Written evidence submitted by Unipol Student Homes [RRS 234]

About the Respondents

Unipol Student Homes welcomes the opportunity to respond to this inquiry on the Government’s White Paper.

Unipol Student Homes is a national student housing charity focussed on supporting education through the provision of suitable accommodation for students. It does this primarily by improving standards through landlord accreditation and operates two Government approved National Codes for purpose built student accommodation (PBSA), as well as local Codes for HMO housing (which we will refer to as ‘off-street’ housing in this submission) in Leeds, Bradford and Nottingham. In this role Unipol engages with over 2,500 landlords and currently accredits 440,000 bed spaces in both larger developments and off-street properties across the UK. Unipol is also a landlord itself, housing 3,000 students on a not for profit basis in the above cities.

Response and Overall Comments

This proposals have several important outcomes for student housing:

• It removes Assured Shorthold Tenancies and grants 2-month periodic tenancy in general PRS. This accounts for around 45% of housing supply, or approximately 570,000 students. It is proposed that those students living in non-PBSA will be treated the same as any other tenant and can rent and stay when they want and give two months’ notice and leave at any time.

• This would mean that there would be no contractual fixed-term for students in off-street housing, and landlords would not know when their properties would be able to be let to incoming tenants.

• It may appear to benefit students to be able to give 2 months’ notice - but because of the annual letting cycle of student accommodation - notice given mid-year will make it difficult to rent to other than non-students, and this will see student properties leave that sector and move into professional letting, reducing availability to students.

• It is also not clear when properties could be let because, until notice is given, the tenancy just runs. This would mean that properties could not be let until notice was given, so letting in advance of May (for the academic year beginning in September) would be unlikely. Although later letting would benefit some students, the majority of students would have left for the summer before they could secure accommodation for September. It should be remembered that most returning undergraduate students tend to house-hunt as a group, adding additional complexity.

• Outside of the academic cycle there is little demand because students have to find their accommodation to fit in line with their studies. Student accommodation is essentially let on an annual rental: shorter letting periods with greater risk will see rents rise or accommodation being let to other, less cyclical tenant groups. Increased financial risk, or lower possible landlord returns, will be priced into new rent levels for students and in to the supply of properties available under this new regime.

• Student homelessness and a lack of off-street accommodation at the beginning of the year will cause educational disruption and will increase student homelessness.

In Unipol’s opinion, the tenancy proposals would be a major disrupter to the academic experience and very bad news for the majority of student renters.

Unipol is not given to parroting landlord claims that they might leave the market if reforms are undertaken that they do not like but Unipol, as a charitable student housing provider, cannot see, under these proposals, how it could continue to let off-street properties viably to students.

Accommodation quality, who you live with and where you live play a significant role in a student’s academic experience, happiness and success.  Having choice and independence in terms of property type, cost, the people you live with and the time you chose to secure that property can have a significant impact on a student’s well-being.  Students who struggle in finding appropriate accommodation are more likely to drop out of university or suffer unnecessary stress due to their living situation.

Recent Lessons from Scotland

The Scottish Government recently commissioned the UK Collaborative Centre for Housing Evidence to review student accommodation, and it reached conclusions on the effect of recent tenure and renting reforms in Scotland that have taken place across a very short period (around 15 months). The conclusions of that study, in August 2022 are clear:

“When the new private tenancy arrangements for Scotland were legislated for in 2016, this reflected a decade of regulatory change in Scotland culminating in open-ended tenancies, finite and reduced means of repossession by landlords and a 28 day cooling off period for tenants at the start of tenancies. It was agreed that students living in university halls or PBSA would be exempt from this legislation, and that they would continue to be housed under a common law contract with the provider rather than a legal tenancy.

However, the majority of students living away from home would continue to be in the HMO private rented sector and would be covered by the new tenancy arrangements, thus creating a division in rights and law depending on what form of accommodation students choose (or can access).

It is now widely accepted across the sector that as a result of the new tenancy and the experience of Covid-19, private landlords who hitherto had been content to let to students are now moving away from that market and looking for more long-term tenants with less chance of void periods. The evidence from Glasgow and Edinburgh appears to suggest that this is shrinking the available supply for student HMOs and putting upward pressure on rents.”

This shift from students to other groups has happened with lightning speed over what is less than a single normal tenancy cycle. A recent BBC story reporting that the University of Glasgow has had to end its accommodation guarantee, shows the initial effect of these changes which have introduced uncertainty for new undergraduates searching for accommodation: https://www.bbc.co.uk/news/uk-scotland-glasgow-west-62493966

Unipol understands that, in Glasgow, the sharp contraction of off-street student HMO accommodation meant that many more students rented PBSA bed spaces during the year and this means that many fewer PBSA bed spaces are available for new first year students. This problem will be creating significant educational disruption for Scottish students who are unable to rely on securing accommodation in line with the academic year, increasing homelessness and sofa-surfing.

Unipol also understands that a similar shift is taking place in Edinburgh and St Andrews, almost most previous student HMOs have left the normal renters market and moved to Airbnb.

Student Homelessness

This contraction in the market has led to NUS Scotland beginning to campaign specifically on the issue of student homelessness, noting that 12% of students had experienced homelessness since starting their studies, with that figure rising to 1 in 3 for estranged (33%) and care-experienced students (29%). The NUS commented:

A student housing shortage has left hundreds of students in Scotland with nowhere to live in the first few weeks of their degree.

The National Union of Students for Scotland has highlighted that students are being forced to pay sky-high rents, experience homelessness, drop out or defer because they cannot find adequate housing.

Students in Glasgow, Edinburgh, and Stirling are among those worst affected, with some landlords increasing rent to profit from demand.

https://www.nus-scotland.org.uk/articles/alarming-research-on-student-poverty

The 2022 Higher Education Policy Institute report Could Universities do more to end student homeless? concluded that there is very little comprehensive data on student homeless, but highlights that prevalence of homelessness is higher in University towns compared to other local authority areas. As of data collected in summer 2022, Scotland has the highest incidence of homelessness in University towns, followed by Wales then England:

There is clearly a link between rising homelessness amongst students and the recent Scottish Government reforms that are almost identical to those proposed in England. Student homelessness disrupts education and must be avoided.

Impact on Rents and Affordability

Student accommodation is already costly without a reduction in supply increasing prices further as seen in Scotland recently.

The NUS/ Unipol Accommodation Costs Survey 2021 looked at PBSA rents and found that outside of London, a student receiving the maximum maintenance loan had just £69 per week for living costs after the average rent of £152 per week is paid. The cost of living crisis will compound this with all-inclusive PBSA rents already forecast to increase by 10% next year because they are energy inclusive and energy costs have dramatically increased. Any increases in demand as a result of the reforms will increase rents further, making an average rent of £200 per week (outside London) quite possible within the next few years.

Off street housing offers a more affordable option to students in their second and third years of study. There is no comprehensive national data available on off-street housing rents for students, but using Leeds and Nottingham as two examples the average rent is £112 and £113 per week respectively for room inclusive of utilities, water and internet (the standard package) on a 12 month contract. This is some 30% cheaper than PBSA.

Leeds and to a greater extent Nottingham are undersupplied markets, with students who arrive late into the city struggling to find housing. If supply reduces, prices will increase with landlords anticipating an 8 month let to cover an annual revenue, in effect “front-loading” rent. This could see rents increase to £180.94 wk. in Leeds and £169.47 in Nottingham, reducing the affordability of off-street housing.

Detriment to Students from the Proposals

Local Impacts

The shift away from student HMOs in England will affect different cities differently. In popular tourist areas, there will be a shift to Airbnb, in other cities (such as Leeds and Manchester) with a vibrant young professional market, that market will be expanded at the expense of half a million student renters.

Source: Higher Education Statistics Agency -  Where do Students Live (2020 – 2021 academic year)

PRS = own residence (50%)+other rented accommodation + other/total

PBSA = provider maintained property + private sector halls/total

In smaller cities like York, Brighton and Bristol which are already undersupplied (with students being forced to live in Hull or Bath last year) any reduction in available off-street housing will turn immediately into serious student homelessness for hundreds of students each September, or the inability to even take up university places.

In cities such as Manchester and Leeds, student housing is likely to be lost to the burgeoning younger professional market (caused by the inability to buy houses without significant help or savings).

In other educational centres the shift away from students may be slower with more capacity for the local market to adapt.

It should be recalled that as student housing is let on an annual cycle, the pace of change could be rapid in key areas as outgoing students are then replaced by other tenant groups.

The large numbers of students involved in this process could mean homelessness could affect thousands of students each year.

Students with Specific Needs

In the Bill there were examples of students who had not benefited from the current contractual tenancy system of those with local ties or a family to support. Students with dependants are likely to be older in age and living outside the student market where tenancies tied to the academic year are not the norm. Students with local ties are likely to have more options and flexibility about where they choose to live taking advantage of nearby friends and family, with greater local knowledge of areas outside student areas. To suggest that upending the student rental market on the basis of benefitting these two impossible to quantify minority interests who can already exercise alternative options, is spurious.

There has also been the suggestion that these changes will be of benefit to disabled and care-experienced students. Between 11% and 17% of students have a declared disability, with 71% of these being mental health or learning related. It is undeniably difficult for disabled students to find accommodation, with most adapted accommodation being located within PBSA, but it’s hard to see what positive impact the proposals would have on that and its likely they will actually reduce choice.

For the rest the contractual system to work properly, ensuring a cycle of appropriately timed and managed accommodation for a specific subgroup of the private sector is essential.

Policy Formation and the Student Experience

One of the big problems in student accommodation is the use of anecdote in policy formation, the “when I was a student” line. Most of these anecdotes are untypical and many are sufficiently embellished with the tricks of memory that they are at best flimsy interpretation of reality.

It will be difficult to argue that students have special needs in PBSA but have no special needs in off-street properties.

Let’s just think about what many “normal” off-street tenancies involve in the professional market:

• unfurnished and partially furnished lets, often without white goods or curtains
• the tenant taking responsibility for gardening/decorating/basic maintenance
• not having all-inclusive rents - water and energy charges paid for separately
• not having internet installed, meaning a student tenant could take weeks to set up an account when much of their study is now provided online.

Unipol is not claiming that students are in some way incapable of being “normal” tenants, but it is important to recognise their special characteristics: they are primarily experiencing living away from home for the first time and they want an “off-the-shelf” produce, to live with other students, concentrating around the academic cycle and their studies.

Students have some significant differences from mainstream renters reflecting their educational needs:

• they are economically inactive, with the bulk of their income coming from student finance with an inability to adapt to increased rents
• they are comparatively less mobile, with reduced funds for travel or commuting so need to be located closer to campuses, restricting choice
• the significant majority of students only need accommodation on an academic year cycle, before either staying in that student accommodation or exercising their preference to move to another type (for example from PBSA into a shared house into a smaller flat)
• their housing needs are focussed on a single uniform start date – all students need accommodation starting in September, and without it they face significant educational disruption.

The idea of students, who are there to study, “putting down roots” in their shared student accommodation is fallacious. Even if students stay in their city of study they want to rent something else and move on from traditional student areas.

The current proposals are likely to result in the law of unintended consequences:

• more homes become holiday lets and moving into other markets
• fewer direct lets and head-leasing schemes for off-street properties by institutions
• “studentified” areas becoming more transient and deregulated
• rent increases and other costs for tenants.

Student tenancies in the off-street market typically operate on a 48-52 weeks cycle commencing in the summer, paying an annual rent advertised as a weekly amount. It is understandable that the option to be able to give two months’ notice, bringing the end of tenancy forward to late April when lectures have finished, is attractive to current student renters and their representatives, but it creates an unsustainable system in which a landlord either has to accept a 4 or 5 month void before a new intake in September (together with Council Tax costs for a vacant property) or switch into a more predictable market. The downside of this advantage will be felt later by future students.

Alternative Solutions

The existing Government proposals already suggest creating some kind of “student tenancy” for those in PBSA. This should be extended to off-street HMOs in order to maintain the academic cycle and the availability of properties when students arrive to study.

The Government seems to be addressing some downsides of the current system, but these can be addressed in different ways, other than separating student housing from the academic cycle.

Those issues are:

It is difficult to define what a student is.

There are already clear legal definitions of what constitutes a student that can be used to define a student tenant.

Local residents becoming a student would see their previous tenancy rights reduced

Those who entered into tenancy arrangements before becoming a student could retain their normal tenancy rights. Students with dependents, who fit ore normally into the wider housing market, could be dealt with in the same way as non-student tenants.

Students, fearful of retaliatory eviction, fail to report repair issues or problems with their landlords.

Students are fortunate in that they have access to students’ union and institutional advice services together with many voluntary accreditation schemes run throughout the country. Most off-street student accommodation falls under mandatory, additional or selective licensing which and action can be taken under the enforcement procedures within the Housing Act 2004. There is no evidence that students’ concern about security of tenure mans they fail to report problems. In Unipol’s experience, most students who have problems with their landlord prefer to leave their house and find somewhere else to live, rather than take time away from their studies to address those issues legally.

Many students sign up for tenancies far too early and some leave their institutions or fall out with their group and are unable to leave their tenancies.

Unipol has some sympathy for this view. At present a significant minority of students ask to be released from their tenancy agreements part-way through their tenancy.  The generally accepted practice is to release a tenant if a replacement student tenant can be found, so that there is no loss to the landlord.

The main period of risk for a student tenant is the time between concluding a tenancy agreement (which is often as early as November for a tenancy due to start in August or September of the following year) and the start of the tenancy. This long completion period is a feature that is particular to the student rental sector and, although renting early for the following year is taken advantage of by some landlords and agents, this “early cycle” is primarily driven by students. Of course, if accommodation is in short supply, then the cycle tends to be earlier.

Some institutional landlords offer rights to cancel; some charge a cancellation fee. 

It would benefit students to be able to cancel tenancy agreements before starting their tenancies.   A common reason for wanting to cancel is the realisation that the group of friends who entered into a tenancy agreement do not, after all, want to live with each other.

If students are to have the right to cancel, it should be exercised whilst there are still other students looking for accommodation.  It is suggested that free cancellation during the period of up to 4 months before the start of the tenancy would be appropriate. Experience shows that allowing free cancellation until just before the planned start of a tenancy encourages students, particularly post-graduates, to book multiple rooms as a holding device.   Such a practice results in accommodation shortages at the start of an academic year, followed by long void periods shortly after the start of the academic year.

Free cancellation rights before the start of a tenancy means that students will not be locked into a fixed-term tenancy that they know, even before they move in, they do not want.  Students exercising the free cancellation rights will release properties or bed spaces for other students who have decided that the decision they made several months before is no longer right for them. 

Charitable Status and Charitable Activity and Housing Students with Families

Unipol first raised specific issues on tenure reform as it might affect charities in a letter dated 24th August 2018 to Anne Frost (then Deputy Director of the Private Rented Sector Division).

Unipol’s charitable aims are “the advancement of education by providing and managing accommodation and related services for educational institutions, their students and other persons associated with educational institutions, and to develop and foster excellence and expertise in this field.”

Unipol houses around 3,000 students from a variety of higher and further educational institutions. Unipol houses around 1,500 students in of-street HMOS and we regard this as an important part of our sock, enabling some progression from halls to smaller in-community houses. Off-street properties are also much more affordable than our PBSA because they carry less overhead costs associated with larger buildings.

An important part of our housing stock is providing around 210 affordable (and subsidised) homes for students with families and these specifically fit into assisting those with limited incomes and seek to address issues of educational access and equality.

In both these cases, as an educational charity, I am concerned that if longer term tenancies come into force this could mean we could end up housing non-students and, if students rented for a shorter period or could come and go at will, it is difficult to see how that stock would be viable.

In family accommodation that we subsidise for student family use and which is highly desirable in comparison to market rented alternatives. These family houses are let fully furnished, with internet services, so that families arriving to study can settle themselves quickly without disruption to their studies. It is not uncommon, once those studies are over, for those families to have difficulty “moving on” into other housing stock.

Charities must stay within their charitable objects.  Where the provider has charitable status on the grounds of education, if housing non-students, those charities may need to change current practices so that income from housing non-students is directed to a charitable purpose. They will also need to consider taxation consequences of letting to non-students.

In other legislation, the Government has recognised the special position of charities dealing with student housing and has exempted them from certain provisions (the example below comes from The Immigration Act 2014:

“Student accommodation

11(1) An agreement that grants a right of occupation in a building which -

(a) is used wholly or mainly for the accommodation of students, and

(b) satisfies either of the following conditions.

(2) The first condition is that the building is owned or managed by any of the following—

(a) an institution within the meaning of paragraph 5 of Schedule 1 to the Local Government Finance Act 1992;

(b) a body that is specified in regulations made under Article 42(2A) of the Rates (Northern Ireland) Order 1977 (S.I. 1977/2157 (N.I. 28));

(c) a body established for charitable purposes only.”

This wording excludes bodies established for charitable purposes only that are providing “wholly or mainly” student accommodation.

Unipol is not alone in having this problem and there are several registered student housing charities who would be affected.

Conclusion

Unipol welcomes many of the proposals in relation to enhanced enforcement of standards, although notes that no additional resources seem to be being made available to Local Authorities, who play the central role in this. It has no objections to a landlord register, although it is difficult to see how this would add much to enforcement when licensing options may well be better.

In this representation it has concentrated on what it regards as “the main show” of badly disruption the supply of off-street to the student market with significant consequences in respect of the academic cycle, student rents and affordability and student homelessness.

Unipol also argues that educational charities should be treated differently from for-profit landlords.

Unipol is happy to work with the Committee and DLUHC to provide enhanced protection for students and those becoming students and address some of the concerns raised about current practices, but putting these minority interests ahead of majority need smacks of “the tail wagging the dog”.

Unipol Student Homes

Response to Levelling Up, Housing and Communities Committee Inquiry – Reforming the Private Rented Sector

Note on Legal Options and Explanations

Fixed Term and Periodic tenancies

The academic cycle

Contracts for student accommodation all tend to start and end roughly at the same time, to coincide with the start and end of the academic year.  Fixed-term contracts have for many years been the norm in student accommodation because landlords know they will have difficulty finding replacement tenants as there is limited mid-year demand from students, and tenants anticipate that they will have difficulty finding an alternative property, part-way through an academic year.

Market forces have produced the fixed-term tenancy in student accommodation, but in practice fixed terms do not cause any difficulty for the majority of landlords or tenants in the student accommodation sector.  

The very limited number of students (approximately 1-2 percent per year) who wish to vacate before the expiry of their fixed term are usually able to do so if they find a suitable replacement tenant.  Finding a replacement is more difficult towards the end of the term - but by that time an end to the student’s rent liability is in sight.

Students who remain in occupation after their fixed term has expired are in a tiny minority.  Of these, only a proportion will become statutory periodic tenants, because such tenancies do not arise in university-owned accommodation.

There is no evidence that students will have – or that they need - any greater security under periodic tenancies than they currently have under fixed-term tenancies.  By contrast, landlords will face considerable uncertainty if students do not have to commit for longer than 2 months.

Landlords and tenants are currently free to enter into contractual periodic tenancies, but few (if any) in the student rental sector choose to do so.

Pricing

Accommodation pricing is formulated on the presumption that the property will be let throughout the whole, or a substantial part, of the academic year.  The accommodation might be packaged as a 39-week tenancy at £130 a week or as a 42-week tenancy at £120.71 a week – but the tenancy costs the tenant the same amount overall.

Shared Living

In the off-street private rented sector, joint tenancies are the norm.   A single student could give valid notice to quit a joint tenancy.  That notice would be irrevocable and binding not only on the student who gave the notice, but on the rest of the group.   A landlord could agree to re-let to the rest of the group, but if a replacement student cannot be found, each of the remaining students would be liable to pay a proportionately higher rent.  A landlord may prefer not to re-let to the remaining students.

The balance of a group in a shared unit could be altered significantly if a non-student is introduced to replace a student who has left a shared house or flat part-way through the academic year.  This may prompt other students in the flat to leave.

If non-students are housed in a shared unit, they may be less likely than students to move on at the end of the academic year.  Landlords will therefore not be able to let with vacant possession to new groups for the following academic year.  This may effectively ‘sterilise’ the property, taking several bed spaces out of circulation until the whole property again becomes vacant.

Off-street properties occupied by students are adapted for occupation by groups of students.  They have an institutional appearance that is unlikely to be attractive to families and couples.  Many will be too large to house single family units.  Many are in older districts without dedicated parking spaces.   Community action groups have campaigned against the effect of transient tenants on their neighbourhoods, with students often quoted as an example.  If students are not committed to renting for longer than 2 months, the population may become even more transient in student areas than it is now.

Who is a Student? Current Legal Definitions

A minority of people cease to have student status part-way through an academic year or part-say through their tenancy.  It would be helpful to clarify whether a person will be deemed to be a student throughout their tenancy if they were a student when they entered into their tenancy agreement, or must be a student on their tenancy start date.   Note that some tenancies will begin shortly before students register or enrol at their educational institution.   It would be unhelpful to both landlords and tenants if a person’s tenancy status were to change mid-term if they ceased to be a student.

It would be helpful to have a consistent statutory definition of “student” for housing matters that will be used in any new Act.

Housing Act 1988, schedule 1

(tenancies which cannot be assured tenancies)

Lettings to students

8(1) A tenancy which is granted to a person who is pursuing, or intends to pursue, a course of study provided by a specified educational institution and is so granted either by that institution or by another specified institution or body of persons.

(2) In sub-paragraph (1) above “specified” means specified, or of a class specified, for the purposes of this paragraph by regulations made by the Secretary of State by statutory instrument.

(3) A statutory instrument made in the exercise of the power conferred by sub-paragraph (2) above shall be subject to annulment in pursuance of a resolution of either House of Parliament.

Local Government Finance Act 1992, schedule 1

(council tax)

Students etc.

4(1) A person shall be disregarded for the purposes of discount on a particular day if—

(a)    on the day he is a student, student nurse, apprentice or youth training trainee; and

(b)    such conditions as may be prescribed by order made by the Secretary of State are fulfilled.

(2) In this paragraph “apprentice”, “student”, “student nurse” and “youth training trainee” have the meanings for the time being assigned to them by order made by the Secretary of State.

5(1) An institution shall, on request, supply a certificate under this paragraph to any person who is following or, subject to sub-paragraph (3) below, has followed a course of education at that institution as a student or student nurse.

(2) A certificate under this paragraph shall contain such information about the person to whom it refers as may be prescribed by order made by the Secretary of State.

(3) An institution may refuse to comply with a request made more than one year after the person making it has ceased to follow a course of education at that institution.

(4) In this paragraph—

“institution” means any such educational establishment or other body as may be prescribed by order made by the Secretary of State; and

“student” and “student nurse” have the same meanings as in paragraph 4 above.

Housing Act 2004, schedule 14

(buildings that are not HMOs for the purposes of the Act, excluding Part 1)

Buildings occupied by students

4(1) Any building—

(a)    which is occupied solely or principally by persons who occupy it for the purpose of undertaking a full-time course of further or higher education at a specified educational establishment or at an educational establishment of a specified description, and

(b)    where the person managing or having control of it is the educational establishment in question or a specified person or a person of a specified description.

(2) In sub-paragraph (1) “specified” means specified for the purposes of this paragraph in regulations made by the appropriate national authority.

(3) Sub-paragraph (4) applies in connection with any decision by the appropriate national authority as to whether to make, or revoke, any regulations specifying—

(a)    a particular educational establishment, or

(b)    a particular description of educational establishments.

(4) The appropriate national authority may have regard to the extent to which, in its opinion—

(a)    the management by or on behalf of the establishment in question of any building or buildings occupied for connected educational purposes is in conformity with any code of practice for the time being approved under section 233 which appears to the authority to be relevant, or

(b)    the management of such buildings by or on behalf of establishments of the description in question is in general in conformity with any such code of practice,

as the case may be.

(5) In sub-paragraph (4) “ occupied for connected educational purposes ”, in relation to a building managed by or on behalf of an educational establishment, means occupied solely or principally by persons who occupy it for the purpose of undertaking a full-time course of further or higher education at the establishment.

Immigration Act 2014, schedule 3

(exclusions from right to rent checks)

Student accommodation

11(1) An agreement that grants a right of occupation in a building which—

(a) is used wholly or mainly for the accommodation of students, and

(b) satisfies either of the following conditions.

(2) The first condition is that the building is owned or managed by any of the following—

(a) an institution within the meaning of paragraph 5 of Schedule 1 to the Local Government Finance Act 1992;

(b) a body that is specified in regulations made under Article 42(2A) of the Rates (Northern Ireland) Order 1977 (S.I. 1977/2157 (N.I. 28));

(c) a body established for charitable purposes only.

(3) The second condition is that the building is a hall of residence.

(4) In this paragraph and paragraph 12 “student”—

(a) in relation to England and Wales or Scotland, has the same meaning as in paragraph 4 of Schedule 1 to the Local Government Finance Act 1992;

(b) in relation to Northern Ireland, means a person who satisfies such conditions as to education or training as may be specified in regulations made under Article 42(2A) of the Rates (Northern Ireland) Order 1977 (S.I. 1977/2157 (N.I. 28)).

12 An agreement under which accommodation is provided to a student who has been nominated to occupy it by an institution or body of the kind mentioned in paragraph 11(2).

Ends.

August 2022