Two large beer glasses being cheersed

Compliance Reporting Changes 

Under the Code, Pub Owning Businesses (POBs) must submit an annual Compliance Report to the PCA covering the period from 1st April to 31st March. Submission of the compliance report must be made within four months of the end of the reporting year. These reports provide information about POB estates and details of how each is adhering to its Pubs Code obligations and responsibilities. The report must include instances of breaches raised or alleged by tenants and steps taken by the POB to ensure compliance. Each POB has a duty to publish a summary of its compliance report.  

The PCA has, in consultation with the POBs, revised the compliance report questions for 2025-26 to refine the information that they provide to the PCA to ensure greater clarity, consistency and reduce the regulatory burden for the sector. This will also promote transparency in the industry by facilitating data insights using digital tools.  

Breach Self-Reporting 

In addition, POBs are expected to self-report to the PCA any failure to comply with the Code. The PCA reviews all self-reported breaches and considers a number of factors in deciding its regulatory approach. Publishing a Register of Breaches allows the PCA to share information about how the Code is working across all parts of the industry in an open and transparent way. Further information can be found in the PCA’s breach reporting policy. 

Data Insights 

Data available to the PCA was used to inform the PCA’s evidence in the third statutory review of the Pubs Code. This submission contains data on POB regulated estate sizes and changes over time.  

The PCA also obtains other data from POBs to understand the make-up of its estates and the use of Code rights. This includes data on the use of the Market Rent Only (MRO) option, requested by the PCA and published by the British Beer and Pub Association. Additional data is of value to the industry in understanding the operation and impact of the Pubs Code. In combination with the compliance report data, available data set out in the associated data table supports the following insights: 

  1. Estate Sizes 

The total number of Pubs Code agreements at the end of March 2026 sat at 8,331 regulated pubs, down 107 (1%) from March 2025 (8,438). That 2025 figure included an increase in the Stonegate estate on the previous year owing to contractual steps it took to bring their Craft Union profit share agreements within the remit of the Pubs Code. The associated table includes data to illustrate the longer-term trend in regulated estate sizes. 

  1. Landlord and Tenant Act 1954 Protection 

The exercise of a right of statutory renewal under the Landlord and Tenant Act (LTA) 1954 is an event entitling the tied tenant to access the MRO right under the Pubs Code. The total number of agreements with statutory protection under the 1954 Act reduced from 2,676 in 2023-24 to 2,400 in 2024-25 and 2,211 in 2025-26. 

This shows a reduction in the number of agreements with such protections across all POBs when compared to figures for 2023-24 and a continuation of a longer downward trend. Amongst the POBs, Admiral, Punch, Stonegate and Marston’s did not offer any new LTA protected agreements in the 2024-25 reporting year.   

  1. Uptake of the MRO right  

The MRO option is key to delivery of the core Code principle that tied tenants should be no worse off than if they were free of tie. Under the Code, tied tenants have the right to compare tied/free of tie options every time they have the right to renegotiate their tied rent. The tenant can compare the tied and free of tie offers and negotiate to choose the best option for their business.  

This right has enabled some tenants to achieve more favourable tied deals or a free of tie tenancy. The right to request MRO is only available at one of the four available MRO events: receipt of a rent assessment proposal (RAP), renewal of the tenancy, a significant increase in price, or a ‘trigger event’ as defined in the Code. This right is not available to those on a short agreement/tenancy at will, who have agreed to an investment exception, or to franchisees. 

The PCA has prepared a table to show the total number of MRO events, and the number of MRO notices accepted as a percentage of this, over time. The reduction in MRO events over time can be understood in the context of changes to agreements in the regulated estates. This data indicates that, given the right to MRO, a relatively stable proportion (roughly 20%) have exercised it over the past few years. 

Of the 453 MRO processes which ended during the statutory review period, 35% resulted in a free of tie agreement. This is comparable to the proportion for last statutory review period.