Pubs Code Adjudicator Releases Compliance Reports 2023-24

Transparency data

Pub-Owning Businesses' Compliance Reports 2023-24

As part of our ongoing commitment to ensuring transparency and fairness in the tied pub sector, the Pubs Code Adjudicator (PCA) has released an overview of key aspects of the latest annual Compliance Reports submitted by regulated pub-owning businesses (POBs). We have also released an infographic on the total number of pubs code agreements and size of the regulated estate.

From: Pubs Code Adjudicator Published 31 March 2025 Get emails about this page

Applies to England and Wales

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Pub-Owning Businesses' Compliance Reports 2023-24 Infographic

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Pub-Owning Businesses’ Compliance Reports 2023-2024: key themes and insights

As part of our ongoing commitment to ensuring transparency and fairness in the tied pub sector, the Pubs Code Adjudicator (PCA) has released an overview of key aspects of the latest annual Compliance Reports submitted by regulated pub-owning businesses (POBs) for the period 2023-2024.

What are Compliance Reports?

Under the Pubs Code, which regulates the relationship between POBs and their tied tenants, POBs must submit an Annual Compliance Report to the PCA by 1 August based on the latest data to the year-end 31 March.

Compliance Reports provide information about estate size and a detailed and accurate view account of how each POB is adhering to its obligations and responsibilities under the Pubs Code, across areas such as rent reviews, Market Rent Only (MRO) options, resolution of disputes. They must include instances of breaches raised or alleged by tenants and the steps taken by the POB as a consequence to ensure compliance.

How do Compliance Reports help the PCA understand practice within POBs?

Compliance Reports are important in helping the PCA assess how the industry is managing key aspects of their relationship with their tied tenants.

While they show how individual POBs are performing and any areas of good practice, Compliance Reports are also useful in identifying areas that need improvement. And by reviewing all submissions collectively, the PCA is able to identify sector-wide similarities and differences and work more effectively to drive further positive change in the support of fair treatment for tied tenants.

Key themes from 2023-2024’s Compliance Reports

This year’s Compliance Reports for the period 1 April 2023 to 31 March 2024 have revealed some interesting developments and areas of ongoing focus across the sector in comparison to the previous year’s reports. Notably:

The total number of Pubs Code agreements at the end of March 2024 sits at 7,983. This is a reduction of -1.6% (or 126) on the previous numbers reported by the POBs.

• Admiral saw the largest decrease at -5.8% while Marston’s saw the largest increase in estate size at 2%.
• Since 2018 however, the pubs code estate size has decreased 21% across all 6 regulated entities, with only Admiral increasing their estate size (by 42%). Stonegate has seen the largest decrease at 32%. 20 tied tenants formally attempted to price-match their premises insurance by providing the pub company with a tenant’s alternative policy and in 8 cases, the pub company accepted it as suitable and comparable (40%). This is slightly more than the previous year, when 19 attempts to price-match by giving a tenant’s alternative policy were made, of which 26% were successful. These numbers are low and may reflect competitive insurance costs and/or limited awareness of this right as reflected in the 2024 tied tenant survey.

POBs received 130 Market Rent Only notifications over this period, 30 fewer than the previous year. 48 tenants went on to enter a MRO agreement with their POB.

• Star (43), followed by Stonegate (38) had the highest number of MRO notices in 2023-24. As a proportion of estate size, Greene King had the highest number of MRO notices.
  The number of legal surrenders increased this year from 414 to 441.

• Stonegate reported the highest number of surrenders, with Marston’s having the most for their relative size.
  Total abandonments stand at 79 this year in total from 67 last reporting period.

• Stonegate reported the highest number of abandonments (41 or 52% of the total this period) representing under 2% of their tied estate.
  The number of agreements with protection under the Landlord and Tenant Act 1954 has reduced from 3,035 to 2,676. This reflects a trend each year since 2016.

POBs are required to self-report any failure to comply with the Pubs Code (referred to as a breach). POBs reported 82 alleged breaches of the Pubs Code within their Compliance Reports this year. Some will cover more than 1 breach of a regulation or breaches of multiple regulations and some may cover more than 1 tenant. The PCA reviews all self-reported breaches and considers a number of factors in deciding its regulatory approach.

Publishing Compliance Reports

Pub-owning businesses must publish their annual Compliance Reports on their website; all have done so.

Looking Ahead

The PCA will continue to monitor POBs’ compliance closely using a range of sources of information (such as through the self-reported breach process) to help inform the PCA’s regulatory priorities.

The intelligence and insights from the annual Compliance Reports inform discussions at bi-annual CEO meetings, where the PCA engages directly with the pub-owning businesses’ senior leaders to address challenges and opportunities in delivering fair outcomes for tied tenants, as well as those at CCO roundtables designed to identify common areas of good practice in ways of working.

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Published 31 March 2025

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