From 27 August 2026leaseholders can lawfully buy plug-in solar panels, and managing agents will start receiving consent requests. The Property Institute’s position is that these should not be treated as routine alterations. Some buildings are excluded by the product specification itself, whatever the lease says — so eligibility comes before consent.
This is general information, written for the agent’s side of the desk. It is not advice on any lease or building, and leases differ materially even within one development. Anything contentious — a refusal, a fee, a covenant that reads both ways — is for your own legal advice.
Legal to buy is not the same as permission to install
What Changes on 27 August 2026, and What Doesn’t
SI 2026 No. 848 was made on 16 July 2026 and comes into force on 27 August 2026. Plug-in solar panels become legal to sell then, and lawful to use in Great Britain; Northern Ireland sits differently on the use permission. They are expected to become widely available at £400–£600, with DESNZ modelling a mean of £500. Reported government estimates put the annual saving at £70–£110 off energy bills.
Be careful with that upper figure, because residents will quote it back at you. The £110case is modelled on a 30-degree south-facing array. A balcony is near-vertical and frequently faces east or west, which is the £70 end of the range. Saying so early is worth more than a complaint later about a system that underperformed a number you repeated.
The panels plug into a socket and need no electrician, which is what separates them from rooftop solar or any conventional installation. They are also portable: a leaseholder who moves house takes the kit with them. And they are usually mounted on a balcony rather than a roof, which is precisely why they land on your desk and not an installer’s.
The legal changes touch product law and nothing else. Nobody gains a right to install solar panels, and nobody is automatically allowed to install anything. A homeowner with a roof always had the conventional route open; leasehold properties did not. Leaseholders still need consent, and how they get permission depends on the lease.
One thing worth knowing before the first request lands: there may be no kit to approve yet. Every device listed under the register’s “Plug-in Solar” type is currently marked Non-compliant, and the number assessed compliant is zero.
That status is narrower than it sounds. In ENA’s own taxonomy, Non-compliant is a sub-category of “Further Information Required” — the device “cannot be deemed compliant at this stage”, and “once the comments have been actioned and documentation updated by the manufacturer, it will be reviewed again - in due course”. So: not compliant today, not something anyone can rely on today, and expressly expected to be looked at again. Read it as “not yet verified” rather than “failed”.
What you should not do is quote a number of entries — not from this page, not from memory, not from a colleague. The register moved twice in the ten days to 11 August 2026, and records can be superseded by amended versions that its search index has not yet picked up, so the list under the type filter may be shorter than the list of devices that actually exist. Check it on the day you reply.
The One Refusal That Isn’t Yours to Make
Clause 5.8 of the Interim Product Specification, published 16 July 2026, states that installations shall not be permitted on:
- aluminium composite material (ACM) or metal composite material (MCM) cladding systems
- high pressure laminate (HPL) cladding systems
- timber cladding systems
- timber balconies
- buildings subject to external wall remediation works, building safety remediation works, or equivalent restrictions relating to external wall fire safety
Be clear about this one before replying to anybody: it is not a consent decision. It is a prohibition in the product specification. You cannot grant it away, the freeholder cannot, the RMC cannot, and a leaseholder cannot agree to carry the risk instead. On the face of that list a large number of UK flats are excluded outright, whatever anyone consents to.
TPI’s first risk heading is fire and electrical safety, “especially in buildings awaiting external wall remediation”. Where that describes a block on your portfolio, say so at enquiry stage, before residents spend £400–£600 on something they cannot use.
You cannot consent your way past clause 5.8
What Leaseholders Will Be Asking For
Requests will come from two directions: leaseholders directly, and tenants asking a leaseholder landlord who then asks you. A leaseholder may need permission from the freeholder, from an intermediate landlord, or from both, and will ask in whatever form somebody has told them to use. Whether they can put panels on a balcony at all depends on the lease — TPI’s fourth risk category is exactly whether balconies and other external areas are demised to the leaseholder.
TPI’s guidance is that each application is assessed on its merits, taking account of “the lease, building design, safety considerations, insurance, and any other relevant legal or technical requirements”. As a request list:
- Product compliance.The on-product declaration of compliance with the Interim Product Specification, and a verified listing on the ENA Type Test Register. A CE or UKCA mark is not the test — our tracker of certified plug-in solar kits records the register position.
- Where and how it is fixed.Balustrade, external wall, balcony floor, roof, or nothing at all with a free-standing frame. TPI warns that inadequate fixtures and fittings “could result in panels falling from height”.
- Network notification. Mandatory. The simplified route is still in development; the obligation is not. See DNO notification under G98.
- Insurance and safety. Both policies. The joint statement of 9 June 2026 by the ECA, Electrical Safety First, the IET, NICEIC and SELECT records that it is not yet clear how insurers would respond where a unit was installed by the consumer and not declared in advance. A real open question, not a pretext.
Our companion page on plug-in solar in blocks of flats covers the same ground for leaseholders, and is useful to send with an acknowledgement.
Consent Letter or Licence to Alter?
Section 19(2) of the Landlord and Tenant Act 1927 applies where a lease contains a covenant against making improvements without licence or consent. Such a covenant is deemed, “notwithstanding any express provision to the contrary”, subject to a proviso that consent is not to be unreasonably withheld. On a qualified covenant, a flat no is an exposed position.
The same subsection preserves the useful part. A landlord may require a reasonable sum for damage to, or diminution in the value of, the premises or neighbouring premises, and for legal or other expenses properly incurred in connection with the licence or consent. Where the improvement does not add to letting value, an undertaking to reinstate may be required where reasonable. Proportionate conditions and costs are available to you; a blanket refusal is the weaker ground.
Two limits, honestly. Section 19(2) does nothing to an absolute covenant. And whether a plug-in solar installation is an “improvement” within the subsection turns on case law we have not read, so we will not assert an answer.
Conditions travel better than refusals
Who Grants It: Freeholder, RMC or RTM Company
A consent granted by the wrong party is worth little. In many blocks a residents’ management company is party to the leases and holds the relevant functions. Where leaseholders have exercised the right to manage, section 98 of the Commonhold and Leasehold Reform Act 2002 provides that approval functions of the landlord or other party to a long lease “are instead functions of the RTM company”, with notice provisions before an approval relating to alterations. If you are the agent, you are usually the correspondent rather than the decision-maker — saying which, in the first reply, heads off most of the friction.
Higher-Risk Buildings: the Extra Layer
Section 65(1) of the Building Safety Act 2022 defines a higher-risk building as one in Englandat least 18 metres tall or with at least 7 storeys, containing at least 2 residential units. If you manage blocks in Wales, Scotland or Northern Ireland, this particular regime is not the one you are working to. Where it does apply, the request arrives inside a regime rather than beside one. Section 62(1) defines a building safety risk as risk to people from the spread of fire or structural failure; for landlords, solar panels fixed to an external wall touch both. Sections 83 to 85 require the accountable person to assess those risks and maintain a safety case report. Section 95(2) cuts the other way: residents must not create a significant risk of one materialising, nor interfere with a relevant safety item. TPI’s line is that “all building safety legislation should be applied, as appropriate for the height of the building”.
Setting Up a Process Before the Requests Arrive
TPI recommends getting ahead of this, because a clear process and advance information “will help manage expectations, reduce unauthorised installations and support informed decision-making by all parties”. Its suggested communication covers four points: that plug-in solar is becoming available; that residents should seek consent before they buy or install plug-in solar panels; that each request is assessed on its merits; and who to contact.
We see this as an opportunity for renters and leaseholders more than a risk to buildings, provided the process is proportionate. Agents who allow plug-in solar on conditions get requests they can administer. Agents who refuse flat get complaints.
Two resources. The Department for Energy Security and Net Zero has published an independent Plug-in Solar Electrical Safety Study, which TPI notes landlords, building owners and freeholders can use when assessing applications. TPI Guidance Note C14 has been updated to cover plug-in solar; it is restricted to TPI company members, we have not read it, and we will not tell you what is in it.
One boundary catches people out: the Renters’ Rights Act 2025 governs the landlord-and-tenant leg, not the leaseholder-and-freeholder leg — see the Renters’ Rights Act 2025 and balcony solar. Our balcony solar insurance guide sets out what is settled on cover, and our leasehold balcony solar page shows what leaseholders are being told to do when they write to you.
Frequently Asked Questions
Can we refuse a plug-in solar request outright?
If clause 5.8 excludes the building, no consent decision arises — it is a product-specification prohibition. If the building is eligible and the covenant is qualified, section 19(2) means consent is not to be unreasonably withheld. An absolute covenant is different again.
Can we charge the leaseholder for dealing with the application?
Section 19(2) preserves a reasonable sum for damage or diminution in value of the premises or neighbouring premises, and for legal or other expenses properly incurred. We will not suggest a figure; we have no reliable data on what these applications cost.
Do we need a formal licence to alter, or is a consent letter enough?
That turns on the terms of the lease, the permanence of the fixing, and how much you need to enforce later. Put it to your own advisers on the specific lease rather than settling it by policy.
Does the leaseholder need planning permission to install solar?
Possibly, and for flats the position is genuinely unsettled rather than merely unknown. It is a separate gate and neither answers the other — see planning permission for balcony solar in flats.
What if the block is undergoing external wall remediation?
Clause 5.8 excludes it. Buildings subject to external wall remediation works, building safety remediation works or equivalent external wall fire safety restrictions are on the prohibited list, and consent cannot cure that.
Who grants consent if an RTM company manages the block?
Under section 98 of the Commonhold and Leasehold Reform Act 2002 the approval functions become functions of the RTM company. Confirm which entity holds the function before issuing anything.
What should we tell residents before 27 August 2026?
Broadly what TPI suggests: that plug-in solar is coming; that they should check their lease and seek consent before buying; that each request is assessed on its merits; and who their point of contact is. Where clause 5.8 already excludes a block, say so now.
If you are the leaseholder rather than the agent, our companion page on plug-in solar in blocks of flats sets out the same three gates from your side.