Rent Repayment Order Time Limit

Miss the deadline and an otherwise strong claim is worth nothing. The limit itself is simple. Working out the date it runs from is the part that catches people.

The limit

The Renters’ Rights Act 2025 doubled both. Which regime applies to you depends on when the offence was committed — not when you found out about it, and not when you moved out.

When does the clock start?

This is the real question. A licensing offence under section 72(1) of the Housing Act 2004 is a continuing offence: it is committed on every day the property is unlicensed and required to be licensed. So there is not one offence date but a run of them.

The practical consequence is that the clock runs from the last day the offence was being committed, which is usually whichever of these came first:

• the day your tenancy ended;
• the day the landlord obtained a licence;
• the day the landlord duly applied for one;
• the day the property stopped being an HMO, or stopped needing a licence;
• the day the landlord sold the property.

You are then looking back from that date across the relevant period to work out what you can claim.

A worked example

You rented an unlicensed HMO from 1 June 2025 and moved out on 31 May 2027. Your landlord never licensed it.

• The offence continued throughout, ending 31 May 2027.
• Because it was still being committed after 1 May 2026, the new limits are in play for that part of the period.
• Your deadline runs from the end of the offence, not from the start of your tenancy.

The overlap between the old and new regimes is genuinely fiddly, and it is one of the things worth having checked rather than guessed.

Reasonable excuse can stop the clock

The Upper Tribunal has held that a period during which the landlord had a reasonable excuse for managing the property unlicensed does not count towards the statutory window.

That cuts both ways. It can mean a landlord is not liable for a stretch you assumed was claimable — but it can also mean you are still in time when a simple calendar count suggests you are not. If you have been told you are out of time, it is worth a second look.

Other offences

For illegal eviction, harassment or violence to secure entry, the offence is usually a single identifiable event rather than a continuing state of affairs. The clock runs from the date of the incident, which makes the deadline easier to calculate but easier to miss — people often spend months dealing with the immediate crisis before they think about a claim.

What to do if you are close to the limit

1. Apply. An application that is issued in time protects your position. Evidence can be filed under the tribunal’s directions afterwards.
2. Use your best evidence of the dates you have — the tenancy agreement, your first and last rent payments.
3. Do not wait for the council to finish an investigation. Their timetable is not yours.
4. Do not wait to move out. Former and current tenants can both apply.

Common misunderstandings

• “The clock starts when I found out.” No — it runs from the offence. Not knowing does not extend it.
• “I have to move out first.” No. You can apply while still living there.
• “My tenancy ended years ago, so that’s that.” Check the dates properly before accepting it. If the offence ran until your tenancy ended, and that was within the limit, you are in time.
• “The landlord has licensed it now, so it’s too late.” The opposite — the date they licensed it is often exactly when the offence stopped, and your clock started.

This article is general information about the law in England and is not legal advice about your own circumstances. Time limits are strict and their application depends on the facts of each case. The rules differ in Wales, Scotland and Northern Ireland.