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RPL Update Report to RFB August 2025

Renfrewshire Council · 20 August 2025
Back to Regulatory Functions Board — 20 August 2025 and its agenda

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To:  Regulatory Functions Board
On:  20th August 2025
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Report by: Director of Finance and Resources
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Heading: Registration of Private Landlords: Applications refused under
Delegated Authority
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1. Summary 
1.1 The purpose of this report is to provide a further update to the Board in
relation to applications for landlord registration refused under powers
delegated to officers following the meeting of the Board on 18th August
2021. Previous updates were given to the Board at its meetings on 3rd
February, 8th June and 26th October, 2022, and 1st June 2023.
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2. Recommendations
2.1  It is recommended that the Board note the contents of the report.
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3. Background
3.1  On 18th August 2021, the Board considered a report by the Director of
Finance and Resources relative to outstanding applications for private
landlord registration where landlords had not confirmed their compliance
with regulatory requirements set out in regulations made under the terms
of the Antisocial Behaviour etc. (Scotland) Act 2004 (“the 2004 Act”). The
report set out options to facilitate determination of these applications.

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3.2 The Board agreed that it be recommended that the Scheme of Delegated
Functions be amended to include a delegation to officers to refuse
applications for landlord registration where the requirements set out in
regulations made under the 2004 Act, and detailed at Paragraph 3.3 of
the report considered at the above meeting, are not met, subject to
regular reports being submitted to the Board detailing the applications
refused. This delegation subsequently came into effect after the meeting
of Council on 30th September 2021, when the Minute of the Board’s
meeting of 18th August 2021 was approved.
3.3 In the report of 18th August 2021, officers indicated that it was anticipated
that any power delegated to officers would not be used until two
communications had been issued to applicants allowing them an
opportunity to demonstrate their compliance.  Accordingly, the practice
adopted by officers has been to issue two separate letters to non-
compliant landlords, allowing them periods of 28 days and, thereafter, a
further 14 days to confirm their compliance.
3.4 Similar to the position at the time of the previous reports, the majority of
landlords written to since the last update to the Board were able to
confirm compliance within the above periods, allowing their applications
for landlord registration to be granted. Although non-compliance is still
being declared on a significant number of applications for landlord
registration, the number of applications able to be resolved in response
to the above correspondence has improved.
3.5 Following the previous update to the Board in June 2023, no further
applications were refused by officers during 2023 and none were refused
in 2024. However, during 2025 to the present date, eight applications
have been refused by officers due to failure to confirm full compliance
with landlords’ legal responsibilities. 
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Implications of the Report 
1. Financial – Nil 
2. HR & Organisational Development – Nil 
3. Community/ Council Planning – Nil 
4. Legal – as detailed in the report

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5. Property/Assets – Nil 
6. Information Technology – Nil
7. Equality & Human Rights - 
The Recommendations contained within this report have been assessed
in relation to their impact on equalities and human rights.  No negative
impacts on equality groups or potential for infringement of individuals’
human rights have been identified arising from the recommendations
contained in the report, as the report only provides the Board with an
update on refused applications for landlord registration as previously
requested by the Board. 
8. Health & Safety - Nil
9. Procurement – Nil
10. Risk - Nil
11. Privacy Impact – Nil
12. Climate Risk- Nil
13. Children’s Rights- the recommendations in the report are not
considered to be incompatible with the UNCRC
14. Cosla Policy Position – Nil
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List of Background Papers- None. 
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Author:           Douglas Campbell, Managing Solicitor (Licensing), 0141-487-1096,
douglas.campbell@renfrewshire.gov.uk