Supported accommodation under the Renters’ Rights Act 2025

The Renters’ Rights Act 2025 represents the most significant overhaul of the private rented sector in a generation. Much commentary to date has focused, understandably, on the abolition of Section 21 ‘no-fault’ evictions, the end of fixed-term assured tenancies and the new periodic tenancy regime that now applies to all private sector landlord assured tenancies from 1 May 2026.

But for the supported housing sector, these headline reforms are not the whole story. For housing associations, registered providers, charities, community interest companies and voluntary organisations operating in supported accommodation, the most consequential provisions of the 2025 Act may be the new bespoke grounds for possession inserted into Schedule 2 to the Housing Act 1988.

These new grounds (Grounds 5E, 5F, 18 and 5H) are designed to address the unique operational challenges of managing supported housing stock. They recognise that supported housing providers need possession tools that reflect the realities of providing care, support and supervision: tenants whose needs change, funding that is withdrawn and individuals who refuse to engage with the services the accommodation is designed to deliver.

Crucially, however, parliament has confined these grounds to a specific class of landlord. Not every provider of care and support can rely on them.

The outcome depends on the landlord’s identity and legal structure, and getting that analysis wrong could mean losing access to the very tools parliament designed to help manage supported housing stock.

This article examines who qualifies, what the new grounds require and why the distinction between different types of supported housing provider demands careful attention in tenancy drafting and corporate structuring.

What is ‘supported accommodation’ under the 2025 Act?

The 2025 Act inserts a new paragraph 12 into Schedule 2 to the Housing Act 1988, which provides the statutory definition of ‘supported accommodation’ for the purpose of the new grounds for possession. The definition imposes two cumulative requirements, both of which must be satisfied.

The first limb: the landlord

The dwelling house must be let by one of the following:

• A housing association (within the meaning of Section 1 of the Housing Associations Act 1985)
• A private registered provider of social housing
• A registered charity
• A voluntary organisation.

This is an exhaustive list. A private company or individual landlord, however extensive the care package they provide, cannot satisfy this limb. The restriction is deliberate and reflects parliament’s view that these enhanced possession tools should be available only to social-purpose landlords, whose constitutional objects are directed towards public benefit rather than private profit.

The second limb: the tenant

The tenant must receive care, support or supervision, provided:

• By the landlord or a person acting on behalf of the landlord
• By someone else, where the tenant has been admitted into the accommodation to meet a need for care, support or supervision.

The second alternative, sometimes referred to as ‘managed accommodation’, arises where the landlord provides the housing but a separate body (such as a local authority or commissioned support provider) delivers the care. The key requirement is that the tenant was admitted for the purpose of receiving care, support or supervision. It’s not sufficient that the tenant happens to receive such services incidentally.

The critical point

Both limbs must be satisfied. A private landlord providing care does not qualify. A housing association letting to tenants who do not receive care, support or supervision does not qualify.

The definition is cumulative, and any analysis of whether the new grounds are available must begin with both questions: who is the landlord, and does the tenant receive care, support or supervision?

The new grounds for possession

The 2025 Act introduces four new grounds directed specifically at supported accommodation. Each addresses a different operational scenario, and understanding their scope is essential for any provider drafting tenancy agreements or planning possession proceedings.

Ground 5E — mandatory

Purpose: The landlord needs the dwelling for supported accommodation, but the current tenant did not enter the tenancy for that purpose.

Ground 5E is a mandatory ground. It applies where the landlord holds the dwelling house for the purpose of making it available as supported accommodation, but the current tenant did not enter the assured tenancy for the purpose of receiving care, support or supervision. This addresses the practical scenario where a general-needs tenant is occupying accommodation that the landlord now needs to allocate to a vulnerable person requiring support.

Ground 5F — discretionary

Purpose: Circumstances have changed and the supported accommodation arrangement is no longer viable or appropriate.

Ground 5F is a discretionary ground, meaning the court must be satisfied that it is reasonable to make the order. It applies where the dwelling was supported accommodation when the tenancy was granted and any of the following circumstances now apply:

• The tenancy was granted for a limited period of support and that period has ended
• A third-party support provider has ceased to provide services and the landlord has used reasonable endeavours to find an alternative
• Funding has been withdrawn and the landlord has used reasonable endeavours to secure alternative funding
• The financial viability of the landlord or the supported accommodation would be threatened
• The tenant does not need the level of support services provided
• The tenant does not need any support services
• The support services provided do not meet the tenant’s needs
• The dwelling has physical features not required by the tenant
• The dwelling is physically unsuitable for the tenant’s needs.

The breadth of Ground 5F reflects the reality that supported accommodation operates within a complex ecosystem of funding, commissioning and need. Landlords must be able to manage their stock dynamically, responding to changing needs, funding cuts and ensuring that specialist accommodation is allocated to those who need it.

Ground 18 — discretionary

Purpose: The tenant has unreasonably refused to co-operate with support services.

Ground 18 applies where the tenancy is of supported accommodation and the tenant has unreasonably refused to co-operate with the person providing support services.

This addresses one of the most challenging scenarios in supported housing management: a tenant who occupies accommodation designed for people requiring support but refuses to engage with the support offered.

The requirement is that the refusal be ‘unreasonable.’ This imports a standard of objective reasonableness, and the court must be satisfied that co-operation was genuinely required and that the tenant’s refusal was without adequate justification. Providers relying on this ground should maintain detailed records of attempts to engage the tenant and the nature of the refusal.

Ground 5H — stepping stone accommodation (mandatory)

Purpose: Time-limited accommodation designed to help tenants move to independent living.

Ground 5H provides a mandatory ground for possession for ‘stepping stone’ accommodation — short-term supported housing designed to prepare tenants for independent living. It’s available only where the landlord is a registered provider of social housing or a charity.

Critically, voluntary organisations are excluded from this ground, even if they otherwise qualify for Grounds 5E, 5F and 18.

Why these grounds matter

The significance of these grounds cannot be overstated. In a post-Section 21 world, the only route to possession for an assured tenancy landlord is through the Section 8 grounds.

Without access to Grounds 5E, 5F and 18, a supported housing provider is limited to the generic grounds available to all landlords, such as rent arrears (Grounds 8, 10, and 11) and antisocial behaviour (Ground 14). These do not address the operational realities of supported housing, including changing needs, withdrawn funding or refusal to engage with support.

Who can rely on these grounds?

The restriction to social-purpose landlords is not incidental – it’s the central design feature of the supported accommodation provisions. Parliament has deliberately confined access to these grounds to landlords whose constitutional character places them within one of the four qualifying categories.

The policy rationale is clear. Grounds 5F and 18, in particular, are powerful tools. Ground 5F allows possession where a tenant’s needs have changed or funding has been withdrawn — circumstances that could easily be manufactured or exaggerated by a landlord motivated by profit. Ground 18 permits possession where a tenant refuses to engage with support — a ground that, in the wrong hands, could be used to remove ‘difficult’ tenants from lucrative supported housing contracts.

By confining these grounds to housing associations, registered providers, charities and voluntary organisations, parliament has ensured they are available only to landlords subject to some form of constitutional constraint on profit extraction: whether that is the asset lock and regulatory oversight of a registered provider, the charitable purposes requirement of the Charity Commission or the not-for-profit requirement of a voluntary organisation.

A private company carrying on activities for profit cannot access these grounds, regardless of the quality of care it provides. This is a bright-line rule, and it applies equally to sophisticated operators with excellent track records and to poor-quality providers. The test is constitutional, not qualitative.

Practical implications for tenancy agreements

The position of non-registered provider supported housing providers has direct and immediate implications for the drafting of tenancy agreements. A provider that falls within the ‘voluntary organisation’ category cannot simply adopt a registered provider’s standard tenancy agreement template. Such a template may assume social housing exemptions that do not apply and may omit provisions essential to the provider’s ability to rely on the supported accommodation grounds.

Conclusion

The Renters’ Rights Act 2025 creates a layered and nuanced landscape for supported housing providers. The new grounds for possession — Grounds 5E, 5F, 18 and 5H — are valuable tools for managing supported accommodation stock in the absence of Section 21, but access to them is not universal.

Understanding where your organisation sits within the statutory framework is essential. This requires consideration of:

• The constitutional character of the landlord (housing association, registered provider, charity, voluntary organisation or none of these)
• Whether the body’s activities are carried on for profit (the Section 180(3) test)
• Which grounds are available
• Whether the tenancy agreement accurately reflects the provider’s specific legal position.

For providers of supported accommodation, this distinction is the difference between a workable tenancy management framework and an unworkable one.