If you own the freehold of a Victorian or Edwardian terrace conversion, the same five statutory duties apply to you as they do to a managed block. That holds whether you collect ground rent and service charge by bank transfer, or hand-write demands once a year. Most informal freeholders don't know this. Their leaseholders increasingly do.
Information only. Not legal advice. Always take qualified advice on a specific situation.
There are 4.83 million leasehold dwellings in EnglandMHCLG, Leasehold Dwellings 2023-24, published 22 May 2025. 72% (3.48 million) are flats; 28% (1.35 million) are houses. Read the full release →, of which a substantial share are flats in converted Victorian and Edwardian terrace houses (the English Housing Survey records that 14% of private rented dwellings are converted flatsEnglish Housing Survey 2023-24. Converted flats are most prevalent in the private rented sector. Read the leasehold fact sheet →, well above purpose-built rates). Most of those converted blocks have no managing agent, no resident management company, no Section 20 paper trail, and a freeholder who never thinks of themselves as a "director". This page is for that freeholder.
You bought the house, converted it (or it was converted before you), sold off the flats on long leases, and kept the freehold. Or you and the other flat owners share the freehold informally between you. You might collect a few hundred pounds of ground rent each year by bank transfer. You sort the buildings insurance once a year. When the roof needs work or the front of the house needs repainting, everyone chips in. That's who this page is written for.
Here's the catch. The Landlord and Tenant Acts of 1985 and 1987 don't ask whether you have a company, a managing agent, or a paper trail. They ask one question: do you own the reversion on a long residential lease? If the answer is yes, you are a "landlord" for the purposes of those Acts. The same five statutory duties that apply to a 200-flat block in Canary Wharf apply to your 3-flat conversion in Walthamstow.
The good news: the duties aren't onerous if you know what they are. The bad news: leaseholders increasingly know what they are, and the Tribunal is a near-zero-cost forum for them to enforce them.
Each one is short. Each one has a specific section number you can quote. Each "no" is real exposure if you ever end up at the First-tier Tribunal.
The Summary is in a prescribed form set by the Service Charges (Summary of Rights and Obligations, and Transitional Provision) (England) Regulations 2007. It must be served with the demand, in the prescribed font size and format. Without it, the leaseholder is legally entitled to withhold payment until you reissue a compliant demand.
Exposure if missing: leaseholder withholds payment lawfully. You cannot recover until you re-serve a compliant demand. The 18-month time limit in Section 20B keeps running while you fix it.Section 47 requires your name and address on every written demand. Section 48 requires you to provide a service address in England & Wales. A bank-transfer email saying "rent due, transfer £150 to acc 12345678 by Friday" almost certainly fails both. So does a generic letterhead with no service address.
Exposure if missing: rent and service charge are not legally "due" until you serve a compliant demand. Leaseholder can withhold without breach.The contributions you collect are not your money. Section 42 places them on a statutory trust for the leaseholders of the building. They should be in a separate client account, not your personal current account, and you should be able to show what's in the fund and what it has been spent on.
Exposure if breached: leaseholders can seek the return of all funds, plus a Tribunal can order an audit of how the money was used. Mixing with personal funds is a serious breach of trust.In a 4-flat conversion, works costing more than £1,000 in total trigger Section 20 consultation. There is a prescribed three-stage process: notice of intention, observations period, notice of estimates. New roof, full repaint, replacement windows, major plumbing. All almost always trigger Section 20.
Exposure if skipped: the recoverable cost from each leaseholder is statutorily capped at £250 regardless of what you actually spent. A £30,000 roof becomes a £1,000 recovery on a 4-flat block. You absorb the rest.Most leases place the structural repair obligation on the freeholder. If the roof leaks and you don't fix it within a reasonable time, the leaseholder can sue for breach of covenant, claim consequential damage to their flat, and apply to the Tribunal for an order for specific performance. "We were planning to do it this summer" is not a defence.
Exposure if neglected: damages claim from each affected leaseholder, Tribunal order to do the works, plus the legal costs of being on the wrong end of a covenant claim.A small share-of-freehold block on the same road as our building was about to spend £20,000 on a new roof. I asked: had they run a Section 20 consultation? They said no. They didn't know they had to. The leaseholders' share of the cost was 66% of the bill, around £13,200. Without a compliant consultation, statute caps recovery at £250 per leaseholder. Total recoverable: a few hundred pounds. The freeholder would have absorbed the rest, on a roof everyone agreed was needed and everyone expected to share. They flagged it to me before signing the contract. We sequenced the consultation properly first. The roof went on. Everybody paid their share. Section 20 isn't a hurdle for stalling. It's the only mechanism that lets you actually recover the money you've spent.
The duties are the same in all three. The starting point and the practical fix differ.
Single freeholder, 2–6 flats on long leases. You collect ground rent annually, sort the buildings insurance, and pay for occasional repairs. You probably don't issue formal service charge demands at all. You just split the bill.
Three or four flat owners co-own the freehold. There is a freehold company on Companies House but nobody really treats it as a company. You meet over coffee, agree what needs doing, and chip in. No board minutes, no formal demands, no client account.
Post-Right to Manage or post-collective enfranchisement. Your previous agent walked away or you fired them. The leaseholders inherited the management with no handover, no document set, no template demand. You're improvising.
Three things have shifted in the last two years. None of them favour the informal freeholder.
First-tier Tribunal disposals rose 51% in Q3 2025 (HMCTS Quarterly Statistics). Leaseholders are using the Tribunal more, not less, because there is no costs award against them in most service-charge cases. They lose nothing financial by challenging your demand. You lose if a single line of it doesn't comply.
Five years ago, the asymmetry was: freeholder had a managing agent and template letters; leaseholder had a copy of their lease they'd never read. That asymmetry is collapsing. A leaseholder with a £7 HMLR lease copy and any AI tool now has more legal context on their lease in ten minutes than most informal freeholders have ever had.
Here is the trap. Generic AI like ChatGPT regularly misreads leases. It hallucinates clauses, miscites statute, and misses where your lease overrides the default position. The leaseholder may be acting on completely wrong analysis. It still creates a dispute you have to defend. A leaseholder armed with a confidently-wrong ChatGPT answer can still write you a letter, withhold payment, or apply to the Tribunal. You then have to spend time and money proving why their reading is wrong, clause by clause, statute by statute. The cost of a dispute caused by a wrong AI answer is identical to one caused by a right one.
The RICS Service Charge Residential Management Code, 4th edition came into force on 7 April 2026 via Statutory Instrument 2026/298. Approved by the Secretary of State. Around 100 pages, extensively rewritten from the 3rd edition. Section 14.8 specifically governs the format and content of service charge, ground rent, and administration charge demands. Mandatory for any RICS-regulated managing agent. It is complex.
Separately, the LFRA 2024 will impose its own statutory prescribed demand format via secondary legislation. MHCLG consulted in 2025 (closed 26 September). Regulations are expected with transitional arrangements. Until they land, the existing Section 21B, Section 47/48, and Section 42 duties remain in force in primary law.
In practice this means two things. One. If you use a RICS-regulated managing agent, you are already on the new regime as of April 2026. Two. If you self-manage or run an informal freehold, you are not strictly bound by the RICS Code, but a non-compliant demand template now invites a Tribunal challenge from any informed leaseholder. The smartest move is to align your template with the RICS Code 4th edition now and watch for the LFRA SI when it commences. See the full LFRA reference for what is in force versus what is pending.
Each one takes under an hour. Each one removes a category of exposure. Together they put you ahead of 80% of informal freeholders.
Tells you which of the five duties apply to your specific building (height, year built, gas, units), and which obligations you're missing. Pick "I'm a freeholder of a converted house" at the top.
Run the audit (free, 5 min) →Upload one recent service charge demand to LEASE-iQ. It checks Section 21B Summary of Rights, Section 47/48 name and address, and the demand format. £50 / 24 hours / clause-cited.
Test the demand →Move your service charge contributions out of your personal current account into a separate account labelled for the building. This is the simplest single step you can take to comply with Section 42.
How to set up a client account →Don't panic, but don't ignore it either. Re-serve a compliant demand for the current period. The 18-month limit in Section 20B keeps running, so the longer you wait, the more historic charges become irrecoverable. Talk to us if you want a solicitor-reviewed template. That's what Stream 2 of our Talk-to-us service does (£225 + VAT).