RTB Rent Register
- Thread starter Sr. Tayto
- Start date
Thanks! I now see this term is used in the original 2004 Act.
Indeed it's interesting to see that the original act contains requirements to set rents at market levels (section 19 also, see below). it seems the recent legislation serves to define that in more detail, notably the introduction of the rent register. I wonder have there been any cases under the original act where it was claimed a landlord set a rent above market level - I hadn't heard of such.
@Gerard0 what you quoted seems to be an amalgamation of the original act and the subsequent amendments, am I correct? Perhaps your own work? Is that available somewhere in full form?
Wouldn't that fall under the legal concept of Caveat Emptor, unless the landlord could be shown to have knowingly concealed issues with the property or suchlike?
It should, but I don't think that is the view the RTB will take. Their job is to protect innocent tenants from evil gouging landlords.
It's in the Consolidated Act prepared by the Law Reform Commission (so I'd say it's correct) here
It firmly establishes the Rent Register as the primary tool for rent setting and is obviously where the RTB is coming from and why 'Rent in excessive of market' is now the top box in the RTB Report Your Landlord Form. They'll be using it to challenge what they regard as outliers.
It firmly establishes the Rent Register as the primary tool for rent setting and is obviously where the RTB is coming from and why 'Rent in excessive of market' is now the top box in the RTB Report Your Landlord Form. They'll be using it to challenge what they regard as outliers.
Great, thanks for the link, very useful.
You linked to section 24. Section 12 is the other that references the rent register:
Section 24(b) is new since March 2026 and replaces references to advertisements etc.
The reference to "rent information" is interesting, because the information on the rent register is limited, and certainly presented in a very limited way.
Character, although a broad concept, by reference to the rent register information can probably only refer to whether the rent for the comparators are similar in terms of subject to RPZ / Rent Control rules or not. The register presents very limited information in terms of "character" of other dwellings, you can't even determine the precise location of the comparators from the rent register. Location would normally be considered highly relevant when looking at "character" but it's impossible to know precise location.
Will be interesting to see how the RTB might use the rent register as a research tool in the future. Eg to publish more detailed information on the average rents for 2 bedroom apartments in Dublin city centre, average sq metres of such units etc. RTB previously published detailed Rent Index every quarter.
The reference to "rent information" is interesting, because the information on the rent register is limited, and certainly presented in a very limited way.
Character, although a broad concept, by reference to the rent register information can probably only refer to whether the rent for the comparators are similar in terms of subject to RPZ / Rent Control rules or not. The register presents very limited information in terms of "character" of other dwellings, you can't even determine the precise location of the comparators from the rent register. Location would normally be considered highly relevant when looking at "character" but it's impossible to know precise location.
Will be interesting to see how the RTB might use the rent register as a research tool in the future. Eg to publish more detailed information on the average rents for 2 bedroom apartments in Dublin city centre, average sq metres of such units etc. RTB previously published detailed Rent Index every quarter.
On such an interpretation the new rules effectively impose rent setting according to a register of reference rents, while allowing politicians attempting to market the Irish PRS to international investors to use the term "market rent". AKA marketing flannel.
Note Ronan Lyons objections to the Housing Commission recommendation of reference rents - as leading to a circular pricing system in which there would be no such thing as market price. It's a fairly fundamental point.
Also note 24(a) exists too.
Having regard to the terms of the tenancy would appear to undermine the use of any rental price set under the old rules as a price limiting comparator. For example a tenancy which grants permanent (or minimum 6 year) tenure to a tenant and requires any sale to keep him in place is worth more to a tenant and less to a landlord than a rental price on the rent register relating to a tenancy who's terms permit the owner to evict to sell at vacant possession price.
Options pricing is a long established element of markets. You can't lose an option to sell at owner-occupier valuation without a change to the market price of the contract. Try something like that in any market with competent market practitioners and you'd get your head handed to you on a plate.
Words have meaning.
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That is very important.
An EA pointed out (it's copied on one of the threads here), that once a tenant has a lifetime or 6 year tenure in the property, he has partial economic ownership which is valuable. He can't be removed and the landlord will have to pay him to leave. In reality he shares in the sales proceeds ie. economic ownership.
That makes the new leases more valuable than older ones and should be factored in for market rent. It won't be by the RTB.
That's where this is leading. Landlord's won't be able to reset to market. It will be a circular pricing system determined by the RTB.
I think what the RTB will do is:
1. Wait for the Register to develop.
2. Go after the top rents and get them knocked back to 'market'
3. Once they have knocked back the top rents, all later landlords who priced their rents based on the previous top price can be knocked back too.
You can imagine the announcement. We have determined that €2,500 is too high for a 2 bed apartment in Cork. Any landlord who has rented at that level must reduce their rent. A cascade effect then follows. €2,400 is now the top rent and the outlier and is too high and so on.
This case was in front of the RTB tribunal from October 2025. While the substantive issue was about notice of termination, there was also complaint from the tenant about the rent review resulting in an above-market-rate rent. Although this latter matter was ruled out of scope of that particular case, you can see from the minutes how the argument against the landlord can go in future.
(Caveat, I haven't read this in great detail so I may have missed something relevant.)
And it is the tenant's word against the landlord's as to whether repairs and maintenance has been carried out. You can guess who the RTB will believe.
This is the future for landlords and as tenancies are pretty much permanent, the landlord can do nothing.
After a year or two in the tenancy, the tenant successfully challenges the rent on the basis that items haven't been fixed, or it hasn't been painted or the furniture is getting shabby.
This is the future for landlords and as tenancies are pretty much permanent, the landlord can do nothing.
After a year or two in the tenancy, the tenant successfully challenges the rent on the basis that items haven't been fixed, or it hasn't been painted or the furniture is getting shabby.
You'll have receipts and invoices to support any work done at the property.
You'll need to expand that thought process.
I read the report & whilst arguments re rent were attempted, the claim was dismissed.
The property owner won the case in full; though whether they'll ever get their arrears is another story.
The below might be a better example to see how things would go in a dispute over market rent.
RTB Tribunal TR1015-001406 — Mardan v Grant Thornton (Eden, Blackrock, Cork)
https://rtb.ie/disputes/dispute-out...ion-and-tribunal-orders/?_search=DR0715-19619
The landlord (acting as receiver, managing 126 occupied (of 127) units in the Eden complex) sought to raise rent from €850 to €1,000. They produced nine actual signed leases for two-bed apartments in the same complex from May–October 2015, all at €1,000–€1,050. The most directly comparable: 6 Blackrock Park let at €1,000 on the very same date the review notice was served.
The tenant's comparators were DAFT advertisements (not achieved rents) for properties in different developments, mostly three-bed or one-bathroom units — i.e. not like-for-like.
The Tribunal landed on €930 (i.e. below market rent they were clearly achieving in other units in complex). The reasoning is striking on three points:
RTB Tribunal TR1015-001406 — Mardan v Grant Thornton (Eden, Blackrock, Cork)
https://rtb.ie/disputes/dispute-out...ion-and-tribunal-orders/?_search=DR0715-19619
The landlord (acting as receiver, managing 126 occupied (of 127) units in the Eden complex) sought to raise rent from €850 to €1,000. They produced nine actual signed leases for two-bed apartments in the same complex from May–October 2015, all at €1,000–€1,050. The most directly comparable: 6 Blackrock Park let at €1,000 on the very same date the review notice was served.
The tenant's comparators were DAFT advertisements (not achieved rents) for properties in different developments, mostly three-bed or one-bathroom units — i.e. not like-for-like.
The Tribunal landed on €930 (i.e. below market rent they were clearly achieving in other units in complex). The reasoning is striking on three points:
- Same-complex achieved rents were effectively discounted. Despite being the closest possible comparators — same development, same unit type, same month — the Tribunal treated them as "not determinative."
- A wear-and-tear discount was applied without evidence quantifying it. The Tribunal accepted the tenant's assertion that the unit hadn't been refurbished and reasoned that fresh re-lets in the complex would command more. No valuation, no costing, no methodology — just an unquantified downward adjustment from the actual market evidence.
- The PRTB/ESRI index was used to back-calculate a "permitted" increase. The Tribunal took Q2 2012 vs Q2 2015 averages for two-beds in Blackrock (~9.51% rise), applied that to €850, and got €930.84 — almost exactly the figure determined. In effect, an index-based uplift was substituted for the achieved-rent evidence in the same building.
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The tribunal in this case dismissed the rent appeal from the tenant on the basis that the tenant did not lodge the complaint within the statuatory period. See page 7. Because of this they did not adjudicate on the basis of the rent level itself. "Accordingly, the Tribunal has no jurisdiction to determine the Tenant’s claim that the rent is above market value, and that element of the application is dismissed". I quoted this case to show the nature of the arguments that the tenant can make, and now post-March they will be able to avail of additional "support" from the legislation and RTB rent register. Another observation on this case is that Threshold supported the tenant (i.e. ProBono) even though they should have seen the tenant had a weak set of arguments, whereas the landlord saw the need to engage a solicitor.
Yes this is indeed a better example since there was a ruling, and not a good one for the landlord.
This is an example how it will go when new cases reach the RTB Tribunals.
Looks like the RTB have stopped publishing the Rent Index? This indicated average rent per County.
Hopefully as a result of the new Published Rent Register the RTB will be in a position to provide more detailed information for each Local Electoral Area, eg average rents for 2 bedroom apts, 65 sq metres, in Dublin city centre etc. ideally this information should be published every quarter.
Hopefully as a result of the new Published Rent Register the RTB will be in a position to provide more detailed information for each Local Electoral Area, eg average rents for 2 bedroom apts, 65 sq metres, in Dublin city centre etc. ideally this information should be published every quarter.
The tenant could claim that they asked you at inspections and you did nothing or show pictures of areas of the house that need work (you mightn't have been told about these wouldn't matter to the RTB). Pictures of shabby couches or dated kitchens could be used to bring down the value of the house for rental purposes, things like that.
Exactly and this is what the Rent Register has been set up to achieve.
I fully expect once that within 6 months or so, the RTB will be taking cases against landlords (or tenants will - it's top on the Report Your Landlord Form).
These are the type of judgments we can expect, plus, possibly fines.
The RTB will want to show successes like these, we got the rent down for tenants!
I imagine they always had the data in a form they could query for such stats, if they had a mind to do it. The rent register query tool is just a - very limited - way to query the database.