Developer

A Private Members’ Bill that seeks to regulate short-term letting was presented to Parliament by Labour MP Rachael Maskell on 2 June 2025 and is due for its second reading on 4 July 2025.

The Bill aims to address concern around the growth of holiday lets, particularly in rural and coastal areas where local residents are being priced out of residential housing. The Bill would introduce a new planning use class for short-term lets that would require local planning authorities to licence individual lettings. The authority would then also have the power to remove licences, for example in the case of anti-social behaviour (addressing the issue with so-called ‘party flats’).

The Bill would also make changes to small business rates relief as it is understood that the government is looking to remove some of the tax advantages landlords have providing short-term holiday lets and encourage them to provide more residential housing.

Short-term Let Accommodation Bill – Parliamentary Bills – UK Parliament

As also detailed in our Disputes section, the Government has set out plans for commonhold reform in its new white paper to bring the system of long leasehold flats to an end.  Commonhold White Paper: The proposed new commonhold model for homeownership in England and Wales – GOV.UK

Commonhold is an alternative management structure to the long leasehold system which allows occupiers to own the freehold of individual flats in a building with the common parts of the building being jointly managed by the flat owners through a commonhold association.  It was first introduced in 2002 but has not been widely adopted. The White Paper proposes changes aimed at reinvigorating the tenure including:

• New rules to give more flexibility which will help commonhold to work for all types of developments, including mixed-use buildings and shared ownership homes;
• Greater security for mortgage lenders by protecting the solvency of commonhold associations by making public liability insurance mandatory, greater availability of reserve funds and oversight of commonholders to approve annual budgets to keep costs down;
• Improve management of commonholders with new rules for appointing directors, clear standards for repairs and mandating use of reserve funds;
• Amended rules will mean more democracy in agreeing the annual budget and clarity with safeguards for changes to “local rules” which relate only to a particular commonhold building.  This will allow homeowners to prioritise what is important for their building;
• A Code of Practice will be released to set out how costs should be apportioned and increase transparency;
• The Government will strengthen regulation of managing agents, who will now report to the common holders who will be able to hire or fire managing agents.

The government is holding consultations with key stakeholders and intends to publish a draft bill (the Leasehold and Commonhold Reform Bill) in the second half of 2025.

It is anticipated that as well as reinvigorating the drive towards a commonhold system, the Bill will contain more detail on the timeframe for the transition to commonhold and how it proposes to convert existing leaseholds to commonhold tenure.

A comeback for commonhold? | Foot Anstey

The Levelling Up and Regeneration Act 2023 (“LURA 2023”) included requirements for disclosure of contractual rights over land in England and Wales.  Secondary legislation will determine how the information will be requested but the requirements for disclosure will include key information such as the type of agreement, the parties involved, the date of the agreement and details of the solicitors involved in the transaction. This will impact certain land agreements including option agreements, conditional contracts and promotion agreements.  The Government consulted on draft regulations seeking views on the implications of collecting and publishing information on contractual control agreements. The consultation closed in March 2024.

Potential disclosure requirements in relation to contractual control agreements will mean that parties to such documents will have to supply more potentially sensitive commercial information. This will also cause further administrative steps for developers and their advisers to correctly file information in line with regulations.  If information is not provided or false information is given knowingly or recklessly, this could constitute a criminal offence under LURA 2023 which carries a maximum of 2 years imprisonment and an unlimited fine.

This article provides more information on the proposals – Government consults on more transparent picture of controls on land | Foot Anstey

In a letter in early 2025 to the Chair of the Land Registry board, Matthew Pennycook MP confirmed he would like to see rapid design and delivery of the systems to collect and publish contractual control agreements.  This is the first indication that the new government will proceed with these proposals. There were no details of timing.

In 2021, the Government proposed to raise the minimum energy efficiency standard to C by 2027 and B by 2030.

The original proposals were abandoned for residential properties but a new consultation was launched on the proposal to raise the minimum energy efficiency standard for domestic (residential) properties.  The proposals include revised metrics for calculating asset ratings and would require that from 2028, all new leases need to comply with the new higher standard; and by 2030, all leases need to comply with the higher standard. The consultation closes on 2 May 2025.

The Government is yet to confirm whether it will implement the original plans for commercial properties. Developers will want to know whether an existing property is exempt under the proposed changes and may consider undertaking works to improve their EPC rating in the long term.  Clarity is also needed as to the standard to which new properties must be constructed.

Improving the energy performance of privately rented homes: consultation document (HTML) – GOV.UK

Another consultation was recently launched dealing with improving the energy efficiency of socially rented homes in England with proposals to introduce a minimum energy efficiency standard for socially rented homes in England for the first time.

Improving the Energy Efficiency of Socially Rented Homes in England – GOV.UK

On 3 March, changes to Right to Manage (RTM) which had been set out in the Leasehold and Freehold Reform Act 2024 were brought into force via the Leasehold and Freehold Reform Act 2024 (Commencement No. 3) Regulations 2025.

These changes look to make it easier and cheaper for leaseholders to take over management of their buildings (there is no requirement for mismanagement by the landlord to be proved for leaseholders to make a claim).

Some of the changes include:

• The requirement to pay the landlord’s reasonable costs upon making a RTM claim has been removed except in limited circumstances. Landlords will therefore have to pay their own costs if such a claim is made.
• RTM previously only applied to buildings where no more than 25% was non-residential. This has been increased to 50%, meaning that more buildings will be eligible for a RTM claim and consequently more leaseholders will have the right to take over management from their landlords.

The Leasehold and Freehold Reform Act 2024 (Commencement No. 3) Regulations 2025

Subsequent to these regulations, a Private Members’ Bill has been introduced to the Commons by Labour MP Rachel Blake, which aims to expand the RTM provisions further in favour of leaseholders.

The Bill’s stated aims are to:

• define qualifying tenants for the purposes of claiming a RTM;
• reduce the number of qualifying tenants required to give notice of a RTM;
• establish a duty on freeholders to assist RTM companies in connecting with leaseholders in their properties;
• establish a presumption in favour of RTM schemes in certain circumstances.

The Bill was presented to Parliament on 18 June 2025 and is progressing slowly.

Right to Manage and Leasehold Bill – Parliamentary Bills – UK Parliament

The government has published a consultation proposing changes to the home buying and selling process including:

• Provision of upfront information;
• Binding conditional contracts;
• Streamlining transactions;
• Professionalising property agents.

The aim is faster, more reliable transactions with fewer fall throughs.  The consultation closes in Deecember.

The proposals would impact the conveyancing process of individual dwellings, likely improving the efficiency of the process for consumers.

Home buying and selling reform – GOV.UK

The English Devolution and Community Empowerment Bill introduced to Parliament in July 2025, proposes a ban on upwards only rent reviews for new commercial leases.  This has the potential to impact rent negotiations for leases and create a two tier market until all existing commercial leases are renewed or terminated.  This will likely impact investment valuations if it becomes law.

A turning point for commercial leasing: reforming rent reviews in England and Wales | Foot Anstey

The Act will reform private renting including abolishing section 21 “no fault” evictions, introducing a tenancy structure where all assured tenancies are periodic and applying the Decent Homes Standard and ‘Awwab’s Law’ to the private rented sector.  The aim is to give renters greater security and stability and includes the following proposals:

• all tenancies will be periodic tenancies;
• existing possession grounds and notice periods are to be reformed, but there are new grounds for possession that are accessible to registered providers of social housing;
• there are changes to the way rent increases work for private registered providers of social housing;
• there are changes around provision for the possession of properties and rent changes, specifically for the social housing sector, including temporary and supported housing;
• a statutory consultation process is required so abolition of section 21 can be applied to social tenancies (where the landlord is a private registered provider of social housing) at a later date.

The Government published a Guide to the Renters’ Rights Act – GOV.UK

Investigatory powers guidance for Renters’ Rights Act 2025 – GOV.UK

Renters’ Rights Act 2025: Implementation roadmap – GOV.UK

The Act will cause significant changes to the rented housing sector.

The Guide to the Renters’ Rights Act – GOV.UK notes that assured shorthold tenancies are typically only used in the social sector where there was an expectation that a tenancy would be for the short-term, and therefore the majority of social tenants already enjoy secure assured tenancies, which have greater security and do not allow the use of section 21.

This Foot Anstey article aimed at developers flags the key issues – Renters’ Rights Act 2025 – All Systems Go! | Foot Anstey

On the 7 November 2025 the Ministry of Housing, Communities & Local Government (MHCLG) published guidance for the Social and Affordable Homes Programme (SAHP) 2026–36.

The SAHP is a new £27.2bn initiative designed to help achieve the building of 1.5 million new homes by to delivering around 300,000 affordable homes, including 180,000 for social rent, across England (excluding London).

Bidding is expected to open in February 2026, with the first grants distributed from April 2026. Bidding will be open to registered providers, local authorities, housebuilders and developers, charities and community-led organisations.

Comment

Key take aways for developers:

• The SAHP emphasises regional strategic leadership in affordable housing delivery by increasing regional mayors’ roles in the decision making process for grant-funding and giving mayors responsibility for setting the strategic direction for affordable housing delivery in their areas.
• There is no proposal to extend additionality rules so Section 106 Affordable Housing can be purchased via the grant funding, as is being considered for London.
• Opportunities for community land trusts and housing co-operatives to deliver affordable housing delivery in their areas.
• The Right to Shared Ownership does not apply to rented housing developed under the new scheme, as can be seen from MHCLG guidance here.

Developments in the Biodiversity Net Gain (BNG) space continue as more and more developments become subject to the BNG regime.

As previously reported, the mandatory BNG regime for all TCPA (Town and Country Planning Act) developments came into force on 12 February 2024. Since this date, developers have had a statutory obligation to ensure a 10% improvement in biodiversity per development.

On 14 March 2025, the government published its first annual report around the income taken from statutory BNG credits.

Comment

BNG currently only applies to developments subject to the TCPA regime, which excludes NSIPs (Nationally Significant Infrastructure Projects). A key development we expect to see in 2026 is the BNG regime extending to NSIPs.

The government previously proposed to bring NSIPs within the BNG regime from November 2025, but this has now been pushed back to May 2026. We can expect to see a surge in interest in BNG leading up to this date, and with it the potential for the demand to drive down the overall price of the off-site credits.

The recent High Court decision in Chidswell Action Group, R (On the Application Of) v Kirklees Council [2025] EWHC 2256 (Admin) has reinforced the procedural requirement set by the Court of Appeal in Greenfields (IOW) Ltd v Isle of Wight Council for local planning authorities (LPAs) to publish draft Section 106 Agreement which contain planning obligations prior to granting planning permission.

This has reaffirmed concerns around procedures for agreeing and publishing Section 106 Agreements, because the developer’s planning permission was quashed after it was decided that the LPA’s failure to publish the Section 106 Agreement before granting planning permission invalidated the decision.

The alarming point for LPAs and developers is that it has been common practice for Section 106 Agreements to be published to the LPA’s planning register after the grant is made (or at the same time). However, in this case the judge decided that there was a strong possibility that publication may have led to a substantially different outcome as the Section 106 obligations would likely have been improved and the committee may have asked for updated biodiversity work to be done before deciding whether to proceed.

The key implication for developers is that planning permissions risk invalidation. We recommend developers check the LPA’s public register regularly to ensure compliance and liaise with the LPA on the timescales for publication, to ensure draft Section 106 Agreements are published early enough during a planning application for scrutiny.

The Supreme Court clarified how environmental protections apply when discharging planning conditions. Our article summarises the issues.

Supreme Court clarifies Nutrient Neutrality and Environmental Protection: The CG Fry Judgment | Foot Anstey

On 17 July 2025 the Government published a joint plan together with the social housing sector which set a statutory deadline for the removal of unsafe cladding from high-rise buildings in England. A new Remediation Bill is being brought forward to crystallise the laws intended under the Remediation Acceleration Plan as soon as the parliamentary timetable allows.

Under the new legislation:

• Buildings that are over 18m in height must be fully remediated by the end of 2029; and
• Buildings that are between 11m and 18m in height must have remediation completed by the end of 2031.

Failure to comply with the strict deadlines could lead to unlimited fines or imprisonment.

Legal deadline confirmed: Unsafe Cladding Remediation | Foot Anstey

The Government has put before Parliament the new Building Safety Regulator (Establishment of New Body and Transfer of Functions etc) Regulations 2026. The new Building Safety Regulator (“BSR”) will be a corporate body reporting directly to the Secretary of State for Housing, Communities and Local Government. These new regulations will:

• Come into force on 27 January 2026 and the new Building Safety Regulator will formally take control of high-rise building safety in England and Wales (having formerly been part of the HSE) from that date;
• Transfer the current powers, staff and live cases that the HSE have managed under the Building Safety Division;
• Enable the BSR to prosecute for non-compliance and charge for services;
• Require the BSR to produce annual reports (with the first being due shortly after the end of March 2026);
• Give the BSR the discretion to “do anything it thinks appropriate for the purposes of, or in connection with, its functions”.

The draft Statutory Instrument is available to view here.

The Ministry of Housing, Communities and Local Government published further guidance earlier this year on the new Building Safety Levy, which includes specific advice for developers of residential buildings and advice for local authorities.

The levy is essentially a tax on new residential buildings which will be collected by local authorities and used to contribute to fixing building safety defects across the country to ensure residents are safe.

Importantly, the Building Safety Levy has been pushed back a year and will now come into force on 1 October 2026. It will apply to building control approval applications for one or more dwellings and/or one or more purpose-built student accommodation bedspaces on or after that date (unless an exemption applies). For example, exemptions apply to social housing and supported housing provided by a local authority, housing association, charity or voluntary organisation.

Our earlier article flags the key issues – The Building Safety Levy – what you need to know | Foot Anstey

In the case of Jaevee Homes v Fincham [2025] EWHC 942 (TCC) the Technology and Construction Court (TCC) was asked to consider the circumstances where a contractor had quoted for work by email, followed by an exchange of WhatsApp messages with the client during which it was confirmed the contractor was successful, and a subsequent formal contract was not executed.

The TCC issued a judgment:

• reaffirming that legally binding contracts can be formed via informal electronic platforms such as WhatsApp provided the language and context support it; and
• establishing that a construction contract can be valid even without agreement on key details like the project duration, start date, or payment terms as these terms can be implied by law.

Lee Ward and Chloe Wood discuss the importance of the judgment and some key tips for parties negotiating a construction contract here.

The Upper Tribunal’s (UT) decision in BNPPDS(J) Limited And BCI Limited V Amanda Hitchings (Valuation Officer) [2025] reaffirms key principles from the Supreme Court ruling in Newbigin v Monk [2017] regarding the rateable value (RV) of properties undergoing refurbishment.

The dispute involved a warehouse in Newcastle undergoing substantial refurbishment from 28 November 2022 to 24 March 2023. The works involved fitting out the property as a “dark kitchen” for use by McDonalds.

The Premises were assessed for RV in the 2017 rating list as a warehouse and premises at £31,500. The owner issued a check and subsequent challenge on 10 January 2023 and 21 March 2023, citing that the Refurbishment Period rendered the Premises incapable of beneficial occupation.

The issue in question was whether the property was capable of beneficial occupation during the refurbishment period, impacting its rateable value (the value ascribed to a domestic or commercial building based on its size, location, and other factors, used to determine the rates payable by its owner).

The UT held that the property was not capable of beneficial occupation during the refurbishment, and consequently its rateable value should be reduced to £1 during this period.

This decision provides clarity for property developers and owners, confirming that substantial refurbishment rendering a property unoccupiable can justify a temporary reduction in the rateable value.

BNPPDS(J) Ltd & Anor v Hitchings (Valuation Officer) (RATING – HEREDITAMENT – 2017 List – warehouse – works carried out following termination of lease and prior to opening as a delivery kitchen – whether property incapable of beneficial occupation – whether state of reasonable repair to be assumed – Local Government Finance Act 1988, Sch 6, para 2(1)(b)) [2025] UKUT 104 (LC) (26 March 2025)

This case revolved around the interpretation an insurance clause in a commercial lease.

The lease provided that the tenant, Picturehouse Cinemas (the Tenant), should pay insurance by reference to the ‘premium payable…for keeping the Centre insured’. However, in practice, the landlord, London Trocadero (the Landlord), obtained insurance via brokers and paid them a commission. The amount of the broker’s commission could be increased and part of that commission was then repaid to the Landlord (the Landlord’s Commission). The effect of this was that when the total amount was recharged to the Tenant, the Tenant funded the Landlord’s Commission, allowing them to profit at the Tenant’s expense.

The High Court ruled that the Landlord could not pass on the fee paid to the broker to the Tenant as part of the insurance rent as it did not form part of the cost of insurance policy itself and required repayments to the tenant to be made.

This decision unravels a decades old practice of insurance commissions being subsumed into insurance rent payable by tenants which produces pure profit for landlords. This will have significant implications for landlords, with more tenants likely to enquire whether landlords have been earning a profit on any commissions.

The judgment may be viewed here: London Trocadero (2015) LLP v Picturehouse Cinemas Ltd & Ors [2025] EWHC 1247 (Ch) (23 May 2025)

A dispute arose in the context of the construction of an extension. The Court of Appeal ruled that two neighbours were bound by a boundary demarcation agreement they had no knowledge of which was entered into by their predecessors in title. This case reaffirms the importance of boundary demarcation agreements, as successors in title will only acquire title as delineated by the agreement regardless of their knowledge of the agreement’s existence.

The judgment may be viewed here: White v Alder & Anor [2025] EWCA Civ 392 (07 April 2025)

The Future Homes Standard (“FHS”), was intended to be published in Autumn 2025, but as of November 2025, we are still awaiting its publication.

The FHS will, once published, include new rules obliging housebuilders to incorporate solar pv panels to new housing developments. The Government has indicated that developers will be required to provide at least 40% coverage (and where this is not possible to still install a ‘reasonable amount’). A lot of the detail is currently unknown and we anticipate that exemptions will be introduced.

In the interim, housebuilders are, in anticipation of the introduction of the FHS, actively looking to incorporate renewable energy generation technologies to their proposed schemes.

The Act designates a government owned statutory clean energy company, Great British Energy, which, using the government’s financial assistance, will invest in and support clean technology and power projects. Great British Energy will contribute to the government’s Clean Power 2030 objectives.

Its key functions are to facilitate

• production, distribution, storage and supply of clean energy.
• reduction of greenhouse gas emissions.
• improvements in energy efficiency to support decarbonisation.
• security of supply measures to support UK energy independence.
• ensuring that supply chains and business are free from slavery and human trafficking.

Great British Energy will be independent from the government in its operational and investment decisions. Its effectiveness will be reviewed by an independent person.

The deployment of clean energy projects (both of established and less-established technologies) may provide additional opportunities to those operating within the developer sector to decarbonise their stock.

UK launches bold call to global investors: “Build it in Britain” | Foot Anstey

Great British Energy: Statement of Strategic Priorities – GOV.UK

The Labour Government has expressed its continued support for the Boiler Upgrade Scheme. In the Autumn 2024 Budget the Government committed £5.8 million of funding to develop England’s first heat network zones in 5 cities (Leeds, Plymouth, Bristol, Stockport, Sheffield and London). Construction is expected to start from 2026. The Government also reaffirmed its plans to introduce secondary legislation as outlined above.

Following the enactment of the Energy Act 2023 (‘Act’)

“The Heat Networks (Market Framework) (Great Britain) Regulations 2025” were made on 2 March 2025. The provisions are coming into force on a staggered basis, such that as of 1 April 2025 it is prohibited to carry out a ‘regulated activity’ without authorisation. Broadly, a ‘regulated activity’ involves the operation of a heating network and the supply of heating or cooling through such a network.

So far, OFGEM has consulted on proposed measures that are intended on protecting end consumers (for instance the tenants of residential buildings), by providing for transparency around pricing and a set of standards that suppliers need to adhere to. OFGEM will have regulatory responsibilities under the proposed new regime.

A lot of the detail is yet to be ironed out, so for now those who operate heat networks or supply heating or cooling through such networks are encouraged to: (i) where they own or operate buildings that are connected to a district heat network or buildings that use a communal heat network, identify whether they are a “heat supplier” or “operator” and (ii) monitor the developments in this space to ensure that they are well placed to respond to any transitional arrangements that the Government may put in place.

From 1 April 2025, all existing communal and district heat networks (i.e. those in existence prior to 1 April 2025) will be deemed authorised. Operators of such networks and suppliers of heat or cooling in those networks will be required to register their regulated activities with Ofgem by 26 January 2027.

All new developments, whether they are residential or commercial or an energy project, require a connection to the grid to be able to import electricity (and where there is on-site generation) export electricity to the grid. Whether a development is connecting to the distribution system or the transmission system, it will be affected to some extent by the Grid Connection Reform that National Grid has instigated.

The Grid Connection Reform is a process by which applications for new connections are submitted, assessed and managed is significantly amended. Additionally, the existing queue for projects connecting to the transmission system is going to be rearranged.

The first phase of the Grid Connection Reform, being the submission of evidence as part of the Gate 2 process, has now been completed and developers of clean energy projects will be notified in the w/c 1 December 2025, whether they have been successful in securing a Gate 2 Offer (with a guaranteed date of connection and point of connection) for their projects.

There is currently no indication from NESO as to when the next Gated Application Window will be. This is bound to create further uncertainty in the energy sector and cause delays in the delivery of clean energy projects. For those residential and commercial developers, who are looking to procure their energy through a renewable energy source, the delays resulting from the Grid Connection Reform, could have a direct impact on their energy procurement strategy.

Heat networks in the spotlight: 2025 and beyond | Foot Anstey

Grid connection reform: The big shake-up | Foot Anstey

NESO moves the goalposts on connections’ reform | Foot Anstey

For those heat networks that are deemed authorised, the general authorisation conditions will become effective from 27 January 2026 and Ofgem will have powers to take enforcement action from that date.

For more information please read here: Ofgem Consultation: Heat networks regulation: authorisation and regulatory oversight

The impact was less than expected but the budget announced some changes to property taxes which will be of interest to investors.

Budget 2025 – what did and didn’t happen to property taxes? | Foot Anstey

Since July 2025 there have been the following key corporate governance updates, which will be of relevance to all corporate investors:

• Since February 2025 there have been the following key corporate governance updates, which will be of relevance to all corporate investors:
• On 25 February 2025 the Financial Reporting Council published an updated “Guidance on the Going Concern Basis of Accounting and Related Reporting, including Solvency and Liquidity Risk”.
• The Institute of Directors establishes a commission to investigate the role of non-executive directors in the UK.
• On 8 April 2025 Companies House launched a new voluntary online identity verification service.

Please see our article below for further detail about each of these.

Corporate governance key updates | July 2025 – October 2025 | Foot Anstey

The English Devolution and Community Empowerment Bill introduced to Parliament in July 2025, proposes a ban on upwards only rent reviews for new commercial leases.  This has the potential to impact rent negotiations for leases and create a two tier market until all existing commercial leases are renewed or terminated.  This will likely impact investment valuations if it becomes law.

A turning point for commercial leasing: reforming rent reviews in England and Wales | Foot Anstey

The government has reformed its apprenticeship programme, with wide ranging changes to apprenticeships including the following items:

• The minimum duration for an apprenticeship is now 8 months, or 187 hours of off-the-job training, whichever is longer.
• For apprentices with no prior learning, off-the-job training hours (which will be published for each apprenticeship standard) must be delivered.
• The apprenticeship funding rules for 2025-2026 have been updated.

Changes are now in effect for English and maths requirements.

This is a Private Members’ Bill. Although unlikely to pass into law, the Bill provide for a statutory definition of bullying at work; to make provision relating to bullying at work, including to enable claims relating to workplace bullying to be considered by an employment tribunal; to provide for a Respect at Work Code to set minimum standards for positive and respectful work environments; to give powers to the Equalities and Human Rights Commission to investigate workplaces and organisations where there is evidence of a culture of, or multiple incidents of, bullying and to take enforcement action.

A second reading is scheduled for January 2026, so watch this space.

Bullying and Respect at Work Bill 2nd reading – Parliamentary Bills – UK Parliament

The government intends to make ethnicity pay gap reporting compulsory for employers with at least 250 employees.

It also plans to introduce compulsory disability pay gap reporting, based on employee self-reporting of disability (they will not be forced or obligated to disclose their status), and judged on a binary basis of “disabled -v- non-disabled” without greater analysis of the different types or degrees of disability.

We await the new draft legislation and the outcome of consultation in this area.

The waiting period for SSP shall be removed, so SSP is paid from day one of sickness. The lower earnings limit will also be removed so all employees, regardless of their earning, qualify for SSP. For employees who earn less than £123 per week, they will be entitled to receive 80% of pay as SSP. These changes will come into force in April 2026.

Under the Employment Rights Bill, the ability of employers to use fire and rehire practices to change terms and conditions of employment will be significantly restricted. It will strengthen the remedies against abuse of the current rules on collective redundancy consultation and fire and rehire.

Changes are expected to take effect in October 2026.

Case highlights the challenges of working in a multi-generational workforce

Employment tribunal and court judgments | July 2025

The new General Data Protection Regulation introduces additional rules to speed up the cross-border enforcement of the GDPR and clarify the relevant procedures and rights.

Among other things, it will:

• Set clear deadlines: Once a lead authority is designated, investigations must conclude within 15 months, extendable by 12 months for complex cases.
• Simplify co-operation: A streamlined procedure applies when the case scope is clear, no objections arise and similar cases exist. The deadline is 12 months, with possible extensions due to national procedures.
• Strengthen complainants’ rights: Complainants can express their views before decisions are made and gain better access to case information, with member states free to offer broader access.

After 17 November 2025 the Regulation will be published in the Official Journal of the European Union and enter into force 20 days after its publication. 15 months after this, (i.e. March 2027) the regulation will be enforceable.

The greater predictability and efficiency with which GDPR will be enforced cross-border represents a significant step for multinationals operating across several EU member states. Developers should review their internal procedures now to ensure they are prepared for the new enforcement landscape.

Data protection: clearer rules for cross-border enforcement | News | European Parliament

In this case, the Court of Appeal made several landmark rulings:

• Claimants do not need to prove that their personal data was disclosed to a third party to bring a GDPR claim – mere “processing” (like printing and mailing) is enough.
• There is no “threshold of seriousness” for data protection claims under English Law

In principle, a claimant can recover compensation for fear of the consequences of an infringement of their rights under the Data Protection Act 2018 (DPA 2018). The harm does not have to be material. However, such fears must be objectively well-founded rather than purely hypothetical or speculative.

Farley and others -v- Paymaster (1836) Limited (trading as Equiniti) – Courts and Tribunals Judiciary