RTB told landlords posting date = service date. The High Court says it doesn't. Accommodation providers set up to fail?

stormy

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High Court judgement published during the week: Argutinski v RTB [2026] Link

A High Court judgment from March 2026 has exposed a serious error in the RTB's own published guidance on notices of termination, with potentially thousands of cases affected over the past 5 years.

What happened?
A Dublin accommodation provider served a notice of termination on a tenant for non-payment of rent. The notice was posted on 21 January 2023. The tenant gave unchallenged evidence that he received it on 23 January. The Tenancy Tribunal sided with the landlord, ruling that the date of posting was the date of service.

The tenant (representing himself) appealed to the High Court and won. The judge found that a posted document is legally deemed served when it arrives in the ordinary course of post, not when it is posted. This is important as, under the RTA Act, the RTB need to be furnished with the notice of termination on the day it is served, otherwise the notice of termination is invalid. As such, in this case, the notice of termination is invalid as the NOT document was given to the RTB on the date it was posted, not served.

He also found that the notice had been signed by "Martin Property Consultants" (a name with no legal existence) when the law requires it to be signed by the landlord or their properly nominated agent. He described the notice as "hopelessly flawed" and cancelled the determination order entirely.

The RTB's own website says the opposite
The RTB's website currently tells landlords a valid notice must be uploaded at the same time it it posted (not what the RTA says, i.e. when legally served)
Below from their website (screenshot at bottom):

To be valid, a Notice of Termination must:
Include the date the notice is sent. This is the date the notice is posted, hand delivered or emailed.
...​
Be sent to the RTB on the same day it is sent to the tenant. Failure to do so makes the notice invalid.
...​
Step 4: Send to your tenant and the RTB
You must send the notice to your tenant and the RTB at the same time. If you don’t, it’s invalid.
You can send the notice to your tenant by post or email. If you send it by post, keep a record of postage.
Submit your notice to the RTB through the online RTB Service Centre.

Source : https://www.rtb.ie/registration-and-compliance/ending-a-tenancy/notices-of-termination

That is exactly the position the High Court has ruled is wrong. Landlords who followed this guidance in good faith, may have had their notices invalidated as a result. If posting isn't service, landlords following RTB guidance were never actually doing this correctly.

They won't defend it in court
Here's the damning part: when this issue came up at the High Court hearing, the RTB's own legal team sought instructions and then told the court they were no longer standing over the Tribunal's decision.

So there you go: the RTB publishes guidance, their Tribunal applies it, a tenant appeals, and the RTB's own lawyers walk away from it in court. Yet the misleading guidance remains on their website.

How many cases could be affected?
This requirement has been in place since 2020, so any notice served by post in the last 5+ years where the landlord followed RTB guidance could potentially be invalid. Whether concluded cases can be reopened is a seperate question, but for anything live or recently decided, this judgment is a serious matter.

The RTB needs to update its guidance immediately and explain itself. That it has not done so already is frankly appalling.

Let me know if I've misunderstood/ misrepresented anything here. To me this is just another example of the traps that's are set for accommodation providers.


Below screenshot taken at 14:50, 26Apr2026
1777211473961.webp
 
There's no doubt that the creation of an environment so clearly hostile, in so many ways, to private sector rented property providers is a remarkable achievement for decades of uninterrupted centre-right government. Several Housing Ministers are to be congratulated!

But is the most appropriate description Kafkaesque or Orwellian?
 
Why blame the RTB
If you have been reading or listening ti the news of late You will see Banks renting money have a bigger problem and no RTB to blame
7 years and not sorted yet,
 
For practical purposes, the date of service (and the relevant notice period should be deemed to have commenced) on the first working date after it is posted (by certified post) and should be copied to the RTB at the same time.

I think it’s worth noting that the High Court explicitly did not base it’s decision on the confusion over the date of posting/service - there were more fundamental problems with the notice.
 
What a farce.

RTB Tribunal said:
... if it was the latter date it would be impossible for a landlord to know when it had been received and when therefore to send the copy to the RTB.

So much for the courts standing up for property rights. The RTB tribunal is the reasonable one here.

There is some issue about 20/21st January dates too. Did they mess up the date on the determination order?

Judgement said:
I prefer not to rest my decision on these points alone.

This may mean that these points (date wrong) are not sufficient on their own to invalidate the ruling. This isn't decided by the ruling, so less clarity on this important point.

The other issue is that the name is not the landlord's name and the dwelling had been sold with tenant in situ.

The tenant can therefore claim that they don't know if they are allowed to pay the rent to that person. The actual landlord must tell the tenant who their agent is and who to send the money to.

This makes buying with tenants in situ even more risky. They can claim they don't know who you are.

Anyway, given that ruling, the best plan would seem to be to flood the RTB with notices.

Post the NoT to the tenant, and then send a copy to the RTB every day for 1-2 weeks (especially include email).

In theory, you need to post the NoT via courier and then watch tracking until it is declared delivered. Even better is to just manually post the NoT yourself.

I wonder if it would count as "served" if you manually put it in the letter box.

I think it’s worth noting that the High Court explicitly did not base it’s decision on the confusion over the date of posting/service - there were more fundamental problems with the notice.

I don't think that makes it much better. There is now a risk for all NoTs and maybe it isn't even a final ruling.
 
I think you are reading way too much into an obiter aspect of the High Court judgement.

If you proceed as I have suggested above, all will be well.
 
I think you are reading way too much into an obiter aspect of the High Court judgement

A High Court judge has identified the RTB's guidance as being inconsistent with the Interpretation Act 2005 - that's not nothing.

The RTB still hasn't updated their guidance, which remains potentially misleading.

Post the NoT to the tenant, and then send a copy to the RTB every day for 1-2 weeks (especially include email).

This seems to be like the only sensible option now. Presumably this now also needs to be done for rent setting and rent reviews. When should one start counting the 90 days from?
 
No solicitor would ever consider the date of posting as the service date or the date of commencement of any relevant notice period.

It should always be the date of receipt in the ordinary course - ie the first working day after the day it is it is posted.
 
No solicitor would ever consider the date of posting as the service date or the date of commencement of any relevant notice period.

Again this is not what the RTB says. I don't see on what basis one can say all will be well if one is not following their express instructions.

If what you are saying is correct, there are many thousands of notices of terminations not valid.
 
I actually don’t see anything wrong with the RTB guidance.

The date of the notice would be the date it is posted. But that’s not the date it is served or the date the notice period runs from.

Again, the notice in this case was not invalidated due to the confusion over the date of posting/service and this would almost certainly fall within the scope of the “slip rule”.
 
I actually don’t see anything wrong with the RTB guidance.
Sorry, I'm confused now.

Let's take an example. If I post a notice of termination today, the RTB's website says I need to do the upload to them today, otherwise it's invalid (as per their website)

As per your suggestion above, aren't you saying it should be uploaded to the RTB portal tomorrow (as it's the next working day)?

What am I missing here?
 
The notice should be sent to the RTB (uploaded or sent by post) at the same as it is sent to the tenant.

And the date it is deemed to have been served and the relevant notice period commences would be the following working day.

Where’s the confusion?
 
Because the RTA says it's to be given to the RTB on the date of service.

So if I upload today, I have not given it on the date of service.
 
No, it says “you must send the notice to your tenant and the RTB at the same time”.

It doesn’t say it has to be sent to the RTB on the date it is deemed to have been served.
 
No, it says “you must send the notice to your tenant and the RTB at the same time”.

Can you link to the relevant section of the Act where you see this?

I see the below under "Requirements for a valid notice of termination"

"F190[(1A) Where a notice of termination is served by a landlord, the landlord shall serve a copy of the notice on the Board on the same day on which the notice is served on the tenant, and where the copy is not so served the notice shall be invalid."

 
Yes and how do you serve notice?

You send it by (certified) post and it is deemed to have been served on the date of receipt in the ordinary course - ie the following working day.

I really think you are overthinking this - there is no contradiction between the RTB guidance and the legislation.
 
But I don't send it by post to the RTB. I upload to their portal.

No, it says “you must send the notice to your tenant and the RTB at the same time”.

Can you please link where it says this? I think this is key, so I'd like to find it.
 
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