and preserves legitimate landlord-paid value.

Authorities cited: UK Legislation; Ministry of Housing, Communities and Local Government; local enforcement authorities. Dated references remain in the private source register.