The convergence, divergence and changing geography of regulation in the UK's private rented sector

The role of the private rented sector (PRS) has grown in many parts of Europe in recent years, both as an increasing component of housing systems and as the effects of the global financial crisis become apparent. In the UK, the role of the sector has deepened and is increasingly relied upon to house growing and diverse proportions of the population for longer periods of time. This has renewed interest in the regulation of the sector in order to improve its suitability and desirability for tenants. There has been increasing convergence in regulatory approaches between some jurisdictions of the UK, such as Scotland and Wales, and divergence between others, such as England where regulation remains a residual policy concern. Using examples of tenure security, landlord regulation and affordability, this policy review seeks to highlight the emerging differences in the way the PRS is regulated within the UK. It argues that the likely consequence of these differences is that there may be increased variation in the effects and experience of renting in the PRS, in relation to eviction protections and landlord management standards. The paper shows how jurisdictions in Scotland, and to a lesser extent Wales and Northern Ireland, are moving towards models of regulation that more closely mirror those used in Western European countries, with England becoming an outlier in the way in which it regulates private renting.