Six-Month Window - Using Ground 4a
>This article explains how/when landlords and agents can start advertising their student properties, dealing with the six-month window required by the Renters' Rights Act.
The Renters’ Rights Act 2025 has changed how student landlords recover possession of properties between academic years.
One of the biggest changes is the introduction of Ground 4A, a new possession ground designed specifically for student accommodation.
For landlords of student HMOs, there is an important restriction: to rely on Ground 4A, the period between the tenancy being entered into and the date the tenants are entitled to possession must be six months or less. (Legislation.gov.uk)
This has caused understandable concern for landlords and agents who traditionally let student properties many months before the next academic year.
At Purple Frog, we have reviewed the legislation, Government guidance and published legal guidance. We have adapted our tenancy processed so that we continue marketing student properties in line with the student letting season, while protecting our landlords’ ability to rely on Ground 4A.
What does Ground 4A do?
Ground 4A allows a landlord to recover possession of qualifying student accommodation so it can be let to another group of students for the following academic year. Without it, landlords can't be sure to have possession of their properties at specified date for the next set of tenants.
For a new tenancy, the main requirements include:
- the property must be an HMO, or form part of an HMO;
- the tenants must meet the Act’s student test when the tenancy is entered into;
- the landlord must give the tenants a written Ground 4A statement before the tenancy is entered into;
- no more than six months must pass between the tenancy being entered into and the tenants becoming entitled to possession;
- the relevant possession date must fall between 1 June and 30 September; and
- the landlord must intend to let the property to qualifying students again.
Government guidance summarises the six-month restriction by saying Ground 4A cannot be used where the tenancy was agreed more than six months before the tenancy starts. (GOV.UK)
>Does this mean we have to wait until January to find tenants for a July tenancy? No.
There is an important distinction between finding tenants and obtaining their commitment to proceed and the point at which the tenancy itself is legally entered into.
The legislation does not say a property cannot be marketed more than six months before occupation.
It does not say prospective tenants cannot select a property earlier.
The relevant statutory test concerns the date on which the tenancy is "entered into".
This distinction allows us to continue marketing student properties during the traditional student letting season while controlling when the tenancy itself becomes binding.
How Purple Frog’s process works
For a typical tenancy where students become entitled to possession on 1 July, our process works as follows.
We market the property during the normal student letting season.
Once a group decides to proceed, Purple Frog issues the proposed tenancy documentation. The documentation includes the required Ground 4A written statement.
The tenants receive the full documentation and sign first.
Our contractual process is designed so that the tenants’ signatures do not themselves create a binding tenancy. Their agreement is subject to subsequent acceptance on behalf of the landlord.
Purple Frog then formally accepts the tenancy on behalf of the landlord (or the landlord signs directly) within the six-month period preceding the date on which the tenants become entitled to possession.
For example:
October 2026: Students select the property and complete their part of the process.
October 2026: Students receive the proposed tenancy agreement, including the Ground 4A written statement, and sign.
January 2027: Purple Frog accepts the tenancy on behalf of the landlord.
1 July 2027: The students become entitled to possession.
The tenancy is therefore entered into within six months of the students becoming entitled to possession.
Why do we consider the tenancy to be entered into when it is accepted?
The Renters’ Rights Act uses the words “entered into” rather than simply referring to the date on which a prospective tenant signs a document.
This distinction also appears elsewhere in Government guidance.
The Ministry of Housing, Communities and Local Government has published statutory guidance dealing with rent payments under the Renters’ Rights Act. One of its examples describes a tenant signing a tenancy before the landlord signs it.
The Government describes rent taken during this intervening period as having been taken before “the tenancy has been entered into by both parties.” (GOV.UK)
The explanatory notes to the Act also refer to rent being paid following a tenancy being “entered into by all parties” and before the tenancy starts. (Legislation.gov.uk)
This provides useful support for structuring a tenancy process where prospective tenants sign first and the landlord or their authorised agent subsequently accepts the agreement.
The exact contractual wording remains important. Simply leaving a landlord’s signature off an agreement does not necessarily prevent a contract from arising. Our process is therefore designed to make clear when the tenancy becomes binding.
What about the Ground 4A statement?
Ground 4A requires the landlord to give the tenants a written statement of the landlord’s intention to rely on Ground 4A before the tenancy is entered into.
Purple Frog includes this statement within the tenancy documentation itself.
The tenants therefore receive the Ground 4A statement when they receive the proposed tenancy and before Purple Frog subsequently accepts the agreement on behalf of the landlord.
This also gives us a clear electronic record showing when the tenants received and signed the documentation and when the tenancy was subsequently accepted.
Why are we taking this approach?
The student rental market operates differently from much of the private rented sector.
Students routinely look for accommodation for the following academic year many months before they intend to move in. Preventing landlords from marketing properties until six months before occupation would significantly change the established student letting cycle.
The legislation itself does not impose such a restriction, instead, Ground 4A focuses on when the tenancy is legally entered into.
Is this interpretation settled law?
Ground 4A is new legislation. There is not yet a body of reported court decisions interpreting precisely when a tenancy is “entered into” for the purposes of the six-month Ground 4A requirement.
Some published guidance uses simplified language. For example, Shelter currently describes the requirement as the tenant having “signed the tenancy agreement less than six months before they moved into the property”, while the NRLA similarly refers to the tenancy being “signed” within six months. (Shelter England)
The wording of the Act itself is more specific. Parliament chose “entered into”, and Government statutory guidance elsewhere under the same Act expressly distinguishes a tenant signing an agreement from the tenancy subsequently being “entered into by both parties”. (Legislation.gov.uk)
We have structured our process around the statutory wording and this Government guidance.
As the new legislation develops, we will continue reviewing Government guidance and relevant court decisions and will update our process where required.
What does this mean for Purple Frog landlords?
For most of our student landlords, there should be little visible change to the letting cycle.
We intend to continue advertising properties at the appropriate point in the student market rather than waiting until six months before the next tenancy begins.
The difference sits mainly behind the scenes.
Purple Frog will control the contractual process and the date on which the tenancy becomes binding. We will also retain records showing when the Ground 4A statement was provided, when the students signed and when the tenancy was formally accepted.
The aim is simple: continue securing next year’s students early while preserving the landlord’s ability to rely on Ground 4A where its statutory requirements are satisfied.
Sources
Renters’ Rights Act 2025, Schedule 1, Ground 4A.
Renters’ Rights Act 2025, Explanatory Notes.
Ministry of Housing, Communities and Local Government, Guide to the Renters’ Rights Act.
Ministry of Housing, Communities and Local Government, Asking for rent in advance: guidance for local authorities.
Shelter Legal, Assured tenancy mandatory grounds from 1 May 2026.
National Residential Landlords Association, Student Lettings Resources.
Landlord’s Guild, Ground 4A Written Statement (Student HMO Letting).