A spokesperson for the Residential Tenancies Board says that those who fail to register face late fees and possibly fines.
On a recent Friday, Cagla Cakir walks out of the Point Campus student accommodation complex across from the 3Arena to collect a bag of food from a Deliveroo driver.
Cakir is living in Point Campus for the year and she likes it, she says. “It’s good.”
There are lots of people around. “It seems quite full,” she says. “They are mostly students I’d say, maybe some interns.”
In 10 minutes, 17 young people go in and out of two doors that lead into different blocks of the student-housing complex.
According to planning documents, the Point Campus has 966 beds but a new public register of student accommodation tenancies last updated on 6 April shows no tenancies registered there.
A Residential Tenancies Board (RTB) spokesperson says that the public register is correct. “If you have paid and your data is up to date, you are on the list.”
Investment fund DWS, which owns the Point Campus, declined to comment on why there were no tenancies registered at Point Campus.
It’s the same story at the Binary Hub on Bonham Street, the Loom on Cork Street and Beckett House on Summerhill, all of which are run by Aparto, a subsidiary of the developer Hines.
“Aparto conducts regular and timely engagement with the Residential Tenancies Board in respect of its regulatory obligations and is currently in the process of providing additional clarification to the Board,” says a spokesperson for Hines.
The RTB spokesperson says that all tenancies should be registered within a month of starting and those that are not registered on time will face late fees and possibly fines.
Since August 2019, all landlords of student-specific accommodation have been required to register tenancies with the RTB.
The public register of those tenancies was last updated on 6 April 2022, and at that point in time student-specific accommodation providers in Co. Dublin had registered 10,305 tenancies.
There are at least 18,652 student-specific beds spaces in Co. Dublin, suggest figures provided by the Department of Education.
Still, several factors complicate efforts to work out vacancy rates in student accommodation, a question of interest to policy makers and students debating whether adding more student rentals would eventually lead to supply outstripping demand and trigger a rent dive, which would ease the affordability crisis in student accommodation – or whether providers would just leave rooms empty rather than drop prices to fill them.
Some tenancy registrations are still in the pipeline, says the RTB spokesperson. The provider might have submitted some documents but not completed the registration process, she says.
Or they might not have coughed up yet. They register tenancies in blocks and then the RTB sends an invoice.
The registration fee is €40 per room, but providers can register between five and ten rooms in a block for €170, according to a guidance document issued by the RTB.
Some of the delays in getting tenancies registered are caused by the fact that the RTB asks for a PPS number for each student-tenant, says the spokesperson.
But if the student doesn’t have a PPS number, the landlord can still register them by signing a declaration, she says.
For every late registration, late fees of €10 per month accrue every month, says the spokesperson. “Failure to register is an offence which may result in a criminal conviction and a fine of up to four grand.”
The register will be updated again at the end of May, she says.
The RTB counts a shared room, even if it holds two beds, as one tenancy on its student accommodation register, which means it isn’t straightforward to compare it with available figures on how many beds each complex has, to work out the vacancy rate.
Heyday Student Living at Carman’s Hall in Dublin 8 has 68 tenancies according to the public register, but it has 207 student bed spaces.
Swuite ISA Grangegorman at Arran Quay in Dublin 7 has 55 tenancies, according to the register, but it has 125 bed spaces, according to the planning file.
Those student accommodation providers haven’t responded to questions about registered tenancy rates and vacancy levels sent by email on Friday.
One other provider did reply to say that it is full, but isn’t registering all students living there with the RTB.
According to the tenancy register, Liv Student Accommodation on Church Street in Dublin 7, has 103 registered tenancies.
A spokesperson for Liv said that the complex has 216 bed spaces and has been fully occupied since last July.
But “113 Beds are currently under Nomination Agreements with a number of different schools that are not required to be registered with RTB”, says the spokesperson.
These are mostly short-term stays but for a minimum of four weeks, he says.
“These rooms are under Business to Business agreements,” he says. “The schools pay us for the rooms and the students pay the schools.”
An RTB spokesperson said that the Residential Tenancies Act defines student-specific accommodation as coming under the remit of the RTB.
“Everyone who provides student-specific accommodation is within the RTBs remit and the legislation clarifies that all licences and tenancies that fall under their remit have to be registered,” she says.
“Each landlord needs to consider the arrangement they have in place and they if necessary need to seek legal advice to determine their individual circumstances,” she says.
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