Leaseholders
Your Rights Service Charges Lease Extension Enfranchisement
Directors
Compliance Obligations RTM Director Responsibilities Compliance Audit
Products
LEASE-iQ BLOCK-iQ Pricing FAQ Try LEASE-iQ free →
Directors & RTM

RTM director responsibilities.
Most directors don't know all 21.

You took on the role to help your building. You didn't sign up for personal legal liability across building safety, service charge law, and Companies Act duties. But that is what you carry. This guide covers what the law actually requires of you.

Companies Act 2006 LTA 1985 Fire Safety Order 2005 Building Safety Act 2022 Health & Safety at Work Act 1974
Personal liability

You cannot delegate your liability away

Most RTM and share-of-freehold directors believe their limited company protects them personally. In most compliance contexts, it does not. Where a director has personally acted in breach of statutory duty, or where the company itself fails a statutory obligation, the consequences fall on those who were responsible — which is you.

There are approximately 8,925 RTM companiesAs of early 2026, Companies House records approximately 8,925 active RTM companies registered in England and Wales. Companies House registered in England and Wales. The directors of those companies — typically unpaid leaseholders doing this on top of their day jobs — collectively carry responsibility for their buildings' compliance with legislation that has grown significantly in scope since the Grenfell Tower fireThe Grenfell Tower fire of June 2017 led to the Building Safety Act 2022, the Fire Safety (England) Regulations 2022, and significantly strengthened obligations on building owners and managers. GOV.UK and the Building Safety Act 2022.

Ignorance is not a legal defence. A director who did not know about their s.20 consultationSection 20 of the Landlord and Tenant Act 1985 (as amended by the CLRA 2002) requires landlords and RTM companies to consult leaseholders before qualifying works costing more than £250 per leaseholder or long-term agreements above £100 per year. Failure limits recoverable costs to £250. Legislation.gov.uk obligations can still find service charge demands rendered unenforceable and costs personally irrecoverable.

Companies Act 2006

Your duties as a company director

These duties apply to every director of every private limited company — including RTM and freehold companies. They are personal duties that cannot be contracted out.

Duty Source What it means in practice
Act within your powers CA 2006, s.171 Only take actions the company's articles of association allow. RTM companies have a specific statutory purpose — managing the building — and cannot act outside it.
Promote the success of the company CA 2006, s.172 Act in good faith in the interests of all members (leaseholders). Decisions that benefit some leaseholders at the expense of others may breach this duty.
Exercise independent judgement CA 2006, s.173 You remain personally responsible for decisions even when you rely on advisers. Delegating to a managing agent does not transfer your responsibility.
Exercise reasonable care, skill and diligence CA 2006, s.174 You are expected to apply the care and skill that a reasonably diligent person with your knowledge would apply. Not knowing about a legal obligation can still constitute a breach.
Avoid conflicts of interest CA 2006, s.175 If you or a connected person benefits from a decision (e.g. awarding a contract to a relative's business), this must be declared and managed carefully.
File accounts and confirmation statement CA 2006, s.394–396, s.853 Annual accounts and confirmation statement must be filed at Companies House on time every year. Late filing triggers automatic financial penalties. Persistent failure can result in the company being struck off.
The full picture

21 statutory obligations. All personal. Most directors don't know them all.

These are the core compliance obligations that BLOCK-iQ tracks for RTM and SoF buildings. Red = immediate safety/legal risk. Amber = significant financial or legal risk. Green = ongoing statutory requirement.

This is a guide only, not legal advice. Obligations vary by building type, height, and lease terms. Always seek professional advice for your specific situation.

01
Fire Risk Assessment
Fire Safety Order 2005, Art. 9
A competent person must carry out and regularly review a fire risk assessment. For buildings with floors above 11m, annual review is required. Records must be kept and shared with residents on request.
Personal criminal liability
02
Buildings Insurance
LTA 1985, s.30A; lease terms
The RTM or freehold company must maintain adequate buildings insurance as required by the lease. Directors who allow insurance to lapse or fail to maintain reinstatement cover face personal exposure.
Critical
03
Section 20 Major Works Consultation
LTA 1985, s.20; CLRA 2002
Before any works where any single leaseholder's share exceeds £250, a three-stage statutory consultation must be completed. Failure means costs above £250 per leaseholder are unrecoverable from service charge.
Financial risk
04
Service Charge Demands — s.21B
LTA 1985, s.21B
Every service charge demand must be accompanied by a prescribed summary of leaseholders' rights and obligations. Without it, the leaseholder is not obliged to pay and cannot be pursued for the sum.
Demand unenforceable
05
Landlord Name and Address — s.47/48
LTA 1987, s.47–48
Every demand must include the landlord's (or RTM company's) name and an address for service in England or Wales. Without this, the demand is not enforceable.
Demand unenforceable
06
18-Month Rule — s.20B
LTA 1985, s.20B
Costs incurred more than 18 months before a demand is issued cannot be recovered through service charge unless leaseholders were notified that costs had been incurred. Late demands lose the money.
Costs unrecoverable
07
Gas Safety Inspection
Gas Safety (Installation and Use) Regs 1998
Annual inspection of all communal gas appliances and installations by a Gas Safe registered engineer. A Gas Safety Record must be issued and retained. Failure is a criminal offence.
Criminal offence
08
Electrical Installation Condition Report (EICR)
BS 7671; Electricity at Work Regs 1989
Communal electrical installations must be inspected and tested by a qualified electrician. Recommended every 5 years for residential buildings. Must be remediated promptly where faults are found.
Safety risk
09
Asbestos Management Survey
Control of Asbestos Regulations 2012, Reg. 4
Buildings constructed before 2000 must have an asbestos management survey. The register must be maintained, reviewed, and made available to anyone who may disturb asbestos-containing materials.
Duty to manage
10
Legionella Risk Assessment
HSE ACoP L8; HSWA 1974
Buildings with communal water systems must have a Legionella risk assessment and written control scheme. Regular monitoring of water temperatures and records must be maintained.
Health and safety
11
Lift Inspection and Thorough Examination
LOLER 1998; PUWER 1998
Passenger lifts must be thoroughly examined every 6 months by a competent person. Defects must be reported immediately. No lift should be operated where it presents a danger.
Safety critical
12
Companies House — Annual Confirmation Statement
CA 2006, s.853
Filed annually at Companies House confirming or updating the company's registered details. Late filing results in automatic financial penalties. Failure to file is a criminal offence for directors.
Annual filing
13
Companies House — Annual Accounts
CA 2006, s.394–396
Annual accounts must be prepared and filed within 9 months of the year end for private companies. Dormant company accounts are simpler but must still be filed. Persistent failure leads to strike-off.
Annual filing
14
Fire Door Inspections
Fire Safety (England) Regs 2022
For buildings with floors above 11m, fire doors to individual flats must be checked every 3 months. Fire doors in communal areas must be checked monthly. Records must be maintained.
Post-Grenfell duty
15
Resident Engagement — Fire Safety Information
Fire Safety (England) Regs 2022
For buildings with floors above 11m, residents must be provided with fire safety instructions annually and when there are significant changes. Instructions must cover evacuation strategy.
Post-Grenfell duty
16
Emergency Lighting
BS 5266; Fire Safety Order 2005
Communal escape routes must be lit by emergency lighting that operates in a power failure. Monthly functional tests and annual full-duration tests must be carried out and recorded.
Regular testing
17
Fire Alarm System Servicing
BS 5839; Fire Safety Order 2005
Communal fire detection and alarm systems must be serviced by a competent person at least twice a year. Weekly tests and daily visual checks must also be carried out.
Twice yearly
18
Service Charge Reserve Fund (Sinking Fund)
LTA 1985, s.19; lease terms
Service charges must be reasonable and only used for purposes permitted by the lease. Reserve fund contributions must be held in a designated account (trust account) and accounted for separately.
Financial compliance
19
Dispensation from s.20 Consultation
LTA 1985, s.20ZA
Where urgent works are required and there is insufficient time to complete full consultation, a dispensation can be applied for at the First-tier Tribunal. This must be done proactively — not retrospectively after costs are challenged.
Emergency works
20
Right to Manage — Ongoing Statutory Notices
CLRA 2002, s.112–113
The RTM company must give notice to the landlord when it acquires functions, manages accounts, and when it ceases to be an RTM company. Certain management functions revert to the landlord on insolvency or dissolution.
RTM-specific
21
Building Safety Obligations (Higher-Risk Buildings)
Building Safety Act 2022
For residential buildings above 18 metres (or 7 storeys), the Principal Accountable Person must register the building, appoint a Building Safety Manager, produce a Safety Case Report, and maintain a Golden Thread of information. Severe penalties apply.
18m+ buildings

BLOCK-iQ tracks all 21 for you

Most directors are managing these obligations across spreadsheets, email threads, and calendar reminders. BLOCK-iQ replaces that with a single compliance dashboard — every obligation, every deadline, every document in one place. Built by a director, for directors.

21 compliance cards RAG status on every obligation Document storage Service charge demand builder Section 20 tracking Free pilot — no setup fees
See BLOCK-iQ →
Common questions

RTM director responsibilities — answered

Can an RTM director be personally sued?

Yes, in certain circumstances. The RTM company's limited liability does not protect directors who personally breach their statutory duties under the Companies Act 2006, or where health and safety failings lead to prosecution. Service charge procedural failures — such as missing the s.21B summary of rights — can render demands unenforceable, leaving the company and its directors exposed. Directors and officers insurance (D&O) is strongly recommended for all RTM and freehold company directors.

What is the difference between an RTM company and a share of freehold?

An RTM company takes over management of a building without purchasing the freehold — the landlord retains ownership. A share of freehold means leaseholders collectively own the freehold, usually through a freehold company. In both cases, the directors carry similar compliance obligations. The key difference is that SoF directors are also the freeholders, which adds obligations around ground rent, lease extensions, and enfranchisement that RTM directors do not have.

Does our RTM company need to file accounts at Companies House even if it makes no profit?

Yes. All private limited companies must file annual accounts and a confirmation statement regardless of whether they are trading, dormant, or making a profit. Dormant companies can file simplified accounts, but the filing obligation remains. Failure to file results in automatic financial penalties and, if persistent, the company being struck off the register — which can mean the RTM ceases to exist and management reverts to the landlord.

What happens if we carry out major works without Section 20 consultation?

If qualifying works are carried out without completing the three-stage s.20 consultation, the amount recoverable from each leaseholder through service charge is capped at £250 — regardless of how much the works actually cost. For a 16-unit building spending £80,000 on works, this could mean you can only recover £4,000 from leaseholders rather than £80,000. The RTM company would be liable for the shortfall. Emergency works are exempt if a dispensation application is made to the First-tier Tribunal.

Stay ahead of compliance changes

Monthly digest: legislation updates, compliance deadlines, and practical guidance for directors running their own buildings.

No spam. Unsubscribe anytime. Join directors from Hafer Road and others already using Building Trust.