10th Nov 2025
By: Martin Harland, Service Manager at Warwickshire Trading Standards and Project Lead Officer.
In a region-wide initiative spanning over three years, Central England Trading Standards Authorities (CEnTSA) undertook a groundbreaking project to tackle non-compliance among letting agents. Known as Operation Jupiter, the project aimed to ensure agents were adhering to legal requirements around client money protection (CMP), redress scheme membership and consumer transparency. The outcomes have been impressive: over £11m in financial detriment prevented, 131 enforcement notices issued, and a return of £68.54 for every £1 spent.
Why it mattered
Letting agents handle large sums of money on behalf of tenants and landlords – rents, deposits and fees. Without proper safeguards, such as CMP, this money is vulnerable to mismanagement or fraud. In 2021, data from the then National Trading Standards Estate and Letting Agency Team (NTSELAT) revealed that 1,175 agents in the CEnTSA region lacked CMP, putting an estimated £117.5m at risk.
Despite the legal requirement for CMP, many agents were unaware, non-compliant or deliberately avoiding it. Operation Jupiter was launched to address this gap, with funding secured via NTSELAT from the Ministry of Housing, Communities and Local Government (MHCLG).
The project in action
The project ran from June 2022 to June 2025, involving 12 local authorities across the West Midlands. It was delivered in three phases:
● Year 1 (2022-23): This focused on training, data gathering and advisory work. Authorities began identifying non-compliant agents and preparing enforcement frameworks. Stoke advised 61 businesses to drive up compliance in their area.
● Year 2 (2023-24): This saw enforcement start in Coventry, Dudley, Staffordshire, Shropshire, Warwickshire and Wolverhampton. Notices of intent and final notices were issued, with the new legal administration processes being used for the first time.
● Year 3 (2024-25): The final push saw Birmingham, Sandwell, Telford, Walsall and Worcestershire actively issuing penalties.
Key outcomes
● £11.1m in detriment prevented – calculated based on average rents and deposits handled by agents without CMP.
● 131 final notices issued – targeting 74 agents, with most receiving multiple penalties.
● £861,578 in penalties – with over half collected by project close.
● £68.54 return per £1 spent – demonstrating exceptional value for money.
One landmark tribunal case involved a solicitor managing rental properties without CMP. The judge ruled that no exemption exists for solicitors. While this is not a binding judgment, it will help with future enforcement where solicitors are conducting lettings work.
There was an unexpected significant challenge in that HM Courts and Tribunals Service’s (HMCTS) administration changes at the end of 2024 caused confusion and delays. It involved the change of tribunal for all appealed notices by agents with only three days’ notice. All appeals lodged after 26 December 2024 were no longer to be heard in the General Regulatory Chamber but in the Residential Property Chamber.
Thankfully, the project was consequently allowed to continue to 30 June 2025 from the original proposed ending of 31 March 2025, which allowed it to be concluded properly.
Prior to the project, most councils lacked the legal framework to issue penalties for lettings and other Trading Standards enforcement. As a project legacy, it now allows these authorities to issue penalties for future lettings non-compliance, as well as other types of Trading Standards legislation that have recently come into force. For example, in tackling single-use vape sales.
Final thoughts
Trading Standards authorities are here to support bona fide businesses like letting agents to ensure they are compliant. In turn, this gives confidence to tenants, knowing that the agents they use are meeting their legal responsibilities.
Operation Jupiter has served as a wake-up call for those non-compliant agents. By taking enforcement action via penalty notices, we have ensured there is a level playing field so that all agents are compliant.
As the private rental sector continues to grow, Operation Jupiter offers a blueprint for how strategic enforcement and collaboration can improve industry standards, protect consumers and support responsible agents in delivering high-quality services.