Industry regulator, the Pubs Code Adjudicator, launches investigation into Stonegate Group over suspected Pubs Code breaches

The Pubs Code Adjudicator (PCA) has launched a formal investigation into Stonegate Group, one of the six regulated pub-owning businesses, over suspicions that it has failed to comply with the statutory Pubs Code. 

Stonegate is the largest pub company in the UK and operates an estate of over 3,000 tenanted and leased pubs across England and Wales.  

The PCA has reasonable grounds to suspect that Stonegate may have failed to comply with its legal obligations under the Pubs Code, specifically in relation to its duties to provide accurate and transparent information to both its existing and prospective tied pub tenants. This investigation follows a period of close regulatory engagement and will allow for a proportionate and targeted examination of Stonegate's conduct during a five-year period, from 15 July 2021 to 14 July 2026.  

Commenting on the launch of the investigation, Fiona Dickie, the Pubs Code Adjudicator, said:  

"The Pubs Code provides important rights entitling tied pub tenants, and those in negotiations to take on a tied pub, to transparent information including with regard to the premises and the rent. This investigation will help us establish if Stonegate has met their duties under the Pubs Code. 

"Upholding the core principles of the Pubs Code, ensuring fair and lawful dealing and that tied tenants are no worse off than free of tie operators, is our priority. 

“The results of our 2026 Tied Tenant Survey identified concerns and issues relating to the satisfaction of tenants of Stonegate in their tied relationship, which has been the lowest of the regulated pub-owning businesses for at least the last three years. Particular tenant concerns relate to repairs to the pub premises.” 

As part of this investigation, the PCA is collecting evidence, and would particularly like to hear from current and former Stonegate tenants if they have been impacted by the issues in the investigation. Fiona Dickie says: 

“It is important that previous and existing tenants, and other interested parties, provide us with information to support this investigation. This will help us to determine whether the Pubs Code has been broken and, if so, the impact on tenants and what further action should be taken.” 

Any tenants or other interested parties who provide information for the purposes of the investigation will not be identified in the investigation report without their consent. The deadline for submission of evidence is 5pm on 12 August 2026.  

Tenants can submit evidence by email to [email protected]. More information can be found on our website page. 

The PCA has not yet reached any decision as to whether Stonegate failed to comply with the Pubs Code, and if so, the extent of any potential non-compliance. 

The investigation will examine whether Stonegate may have: 

1.1 Failed to provide to prospective tenants a full and clear description of the premises, including an accurate Schedule of Condition and/or disclosure of other specific problems in the premises; 

1.2 Provided to prospective tenants defective lists of initial works to be carried out to the pub premises to which the tenancy related. In particular, Stonegate may have: 

• failed to include details of all initial works, such as by: 

  - representing to prospective tenants that it would carry out repair, maintenance and/or improvement works, but not capturing these representations in the list of initial works (and in any event failing to complete the works); 

  - failing to include details of any initial works required to be completed before the agreement was in force; 

• where the initial works were to be completed after the agreement was entered into, failed to specify the date on which the works were to be completed; 
• otherwise failed to provide a list of initial works in the required form and/or at the required time; 

1.3 Provided to prospective tenants unreasonable and unrealistic projections in the context of rent proposals, which informed rent proposals given to tenants and tenants' business plans. That data may have also been insufficiently clear and detailed, and lacked justification or supporting evidence, to allow tenants to understand the basis of its calculation. It may have also meant that Stonegate failed to ensure that the prospective tenants' business plans were sustainable; 

1.4 Failed to comply with reasonable requests by tenants that were relevant to the negotiation of rent or that would have helped the tenants to understand the rent, or, alternatively, failed to provide a reasonable explanation within 7 days as to why the information was not provided; and 

1.5 Failed to ensure that its business development managers dealt fairly and lawfully with tenants, and that notes of discussions with those tenants were recorded properly in accordance with the Pubs Code. 

In addition, the PCA will also investigate whether Stonegate failed to provide the PCA with a detailed and accurate account of its compliance with the Pubs Code and/or instances of breaches or alleged breaches of the Pubs Code, and any steps taken to address these, as required as part of its annual compliance report.