NRLA assured periodic tenancy agreement – Is it missing a vital piece of information?

I have noted a potential issue in the NRLA’s new APT agreement that may be an omission of the “written statement requirements” under the Renters’ Rights Act.

The official Government guidance can be seen by clicking here.

There is a statement under “Disability Adaptations” on page 9 that makes the statement. “You must provide information that tells your tenant that they can find the definition of “disabled person” in section 6 of the Equality Act 2010 and the definition of “improvement” in section 190(9) of that Act.”

In the NRLA APT agreement, under Section A paragraph starting “Section 190 of the Equality Act”, there appears the statement, “Where Section 190 of the Equality Act 2010 applies, a landlord may not unreasonably withhold consent for a tenant’s application to make an improvement to premises where a disabled person occupies or intends to occupy the premises as their only or main home, and the improvement is likely to facilitate the disabled person’s enjoyment of the premises, having regard to their disability.”

However, this does not contain the definition of “disabled person” nor “improvement” under the Equality Act 2010, stated as required in the official government guidance line above.

Under Section B (definitions), the NRLA APT agreement states, “’disabled person” has the same meaning as set out in Section 6(2) of the Equality Act 2010.”

However, I can find no definition of “improvement” under the Equality Act 2010 in their APT agreement.

Should the APT agreement also define “improvement” under the Equality Act 2010 in Section A, Section B, or elsewhere in the agreement?

Is this an accidental omission?

Could this expose users of the current NRLA APT agreement “as is” to fines?

I have contacted the NRLA for clarification and I will post it here when received. In the meantime, if anyone has any thoughts on the matter, I would be very interested to read them.

Thanks,

Alex