The RTB welcomes the publication of the CSO Frontier Series Research Paper ‘Rented from Private Landlords 2022’ which, for the first time, provides greater insights into the difference between the CSO data, gathered through Census 2022, and RTB private tenancy registrations data. Of the 73,002 tenancies that the research identifies as not registered with the RTB, 25,248 are possible ‘formal’ rental arrangements that should be registered. The remaining 47,754 possible ‘informal’ rental arrangements are likely to be outside the scope of RTB regulations.
In total, the CSO matched 238,433 tenancies on the RTB Register of Private Tenancies with data collected on Census night. When the matched dataset is compared with the 25,248 possible ‘formal rental agreements’ that the research suggests were not registered, it would appear that over 90% of tenancies that should have been registered with the RTB were in fact registered.
The project was initiated following the publication of Census 2022 data which showed there were 330,632 households living in the private rented sector on 3rd April 2022, while the RTB Register of Private Tenancies showed that there were 246,453 private tenancies registered at the end of Q4 2022. In considering the CSO analysis it is important to note that the Census and RTB Register are two completely different datasets, collected at different points in time, using very different mechanisms.
Over the last 12 months, the RTB has engaged with the CSO and provided data from the RTB Register of Private Tenancies to assist with the research project. Following an extensive data matching exercise, the final difference between Census 2022 data and RTB data was reduced from 84,179 to 73,002 unmatched private rentals. Subsequent assessment of additional administrative data enabled the CSO’s classification of the unmatched dwellings into two categories – possible informal rental arrangements, and possible formal rental arrangements.
In accordance with the Statistics Act 1993, the CSO is unable to provide the RTB with a list of the properties subject to possible ‘formal rental’ arrangements, which were not registered with the RTB. The research makes an important contribution to the RTB’s understanding of potential non-compliance, and will continue to inform our approach to develop and enhance our enforcement activities – a key strategic priority in our current RTB Statement of Strategy (2023 – 2025).
Within the lifetime of the RTB’s Statement of Strategy 2023 – 2025 we have committed to:
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implement a new compliance function to identify and address low risk non-compliance at the lowest level of cost and complexity
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develop a risk rating to assist in identifying levels of non-compliance
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develop new efficient methods for analysing large datasets from other public bodies to identify potential non-compliance
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strengthen our escalation pathways to ensure that the most serious offenders are identified and pursued through either civil sanctions or criminal prosecutions as appropriate and in the public interest
In addition to this work, the RTB has also been working with officials in the Department of Housing, Local Government and Heritage on new proposed legislation. The recently published Residential Tenancies (Amendment) No. 3) Bill will provide a legal basis to facilitate the sharing of data by the Revenue Commissioners with the RTB for the purposes of identifying potential non-compliance.