Ms Emer Morrissey:

We have a couple of processes for people to report non-registration to us. It can come in from a member of public or we do data sharing with other public bodies, such as HAP Shared Services Centre, the Department of Social Protection and local authorities. We also have internal data from our disputes process. If someone is part of a dispute or if a tenant raises a dispute and that property is not registered, we can get that information and pursue it.

The RTB has two mechanisms for pursuing non-registration. As Ms Steen outlined in her statement, we have our criminal process, which is registration enforcement, and then we have our investigations process under Part 7A. Both are slightly different processes. The registration enforcement process is about notifying the landlord that we know he or she is not registered. We give the landlord two opportunities to engage and actually register that property. If the landlord does not comply, he or she can be prosecuted through a criminal prosecution with a fine of up to €4,000.

Our investigations process involves a formal investigation, so it very much looks at the evidence that comes from the person who sent that complaint to us. It investigates what the set-up is and whether it falls under our jurisdiction and if it is not registered. If we get a complaint about something else, for instance, breach of an RPZ, we will always check the registration status. Therefore, even if somebody complains about something that is not to do with non-registration, we will have a look at and address it and add it on to the investigation if we can. We follow that process, and the sanction can be up to €15,000 for non-registration if someone has been found to have breached it. We also give landlords the opportunity to comply throughout that process. They can acknowledge and rectify it and register. They can still be liable for a sanction if they do that as well. It is just that is looked on more favourably depending on a couple of different aspects of that, but there is plenty of opportunity.