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Last updated: 4 April 2026
Leaseholders & Directors

What does a managing agent actually do?

Most leaseholders pay thousands a year in service charges to a managing agent but have no clear picture of what that money covers. Most directors appoint one but have never benchmarked what "competent" looks like. The reality is that managing agents are responsible for an enormous amount of work across 145+ regulatory obligationsBuilding Trust compliance mapping across fire safety, health and safety, company law, leasehold law, data protection, and building safety. Count as of March 2026., often for fees that are at or below cost. The issue is rarely that they do too little. It is that nobody involved has a clear picture of what the job actually requires.

This guide is for general information only. It does not constitute legal advice. Building Trust is a property management technology platform, not a managing agent. Seek professional advice before acting.

The 8 areas What applies to your building? Key legislation Who carries the liability? Check your building
What good looks like

Eight areas a competent managing agent should cover

A managing agent is appointed by the freeholder, an RMC, or an RTM company to handle day-to-day management. They act on your behalf, but the legal responsibility for compliance still sits with the directors. The scope of work below is significant. Many leaseholders expect champagne service for prosecco prices, without knowing what the job actually involves. Equally, many directors have no way to tell whether their agent is meeting the standard or falling short. Both problems start in the same place: a lack of visibility.

1

Service charge administration

  • Prepare annual budgets and issue service charge demands to every leaseholder
  • Collect contributions, chase arrears, instruct solicitors for non-payment
  • Produce year-end accounts certified by a qualified accountantRequired under s.21 Landlord and Tenant Act 1985 where there are more than 4 flats, or costs relate to another building. Source (Landlord and Tenant Act 1985, s.21)
  • Hold service charge money in designated trust accountsRICS Service Charge Residential Management Code (4th ed., effective 7 April 2026) requires service charge funds to be held in trust. Exempt landlords (non-profit PRPs) follow separate rules. Source separate from the freeholder's own funds
  • Maintain a separate reserve or sinking fundReserve funds must be held in a separately designated trust account, not mixed with operating service charge funds. RICS Code 4th ed. and best practice guidance. Source account for major future expenditure
  • Administer ground rent collection and freeholder accounts for notices, consents, and covenant compliance
2

Section 20 major works consultation

  • Run the full statutory consultation process for any qualifying works exceeding £250S.20 Landlord and Tenant Act 1985, as amended by s.151 Commonhold and Leasehold Reform Act 2002. Threshold applies per leaseholder, not per building. Source per leaseholder
  • Consult on any qualifying long-term agreementAny contract for works or services lasting more than 12 months where any leaseholder's contribution exceeds £100 per year requires a separate consultation process. Service Charges (Consultation Requirements) (England) Regulations 2003. Source exceeding £100 per leaseholder per year (e.g. lift maintenance, cleaning, gardening contracts)
  • Issue Notice of Intention, obtain competitive tenders, issue Notice of Estimates, manage leaseholder observations within 30-day windows
  • Failure to consult limits recovery to £250 (works) or £100 (long-term agreements) per leaseholder, regardless of actual cost, unless the Tribunal grants dispensationFirst-tier Tribunal (Property Chamber) can dispense with consultation requirements under s.20ZA Landlord and Tenant Act 1985 if it considers it reasonable to do so. Source
3

Fire safety and Building Safety Act

  • Commission and maintain a current Fire Risk AssessmentRequired under the Regulatory Reform (Fire Safety) Order 2005 (Article 9). The 'Responsible Person' must make a suitable and sufficient assessment of the fire risks. Must be reviewed regularly and kept up to date. Source and implement all recommendations within stated timescales
  • Check communal fire doors at least every 3 monthsFire Safety (England) Regulations 2022, Regulation 10. Communal fire doors must be checked quarterly. Flat entrance doors must be checked at least every 12 months using best endeavours. Applies to buildings with 2+ sets of domestic premises above 11m in height. Source and flat entrance doors at least annually (Fire Safety (England) Regulations 2022)
  • Maintain emergency lighting, fire signage, and fire detection systems in communal areas
  • For higher-risk buildingsBuilding Safety Act 2022, Part 4. Higher-risk buildings are at least 18m in height OR have at least 7 storeys, AND contain at least 2 residential units. The Principal Accountable Person must register with the Building Safety Regulator. It is an offence to allow residents to occupy an unregistered higher-risk building. Source (at least 7 storeys or 18m, with 2+ residential units): register with the Building Safety Regulator and appoint an Accountable Person
4

Health and safety compliance

  • Annual gas safety inspectionsGas Safety (Installation and Use) Regulations 1998, Reg 36. Every gas appliance, flue, and installation pipework must be checked by a Gas Safe registered engineer at least every 12 months. Includes communal boilers and shared installations. Records must be kept for at least 2 years. Source for communal boilers and shared gas installations
  • 5-yearly electrical condition reportsElectrical Safety Standards in the Private Rented Sector (England) Regulations 2020 require an EICR at least every 5 years. Must meet BS 7671 (18th Edition Wiring Regulations). Remedial work must be completed within 28 days. Penalties of up to £30,000 for non-compliance. Source (EICR) for communal electrical installations
  • Asbestos management surveyControl of Asbestos Regulations 2012, Reg 4 ('Duty to manage'). Applies to communal areas of residential blocks: corridors, stairways, lifts, parking areas, bin stores, boiler rooms. Requires a management plan detailing steps to manage the risk. Source and management plan for all communal areas
  • Legionella risk assessmentHealth and Safety at Work Act 1974, HSE Approved Code of Practice L8. No fixed statutory frequency, but HSE recommends regular review, typically every 2 years. Communal water tanks require annual inspection. Source for communal water systems, reviewed regularly
  • Lift inspections every 6 monthsLifting Operations and Lifting Equipment Regulations 1998 (LOLER). Passenger lifts must be thoroughly examined at least every 6 months by a competent person. Falls under the Health and Safety at Work Act 1974. Source (LOLER 1998) and ongoing plant maintenance
5

Insurance

  • Arrange buildings insurance to full reinstatement value including property owners' liability
  • Review cover annually: terrorism, flood, subsidence, directors' and officers' liability
  • Manage claims from notification through to settlement
  • Disclose all commissions and remunerationLeasehold and Freehold Reform Act 2024 replaces insurance commissions with a regulated 'permitted insurance fee' based on work undertaken and time spent. Landlords must provide disclosure documents including policy features, premium, intermediary remuneration, and conflicts of interest. Targeted effective date: April 2026. Source to leaseholders (Leasehold and Freehold Reform Act 2024)
6

Building maintenance and repairs

  • Conduct regular building inspections and produce condition reports
  • Manage reactive repairs including 24/7 emergency response
  • Create planned preventative maintenance programmes with costed timelines
  • Tender works competitively, supervise contractors, sign off on completion
  • Develop and maintain a reserve fund strategy aligned to the building's long-term maintenance needs
7

Lease compliance and company governance

  • Monitor and enforce lease covenants: subletting, alterations, nuisance, pets
  • Issue and pursue breach notices under the lease
  • File annual confirmation statements and accounts with Companies House
  • Maintain statutory registers and convene AGMs (Companies Act 2006)
  • Administer Right to Manage transfers and enfranchisement processes
8

Communication and dispute resolution

  • Act as single point of contact for leaseholders, tenants, and contractors
  • Operate a formal complaints procedure and belong to an approved redress scheme
  • Mediate disputes between residents before they reach the First-tier Tribunal
  • Provide transparent reporting: meeting minutes, contractor invoices, insurance schedules
By building type

What applies to your building?

Not every obligation applies to every building. The rules change based on height, number of storeys, and number of residential units. This table shows which requirements kick in at each threshold. It is one of the main reasons people get confused.

Obligation Any block
2+ flats, any height
Above 11m
~4+ storeys
18m+ / 7+ storeys
Higher-risk building
Fire safety
Fire Risk AssessmentRegulatory Reform (Fire Safety) Order 2005, Article 9. The 'Responsible Person' must make a suitable and sufficient assessment of fire risks in communal areas. No height threshold. Must be reviewed regularly. Source Yes Yes Yes
Responsible Person dutiesFire Safety Order 2005, Article 3. The Responsible Person (typically the freeholder, RMC directors, or managing agent acting on their behalf) must take general fire precautions and ensure the safety of relevant persons. Applies to all buildings with communal areas. Source Yes Yes Yes
Fire safety information to residentsFire Safety (England) Regulations 2022, Reg 9. Responsible Person must provide fire safety instructions to all residents at least annually, including how to report a fire and evacuation procedures. Applies to all multi-occupied residential buildings. Source Yes Yes Yes
Quarterly communal fire door checksFire Safety (England) Regulations 2022, Reg 10. Communal fire doors must be checked at least every 3 months. Flat entrance doors checked annually (best endeavours). Applies to buildings above 11m with 2+ sets of domestic premises. Source Yes Yes
Annual flat entrance door checksFire Safety (England) Regulations 2022, Reg 10. Flat entrance doors that open onto communal areas must be checked at least every 12 months using best endeavours. Applies to buildings above 11m with 2+ sets of domestic premises. Source Yes Yes
Secure information boxFire Safety (England) Regulations 2022, Reg 4. High-rise residential buildings (18m+ or 7+ storeys) must install a secure information box accessible to the fire service, containing floor plans, building plans, and Responsible Person contact details. Source Yes
PEEPs for vulnerable residentsFire Safety (Residential Evacuation Plans) (England) Regulations 2025 (SI 2025/797), in force 6 April 2026. Person-centred fire risk assessments and evacuation plans for residents with mobility or cognitive impairments. Applies to 18m+/7+ storey buildings, and 11m+ buildings with simultaneous evacuation. Source Only if simultaneous evacuation Yes
Building Emergency Evacuation PlanFire Safety (Residential Evacuation Plans) (England) Regulations 2025 (SI 2025/797), in force 6 April 2026. A building-level evacuation plan that must be shared with the local Fire and Rescue Authority and placed in the secure information box. Reviewed annually. Same threshold as PEEPs. Source Only if simultaneous evacuation Yes
Building Safety Act 2022
Accountable PersonBuilding Safety Act 2022, Part 4, s.72. The Principal Accountable Person must register with the Building Safety Regulator, manage building safety risks, and engage with residents. Applies only to higher-risk buildings: 18m+ or 7+ storeys, with 2+ residential units. Source Yes
Register with Building Safety RegulatorBuilding Safety Act 2022, s.65. Higher-risk buildings must be registered with the BSR. It is a criminal offence to allow residents to occupy an unregistered higher-risk building. Registration opened April 2023, enforcement from April 2024. Source Yes
Building Assessment CertificateBuilding Safety Act 2022, ss.79-80. The BSR instructs the Principal Accountable Person to apply for a certificate every 5 years. Demonstrates compliance with building safety duties. Must include safety case report and resident engagement strategy. Source Yes
Leaseholder remediation protectionsBuilding Safety Act 2022, ss.116-122 and Schedule 8. Protects leaseholders from service charge recovery for 'relevant defects' (fire spread or structural collapse). Lower threshold than other BSA duties: applies to buildings over 11m or 5+ storeys with 2+ residential units. Includes full cladding cost exemption and non-cladding cost caps. Source Yes Yes
Health and safety
Annual gas safety inspectionGas Safety (Installation and Use) Regulations 1998, Reg 36. Communal boilers and shared gas installations must be checked by a Gas Safe registered engineer every 12 months. Records kept for 2 years. Penalties for non-compliance include unlimited fines and imprisonment. Source Yes Yes Yes
5-yearly EICRElectrical Safety Standards in the Private Rented Sector (England) Regulations 2020. Electrical Installation Condition Report required every 5 years for communal installations. Remedial work must be completed within 28 days. Penalties up to £30,000 for non-compliance. Source Yes Yes Yes
Asbestos duty to manageControl of Asbestos Regulations 2012, Reg 4. Duty holder must identify asbestos-containing materials in communal areas (corridors, stairways, lifts, bin stores, boiler rooms) and maintain a management plan. Survey required before any refurbishment or demolition work. Source Yes Yes Yes
Legionella risk assessmentHealth and Safety at Work Act 1974, HSE Approved Code of Practice L8. Required for communal water systems (tanks, showers, cooling towers). No fixed statutory frequency but HSE recommends review every 2 years. Communal water tanks require annual inspection. Source Yes Yes Yes
Lift inspections (6-monthly, LOLER)Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). Passenger lifts must be thoroughly examined by a competent person at least every 6 months. Falls under Health and Safety at Work Act 1974. Only applies where a lift is present. Source If lift present If lift present Yes
Leasehold and company law
Service charge rules (LTA 1985)Landlord and Tenant Act 1985, ss.18-30. Service charges must be reasonable (s.19), demands must include landlord name and address (s.47/48), and a summary of rights and obligations (s.21B). Costs over 18 months old are unrecoverable without notice (s.20B). Source Yes Yes Yes
S20 consultationLandlord and Tenant Act 1985, s.20, as amended by CLRA 2002. Two separate processes: qualifying works (£250/leaseholder threshold) and qualifying long-term agreements over 12 months (£100/leaseholder/year). Failure to consult caps recovery at the threshold amount. Source Yes Yes Yes
Insurance commission transparencyLeasehold and Freehold Reform Act 2024 replaces insurance commissions with a regulated 'permitted insurance fee' regime. Landlords must disclose policy features, premiums, intermediary remuneration, and conflicts of interest. Secondary legislation pending. Source Yes Yes Yes
Companies Act duties (RMC/RTM)Companies Act 2006. Directors of RMCs and RTM companies must file annual confirmation statements, maintain statutory registers, hold AGMs, and comply with director duties (ss.171-177). Late filing penalties from £150 to £1,500. Personal liability for directors who fail to comply. Source Yes Yes Yes

This table covers the most common statutory obligations. It is not exhaustive. Some obligations depend on building type (e.g. converted house vs purpose-built), tenure (freehold vs leasehold), and whether the building has specific features (communal boilers, water tanks, lifts). Always take professional advice for your specific building.

Key legislation

The legislation your managing agent navigates

A residential block of flats is subject to 145+ regulatory obligationsBuilding Trust compliance mapping across fire safety, health and safety, company law, leasehold law, data protection, and building safety. Count as of March 2026. across fire safety, health and safety, company law, leasehold law, data protection, and building safety. The table below covers the statutes most directly relevant to block management.

Legislation / Code Relevance to block management
Landlord and Tenant Act 1985 Service charge reasonableness (s.19), right to a summary of costs (s.21), right to inspect receipts (s.22), consultation requirements (s.20)
Commonhold and Leasehold Reform Act 2002 Right to Manage, section 20 consultation thresholds (£250 works, £100 long-term agreements)
Leasehold and Freehold Reform Act 2024 Insurance commission transparency, permitted fees regime, enhanced leaseholder rights
Regulatory Reform (Fire Safety) Order 2005 Fire risk assessment duty on the Responsible Person for communal areas
Fire Safety Act 2021 and Regulations 2022 Extended scope to structure, external walls, flat entrance doors. Quarterly communal fire door checks for buildings above 11m
Building Safety Act 2022 Building Safety Regulator, Accountable Person, resident engagement strategy for higher-risk buildings (7+ storeys or 18m+)
Health and Safety at Work Act 1974 General duty of care for communal areas. Underpins gas, electrical, asbestos, legionella, and lift safety obligations
Companies Act 2006 Director duties, statutory filing, AGMs, annual confirmation statements for RMCs and RTM companies
RICS Service Charge Code (4th ed.) Best practice standard for service charge management. Effective 7 April 2026. Approved by Secretary of State
Personal liability

The liability does not transfer with the appointment

Appointing a managing agent does not remove your legal obligations as a director. If the agent fails to commission a fire risk assessment, it is the directors of the RMC or RTM company who face prosecution under the Fire Safety Order. If they mishandle client money, it is the directors who answer to leaseholders at tribunal. The managing agent is a contractor. The directors are the duty holders.

This is why visibility matters. You need to know what your managing agent is doing, what they have missed, and whether their work actually meets the standard the law requires. Most directors do not find out until something goes wrong.

67% of leaseholdersEnglish Housing Survey 2023-2024. The survey did not include complaints to The Property Ombudsman and Property Redress Scheme. Source who complained about management of their property to their managing agent were not happy with the response. 78% of thoseEnglish Housing Survey 2023-2024, via LEASE Redress Insight Report. Leaseholders cited the process seeming too time-consuming, costly, or stressful. Source then chose not to escalate further. Most people give up before they get anywhere.

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