Shield within beer glass

The PCA has reasonable grounds to suspect that Stonegate has failed to comply with the Pubs Code. However, the PCA has not yet reached any conclusion as to whether Stonegate has breached the Code, or the extent of any non-compliance. 

This investigation is looking at whether Stonegate has complied with key obligations under the Pubs Code, which is designed to ensure tied tenants receive the information and support they need to make informed business decisions. The PCA is investigating Stonegate's conduct from the period 15 July 2021 to 14th July 2026. The investigation will examine possible breaches of the Pubs Code relating to: 

  • Information provided to prospective tenants about the condition of premises before they signed agreements 
  • Repair, maintenance and improvement works 
  • Financial forecasts and rent proposals 
  • Requests for information from tenants during rent negotiations and throughout tenancies 
  • Requirements relating to sustainable business plans 
  • The conduct of Business Development Managers and the fair treatment of tenants 

The investigation will also consider whether any issues identified are isolated incidents or indicate wider, systemic failings. 

Further information is available in the PCA’s Notice of Investigation and Call for Evidence

The investigation will focus on Stonegate and will not currently extend to any other pub-owning business. If, during the course of the investigation, the PCA becomes aware of potential breaches of the Pubs Code by any other pub-owning business, the PCA will consider and assess what action would be appropriate to take.

The PCA can open a formal investigation under section 53 of the Small Business, Enterprise and Employment Act 2015 where there are reasonable grounds to suspect a breach of the Pubs Code.    

As part of that investigation, the PCA can require a pub-owning business to provide documents and information under Schedule 1 of the Act. It is a criminal offence for a person to intentionally fail to provide information required under these powers or to knowingly provide false information.  

The PCA can also gather evidence from other sources, including current and former tenants and third parties.    

The PCA is calling for evidence from tenants of Stonegate, including current and former tenants who may be affected by the issues within the scope of the investigation. The PCA also welcomes evidence from any other interested parties who believe that they may hold relevant evidence. 

The deadline for submission of evidence is 5pm on 12 August 2026.   

Please send relevant information to [email protected].  

Alternatively, you can also send us information by post: 

Pubs Code Adjudicator 
Office of the Pubs Code Adjudicator 
4th Floor 
23 Stephenson Street 
Birmingham 
B2 4BJ 

The evidence that tenants, and others, provide may help the PCA to understand whether Stonegate failed to comply with the Pubs Code, whether the issues identified were isolated or more widespread, and what impact any non-compliance may have had on tenants. 

There is no prescribed format of response – respondents should feel free to provide any information and/or documentation they believe may be relevant to the issues under investigation. While the PCA does not require supporting documents / records at this stage, the PCA office may follow-up to ask for supporting evidence, such as notes of conversations with the Business Development Manager which the tenant must be given under the Code, and any letters or emails. 

Your evidence will be acknowledged, and the PCA office may follow up to ask for supporting evidence where appropriate – for example, notes of conversations with a Business Development Manager (BDM) which the tenant should have been given under the Code, or any relevant letters or emails. 

Anyone providing information will not be identified in the report without their consent.  

The PCA recognises that tenants and others may be providing confidential information in this investigation, and will ensure this is treated with all due care and in accordance with her own legal duties to protect material that is sensitive, commercial or private.    

Where the PCA is satisfied that a pub-owning business has breached the Code, she may take one or more of the following enforcement measures: make binding recommendations to the pub-owning business; require them to publish information; and/or impose a financial penalty of up to 1 percent of total UK turnover. As noted above, the PCA has not reached any conclusion as to whether Stonegate has failed to comply with the Code. 

There is no prescribed time limit for the PCA's investigation. However, the PCA will endeavour to complete investigations as soon as reasonably practicable. The PCA's statutory guidance on investigation & enforcement indicates that the PCA is likely to complete any investigation within 12 months. 

 

The PCA welcomes information regarding how pub companies are complying with the Pubs Code. This information helps the PCA build a picture of pub company behaviour and decide what action to take as the regulator. If you have information or a query regarding rights and duties under the Pubs Code that doesn't appear to be covered by the scope of the investigation, please use the PCA Online Enquiry Form or send an email to [email protected]. If you are unsure about whether the information you hold is in scope, please contact the PCA. 

Image of Fiona Dickie