Clarification needed on RRA 2025 compliance in standard APT contract (Pets, Guarantors, Ground 4A)

Landlord Discussion Legal
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Hi everyone,

I am preparing to use the OpenRent Assured Periodic Tenancy (APT) agreement for a new tenancy following the May 1, 2026 rollout of the Renters’ Rights Act 2025. While reviewing the sample contract, I noticed a few specific clauses that appear to conflict with the finalised legislation. I wanted to flag these to see if OpenRent plans to update the template or if landlords should be manually removing these to stay compliant.

Here are the three specific issues I found:

1. Pet Damage Insurance (Clause 9.30)
The current template states: “Where the Landlord consents to the Tenant keeping a pet, the Tenant may be required to obtain and maintain pet damage insurance if reasonably requested by the Landlord.”
While the government originally proposed allowing landlords to demand pet insurance, this was removed from the final version of the Act. Therefore, requiring a tenant to take out pet insurance is now classed as a banned fee under the Tenant Fees Act 2019, and landlords attempting to charge or mandate this could face financial penalties of up to £7,000.

2. Guarantor Liability After a Tenant’s Death (Clause 15)
The guarantee section seems to imply that liability continues indefinitely. However, Section 19 of the Renters’ Rights Act 2025 (which inserts Section 16N into the Housing Act 1988) explicitly states that a family guarantor is no longer liable for rent payable after a tenant’s death. Shouldn’t the guarantor deed explicitly acknowledge this statutory release to ensure the terms aren’t deemed unfair under the Consumer Rights Act?

3. Student Tenancy Notice – Ground 4A (Clause 13.6)
The contract includes a boilerplate notice stating the landlord may seek possession under Ground 4A. However, Ground 4A can only legally be used if the property is a House in Multiple Occupation (HMO), which requires at least three unrelated tenants living there. For landlords renting to only one or two students, the property does not qualify as an HMO, making Ground 4A entirely inaccessible. Leaving this in a contract for a 2-person let asserts an eviction right that doesn’t legally exist.

Are other landlords manually deleting/editing these clauses using the custom clauses feature, or is there a planned update for the boilerplate text to reflect the final enacted law?

Any advice or clarification from the OpenRent team would be greatly appreciated!

Rentnow option with customised agreement in line with RRA? PDF copy of contract download option
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@Suranjith

thanks for sharing

Adding @Dan4 from OR’s legal team and @mod_emma and @mod_harry to see request for advice from OR

Point 1 pets
I think agree a little suspect but isnt actually a breach of the act as it’s only saying ‘may’ be required not that it is - thus leaving it up to the LL - if a LL did actually require it that would be down to them. Arguably keeping it in may prompt some tenants to volunteer to get pet insurance. It’s like the ‘No pets’ indication on adverts - not what pet owners like but not illegal either.

However agree there’s a case to remove in light of what the legislation ended up saying, to stop LLs potentially requiring and getting in trouble.

Point 3 also says ‘may’ which allows for the specifics where it ‘maynt’ be used

Best

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But the clauses do encourage landlords not so au-fait with the law to believe this is possible and could lead to £7k penalties.

Its possible that Suranjith has somehow got hold of an earlier draft of the tenancy agreement thats still knocking around on the site, but either way, this needs urgent attention from Openrent.

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I downloaded what I assumed was the latest AST from their site, following the link in their latest newsletter.

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