All letting agents in England handling client money must be members of a government-approved CMP scheme under the Client Money Protection Schemes for Property Agents (Requirement to Belong to a Scheme etc.) Regulations 2019 (SI 2019/386). Failure to belong is a criminal offence carrying a fine up to £30,000.
The Client Money Protection Schemes for Property Agents (Requirement to Belong to a Scheme etc.) Regulations 2019 (SI 2019/386) made CMP scheme membership mandatory for all letting agents in England that handle client money, from 1 April 2019. Client money means money held on behalf of landlords (including rent collected, landlord funds held on account) and tenants (including deposits before transfer to a deposit protection scheme). The obligation applies regardless of business size and regardless of whether the agent also handles sales.
The Client Money Protection Schemes for Property Agents (Approval and Designation of Schemes) Regulations 2018 (SI 2018/1285) governs which schemes may be approved. As at June 2026, there are five government-approved CMP schemes. Membership of a non-approved scheme does not satisfy the obligation under SI 2019/386 — agents must belong to one of the five approved schemes and must renew membership annually. If a scheme's approval is withdrawn, agents have 14 days to join another approved scheme.
Under s.17 of the Tenant Fees Act 2019, letting agents must display the name of their CMP scheme in every office where they deal with the public, on their website, and in all written communications where fees are quoted. The display obligation is separate from the membership obligation — an agent who belongs to an approved scheme but fails to display it commits a separate criminal offence. Local authorities enforce both obligations.
Failure to belong to an approved CMP scheme under reg.3 of SI 2019/386 is a criminal offence. Local authorities are the primary enforcement body and may bring proceedings before a magistrates' court. The maximum fine is £30,000 per enforcement action. Under the Renters' Rights Act 2025 Phase 1 investigatory powers (in force 27 December 2025), local authorities may verify CMP scheme membership during enforcement visits — non-membership is treated as a higher-risk finding.
CMP schemes indemnify landlords and tenants against the loss of money held on their behalf by a letting agent. Protection covers misappropriation of client funds, fraud, and agent insolvency. Schemes compensate landlords for rent received but not passed on, and tenants for deposits held before transfer to an approved Tenancy Deposit Protection (TDP) scheme. CMP does not cover disputes between landlords and tenants — only loss caused by agent misconduct or insolvency.
EstateHQ records CMP scheme membership in the Compliance HQ dashboard. Agents enter their scheme name, membership number, and expiry date. The dashboard displays current membership status and flags approaching expiry to prompt renewal before the membership lapses. All features listed below are live in the current platform.
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