The Government’s Consultation on the Leasehold and Commonhold Reform Bill – a Response from Leaseholders at Chelsea Bridge Wharf and the Rendall and Rittner Action Network
24th February 2026
A group of leaseholders at Chelsea Bridge Wharf and Rendall and Rittner Action Network
London SW11
residents@chelseabridgewharf.org.uk
Dear Madam/Sir
This is my response to your consultation on the draft Leasehold and Commonhold Reform Bill
Summary:
This submission raises concerns that the draft Leasehold and Commonhold Reform Bill fails to deliver on the government’s commitment to end the leasehold system and risks creating a two-tier housing market in which existing leaseholders remain trapped while new properties move to commonhold. A key issue identified is the lack of clarity on enfranchisement rates. Without affordable and predictable pricing for buying the freehold, many leaseholders will be unable to convert to commonhold and will remain dependent on freeholders indefinitely.
The submission highlights widespread problems experienced by leaseholders across the UK, based on experience through the Rendall and Rittner Action Network, including high service charges, poor service quality, lack of transparency, and limited accountability. Survey evidence from 2025 suggests these problems remain prevalent, with many leaseholders facing financial stress and difficulty selling their homes.
While Right to Manage (RTM) can provide some empowerment, the submission argues that it is currently too difficult to obtain and vulnerable to abuse once implemented. Insufficient legal requirements around governance mean that small groups of directors can exercise power without meaningful elections, consultation, or accountability. The experience at Chelsea Bridge Wharf is presented as an example of how RTM can fail without stronger safeguards. Reforms are therefore proposed to improve transparency, democratic participation, and regulatory oversight of RTM companies.
The submission also criticises the failure to include remaining Law Commission recommendations on enfranchisement and RTM, the proposed ground rent cap timeline extending to 2068, and barriers affecting leaseholders in mixed-use buildings or those who did not initially participate in enfranchisement. It argues that managing agents should be prevented from obstructing RTM and should face stronger regulation and sanctions for non-compliance with legal obligations.
The submission concludes that stronger reforms are needed to ensure affordable enfranchisement, easier access to RTM, proper regulation of managing agents and RTM companies, and a genuine transition to commonhold. Without significant changes, most leaseholders will remain in the current system for the foreseeable future.
Our full response:
1. Failure to honour promise to end leasehold and creation of a two tier system of ownership
I am concerned that the draft Leasehold and Commonhold Reform Bill does not deliver on the government’s manifesto commitment to bring the feudal leasehold system to an end. In its current form it would leave most of the existing 5 million leaseholders exactly where they are and most will continue to find it very difficult to even achieve Right to Manage let alone enfranchisement or transfer to commonhold.
2. Lack of clarity on enfranchisement rates
Because collective enfranchisement will be a prerequisite for conversion to commonhold, uncertainty around pricing undermines the entire reform programme. The government promised a consultation on valuation rates, but this has not happened. Without cheaper and clearer enfranchisement terms, many flat owners will never be able to acquire the freehold, which in turn prevents them from converting to commonhold and leaves them trapped and at the mercy of freeholders indefinitely.
3. The misery that many leaseholders face – trapped and powerless with extortionate service charges, poor service and no redress.
I have spoken to leaseholders at hundreds of developments across the UK as part of my work for the Rendall and Rittner Action Network. I founded this group in 2020, initially as a response to the concerns which I and many other residents felt about escalating service charges and declining service at our own development (Chelsea Bridge Wharf, London SW11). I was soon contacted by leaseholders from many other developments who were experiencing the same problems and were stressed and unhappy, and in some cases unable to sell their flat and unable to afford to stay there either.
4. Open letter and petition to Rendall and Rittner
With leaseholders at many other developments managed by Rendall and Rittner, I published an open letter to Rendall and Rittner in 2020 https://chelseabridgewharf.org.uk/wp-content/uploads/2020/07/enough-is-enough-an-open-letter-to-rendall-rittner-21st-july-2020-final.pdf which was updated in 2025 https://chelseabridgewharf.org.uk/2025/06/04/2025-open-letter-to-rendall-and-rittner/ and an associated petition to Rendall and Rittner that now has over 6,200 verified signatures. https://c.org/vYQx5k7qnY . This petition was citied in a letter to Rendal and Rittner from Florence Eshalomi MP Chair, Housing, Communities and Local Government Committee, in July 2025 https://chelseabridgewharf.org.uk/2025/07/03/our-petition-is-cited/ following Rendall and Rittner’s appearance in parliament to answer questions in May 2025 which I was kindly invited to attend as an observer.
5. Survey of leaseholders at Rendall and Rittner managed developments in 2025
https://chelseabridgewharf.org.uk/2025/06/01/online-survey-of-rendall-and-rittner-leaseholders/ which showed that all the problems identified in 2020 were unresolved and if anything were getting worse as shown in key findings below:
Summary of 2025 survey of leaseholders at Rendall and Rittner developments across England (368 responses)
- High service charges (generally)’ was the most cited issue, mentioned by 96.8% (363 respondents )
‘Poor service generally’ and ‘Poor tendering, procurement leading to bad value for money’ were also very common, reported by (83.7%, n=308) and (77.7% , n=286) of respondents, respectively. - ‘Failure to maintain your block/ development to a good standard’ was reported by 68.5% of respondents (n=252) .
- Issues related to the supply of accounts were also frequently mentioned (45% saying accounts not produced at all, 62.8% saying accounts not supplied in a timely way and 61.1% citing failure to supply full or meaningful accounts).
- 49% of respondents (n=183) referred to failure to deal with fire safety issues and 16.6% (n=41) cited unwarranted interference in their residents’ association or management company by Rendall and Rittner
- Service Charge Amounts: The average (mean) annual service charge is approximately £5,762.69.
Despite the open letters, petition and survey evidence, we have never had any meaningful response from Rendall and Rittner.
6. The need for greater democratic checks and balances to prevent abuses by dysfunctional Right to Manage companies
Right to Manage can and does work in some developments and (as I deal with later on) should be made much easier for leaseholders to obtain, but it is also wide open to abuse by controlling, unscrupulous, unethical, or corrupt RTM directors. What is intended as a transfer of power from freeholder to leaseholders can, in reality, become a transfer of power to a handful of unelected and unaccountable leaseholders. I am aware of many such cases and quite a few are also documented on the website of various leasehold campaigning organisations.
There is no requirement either in current legislation or in the reforms in the Leasehold and Commonhold Reform Bill for directors of RTM companies to be elected, nor even to hold an annual general meeting (AGM). They need not meet with or consult residents at all, apart from statutory consultations for large expenditure projects which require a Section 20 consultation.
This means that at many developments two or three leaseholders can form the RTM company, take over as directors, and abuse the levers of power and the tools available to incumbents to stay in power, never subjecting themselves to election, accountability, or scrutiny from leaseholders. There are a great number of such cases of which I am aware, and I am sorry to have to say that one of the worst is my own development, Chelsea Bridge Wharf, London SW11.
At Chelsea Bridge Wharf there has been a history of misinformation, bullying, and electoral manipulation by the residents’ association (Chelsea Bridge Wharf Residents’ Association), which eventually “morphed” into the Chelsea Bridge Wharf Right to Manage Company.
The background is that this group of people for many years misinformed residents that Right to Manage was not possible and used incorrect advice from the ‘’well known’’ consultant, Roger Southam[1][2], https://en.wikipedia.org/wiki/Roger_Southam to justify this.
When I alerted residents to the fact that they were being misinformed by the Chair of CBWRA and the committee, and that RTM was possible at Chelsea Bridge Wharf, I was severely bullied by members of the residents’ association[3]. False allegations were made against me which they were never able to substantiate, and I was excluded. Others who objected to the behaviour of the CBWRA were treated in a similar way. https://chelseabridgewharf.org.uk/2022/11/15/the-orwellian-world-of-the-chelsea-bridge-wharf-residents-association/
This residents’ association also colluded with the then managing agent, Rendall and Rittner, such that the Chelsea Bridge Wharf Residents’ Association took the extraordinary step of “banning” my petition against Rendall and Rittner. I was told that I had to take the petition down or leave the residents’ association committee. I chose the latter.
In 2022 the residents’ association falsely claimed to have started a Right to Manage process and in the same year published a newsletter claiming that I was misleading residents by stating that Right to Manage was possible!.
Despite this intense campaign of bullying and character assassination by the Chelsea Bridge Wharf Residents’ Association, I continued to campaign for Right to Manage and obtained independent advice confirming that the advice given by Mr Southam was wrong and that Right to Manage was entirely possible at Chelsea Bridge Wharf. https://chelseabridgewharf.org.uk/wp-content/uploads/2022/06/canonbury-summary-advice-1.6.22-correspondence-1522672.pdf
In the face of this unequivocal evidence, in mid-2023, the CBWRA Chair and committee members suddenly changed position to support Right to Manage but never apologised to me nor withdrew any of their false allegations. Many of these same people are currently directors of the Chelsea Bridge Wharf Right to Manage Company, or were until recently.
One of the directors of what eventually became the Chelsea Bridge Wharf RTM company has been the subject of multiple police complaints (three from me) and allegedly physically assaulted another leaseholder, and with a witness and CCTV evidence, led to the police authorising charges of common assault (this process was later timed out due to police delays, but it is all documented with crime reference numbers).
Chelsea Bridge Wharf eventually obtained Right to Manage in May 2025, and Urang were appointed as the new agent in a highly secretive and undemocratic way[4]. https://chelseabridgewharf.org.uk/2025/03/09/how-urang-were-selected-to-be-the-new-agent-at-chelsea-bridge-wharf/
- At the current time, despite Right to Manage, leaseholders at Chelsea Bridge Wharf:
- Cannot view the management contract with Urang (this has recently been offered subject to an NDA which is so sweeping and restrictive that no reasonable person could sign it).
- Cannot see notes of meetings between the RTM company directors and Urang.
- Cannot hear a recording or see a transcript of meetings between Urang and leaseholders and are instead given notes by Urang which are a complete misrepresentation of the meetings with residents, omitting all criticism of Urang and the directors https://chelseabridgewharf.org.uk/2025/11/16/the-real-notes-from-the-meeting_urang_150925/
- Cannot vote for directors in a meaningful election.
- Cannot participate in a meaningful AGM (there has been ONE AGM in the entire history of the Chelsea Bridge Wharf Right to Manage Company (in December 2025) using LUMI software and that lasted nine (9) minutes: leaseholders were not able to see or hear each other and there was no discussion of any kind. https://chelseabridgewharf.org.uk/2025/11/24/the-chelsea-bridge-wharf-agm-less-than-10-minutes-long-and-no-questions-or-discussion/
- Cannot see the results of a ‘resident’s survey’ carried out by Urang in November 2025.
- Are not consulted on our priorities / how our service charges should be spent.
Elections for directors of the Chelsea Bridge Wharf Right to Manage Company were eventually forced through by me and other leaseholders, but these were carried out in a highly manipulated way so as to be meaningless. There was no debate or forum between directors or any chance for leaseholders to ask them questions, and an opaque voting system was used, with no ‘’abstain’’ option, which allowed one of the candidates (the ‘Chair’[5], Louis-Sebastian Kendall) to use all ‘neutral’ votes for himself or other candidates while refusing to disclose how many such votes were used.
Even after Right to Manage, and having replaced Rendall and Rittner with Urang, there is little or no consultation with residents, and Urang and the RTM directors tried to push through a major Section 20 notice just before Christmas (when many leaseholders were on holiday/away from the development) and later had to withdraw this notice. https://chelseabridgewharf.org.uk/2026/01/25/a-section-20-farce-by-urang-at-cbw/
7. Failure to include law commission recommendations on Right to Manage and enfranchisement
The draft bill does not incorporate the outstanding Law Commission recommendations relating to enfranchisement and the Right to Manage. In particular, the absence of measures to limit development value within enfranchisement valuations could lead to substantial cost increases, placing the acquisition of the freehold out of reach for many leaseholders. This creates a real danger that current homeowners will remain trapped within the leasehold system, while prospective purchasers increasingly favour commonhold properties, which provide democratic oversight of building management and service charges.
The Right to Manage framework itself also continues to require considerable improvement. While the 2024 Act introduced some reforms, the procedure remains excessively complex and open to obstruction from freeholders and their legal representatives. Claims can still be defeated by minor technical mistakes, and tribunals do not have sufficient discretion to overlook such errors where no prejudice has been caused. In my view, Right to Manage should evolve into a universal entitlement, particularly given the expectation that commonhold will become the standard form of tenure for new flats. Without further reform, existing leasehold homes risk becoming progressively less desirable and harder to sell.
8. Participation rate for RTM and enfranchisement must be lowered to 35%
In particular, I believe the participation threshold for Right to Manage claims should be reduced from 50 percent to around 35% or less, as achieving 50 percent participation is often unrealistic in developments with many absentee landlords or large numbers of investor-owned units. I can say this from long personal experience of canvassing by door knocking, newsletters, meetings, etc. It took a very long time to get 50% of the 1132 leaseholders into an RTM company at Chelsea Bridge Wharf.
9. Managing agents should be prevented from blocking RTM
Managing agents can and do obstruct RTM processes, and this needs to be stopped. They should be compelled to help such processes (or at least not stand in the way), for example by passing communications about RTM to all leaseholders on their lists where there is a residents’ association that wants to pursue RTM or investigate it.
There should be tribunal remedies where directors (i.e. leaseholders) obstruct membership of RTM companies and when they engage in the other undemocratic behaviours referred to in relation to Chelsea Bridge Wharf and other developments.
I have also heard of cases where managing agents have removed posters from communal areas which seek to raise awareness about Right to Manage or to organize meetings on RTM.
10. Ground rent cap
The proposal to cap ground rents at £250 from 2028 and only reduce them to a peppercorn by 2068 is essentially a cave in to freeholders. Why should investors be given a 40 year transition period?. This is not exactly ‘abolishing leasehold’ as the government has often promised and indeed boasted about, is it?
11. Leaseholders prevented from joining enfranchisement ‘after the fact’
Another issue is the lack of a Right to Participate for leaseholders who did not join an original collective enfranchisement claim or who purchased later. Without such a right, some residents remain excluded from ownership and decision-making within their own buildings, which undermines fairness and complicates future conversion to commonhold. I believe introducing a Right to Participate is now even more important to prevent a two-tier market and to support wider adoption of commonhold.
12. Leaseholders in mixed use buildings
Even with reforms to the commercial space threshold, many leaseholders may still be excluded from enfranchisement because of structural dependency rules relating to shared services. This undermines the intention of previous reforms to expand access and should be addressed.
13. Specific recommendations / chnages to the Bill which are proposed:
We propose the following specific changes to the leasehold and commonhold reform bill
- Abolish ground rent and leasehold with urgency and not in 2.5 years’ time when the government may not even last that long or other priorities may emerge which prevent this bill passing and / or being enacted.
- Managing agents to be regulated in a strong way with a meaningful regulator — the ombudsman is a joke and currently so backlogged it is pointless to complain. They are also toothless. We need serious sanctions, fines, and jail time for agents who can be shown to be ripping off leaseholders.
- A managing agent’s failure to comply with Sections 21 or 22 of the Landlord and Tenant Act 1985 should be a criminal offence, with serious fines or potential jail sentences. Refusal to supply invoices and records of accounts to leaseholders makes it impossible for them to check how their service charge funds are being spent. Currently there is no meaningful sanction for failure to comply with Section 21/22 requests, and the last prosecution by a local authority (which in theory has this responsibility) was in 1998.
- Managing agents should be obliged to pass on details of RTM meetings to their list of leaseholders and should be prevented from obstructing the process in any way.
- RTM companies must also be regulated, and directors should be forced to stand in fair elections using a standardised electoral process annually.
- A mandatory AGM and at least two other meetings a year with residents.
- A mandatory annual vote of leaseholders with regard to renewing the contract of the agent. If a majority vote against, then retendering must take place, either by the freeholder or RTM company. This means that the agent can be changed with or without RTM.
- A mandatory annual vote of leaseholders to approve or reject the service charge budget.
- Dysfunctional RTM companies should be subject to investigation by a regulator if 20% of members demand it, and directors who do not respect the Articles of Association should be sanctioned or barred from being directors of the RTM company.
- The threshold for RTM should be 30% of leaseholders (not 50%).
- Purchase of the freehold should be capped at £2,000.
- The process for conversion of leasehold to commonhold must be cheap, simple, and heavily supported by government with advice and training, or it will never happen. The threshold here should also be 30% (not 50%).
- We need a national database of RTMs and RMCs to see what percentage of leaseholders/developments are governed by these, whether that number is growing, and also how many (number and percentage) are converting to commonhold.
- Adopt all recommendations of the Law Association on RTM.
- The government also needs to make all the provisions in LAFRA “live” immediately.
In conclusion
The government has not kept its promise to abolish leasehold, and at the current rate even LAFRA will not be fully made live by the end of the Parliament, let alone the Commonhold Bill. The government is widely perceived to have “caved” to freeholders and to be dragging its feet and watering down leasehold reforms wherever possible. It is certain that most of the estimated 5 million leaseholders will remain in leasehold for the foreseeable future and most will not even be able to achieve the limited empowerment which is offered by RTM. I am afraid the government will pay a heavy price for this at local and national elections unless there is a major change of attitude and direction.
[1] Mr Southam was appointed as non-executive chair of the government-funded Leasehold Advisory Service (LEASE) in December 2014.[5] Since then his suitability for the role has been questioned, for example see Private Eye No 1448, 27 July 2017, page 37 “Going Southam”.[6]
[2] https://www.leaseholdknowledge.com/category/news/roger-southam/
[3] An extensive archive of emails, screenshots, zoom recordings, phone calls and complaints to the police by me, supports this statement.
[4] The Leasehold Knowledge Partnership published a blog piece on RTM being achieved at Chelsea Bridge Wharf but they were so determined to make political capital from this (the UK’s largest RTM, huge victory for leaseholders etc) that they chose to write a highly selective and ,in my view, misleading account of events at this development which airbrushed out a number of rather important facts (as can be seen from the comments at the end of the article). Despite all the published evidence regarding the Chelea Bridge Wharf Residents’ Association and RTM company, LKP bizarrely continue to cite CBW as some sort of model RTM when it is the very opposite.
[5] There is no record accessible by leaseholders of Mr Kendall having ever been elected or appointed as Chair of the CBW Right to Manage Company.