Material Information & Upfront Property Packs: What Buyers Need to Know (2026)
Quick answer
“Material information” is the set of facts a UK seller or estate agent must disclose in a property listing — covering price, council tax and tenure, plus things like utilities, parking and flood risk. Since 6 April 2025 this duty has sat under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), enforced by the Competition and Markets Authority (CMA), which replaced the older Consumer Protection from Unfair Trading Regulations 2008. The government is separately consulting on going further — making standardised upfront “sales packs” mandatory before a home is listed — but that is a multi-year reform that is not yet law.
What "material information" means
Material information is any fact about a property that the average buyer would need in order to make an informed decision — and which, if left out, could mislead them. In practice it is the information an estate agent or seller must put in (or link from) a property listing.
The duty is not new. What has changed is the law it sits under and who enforces it. Crucially, omitting material information is now treated as an unfair commercial practice in its own right — under the DMCC Act, the prohibitions on misleading actions and omissions are no longer subject to the old test of whether the omission would actually change the average consumer's decision.
The Parts A, B and C framework
For several years, the National Trading Standards Estate and Letting Agency Team (NTSELAT) published guidance splitting material information into three parts. That formal guidance was withdrawn in 2025 (more on why below), but the A/B/C structure remains the clearest way to understand what should appear in a listing, and is still widely used across the industry as a working reference.
Part A — always required, for every property
- Asking price
- Council tax band (or rate)
- Tenure (freehold / leasehold / etc., for sales)
Part B — should be established for every property
- Property type and construction materials
- Number and type of rooms, including measurements
- Utilities: electricity, water, sewerage, heating, broadband and mobile signal
- Parking
Part C — required only where the property is affected
- Building safety issues (e.g. cladding, asbestos)
- Restrictions (conservation areas, listed status, tree preservation orders)
- Rights and easements (e.g. public rights of way, shared drives)
- Flood risk and coastal erosion
- Planning permission issues
- Accessibility features
- Mining areas (e.g. coal mining)
For online listings, the original guidance expected Part A on the main listing and Parts B and C to be no more than one click away.
What changed in 2025: from the CPRs to the DMCC Act
Until April 2025, the legal foundation for disclosure was the Consumer Protection from Unfair Trading Regulations 2008 (CPRs), enforced by Trading Standards. On 6 April 2025, Part 4 of the Digital Markets, Competition and Consumers Act 2024 came into force and repealed those regulations, transferring primary enforcement to the Competition and Markets Authority (CMA).
Because the NTSELAT material information guidance was built on the now-repealed CPRs, NTSELAT withdrew that guidance in 2025, alongside the DMCC Act coming into force. The disclosure obligation itself did not disappear — it moved to a stricter footing:
- The CMA can now enforce consumer law directly, without first going to court.
- It can impose fines of up to 10% of a business's global annual turnover for the most serious breaches, plus personal penalties on individuals who are accessories to a breach.
- A misleading omission can be an infringement regardless of whether it actually changed a particular buyer's decision.
So the correct 2026 framing is: the duty to disclose material information continues, but under the DMCC Act 2024, policed by the CMA — not under “the CPRs” and not under withdrawn NTSELAT guidance.
The 2026 direction: upfront packs and digital property logbooks
Separately from the DMCC Act, the government is reforming how home buying works. On 6 October 2025 the Ministry of Housing, Communities and Local Government (MHCLG) launched a consultation on home buying and selling reform, which closed on 29 December 2025. The headline proposal: require a standardised “sales pack” of upfront information before a property is listed, so buyers see the facts earlier.
The proposed pack content goes well beyond today's listings — potentially including tenure, council tax band, EPC, property type, title information and seller ID, leasehold terms, building safety data, standard searches, a property condition assessment, service charges, planning consents, flood risk and chain status, alongside digital “property logbooks” and ID verification.
The government has published a reform roadmap as the outcome of that consultation, and consultation support was strong. However, the framing matters: the roadmap sets out a phased plan to 2027–2028 and beyond, with mandatory sales-pack legislation slated for “when parliamentary time permits” — i.e. not yet enacted. Near-term steps for 2026 are largely voluntary, and the government has explicitly said it is learning from the failed 2007 Home Information Packs (HIPs), which were introduced and then scrapped.
Bottom line: mandatory upfront packs are a clear policy direction, but whether — and exactly how — they become law remains uncertain. Treat any “packs are coming in 2026” claim with caution.
What this means for buyers specifically
Better disclosure rules are good news, but they have limits that matter to anyone buying:
- The information is seller-supplied and raw. Material information in a listing comes from the seller and their agent. It tells you what (e.g. “leasehold”, “flood zone 2”, “non-standard construction”) — not what it means for your mortgage, your premiums, or your resale.
- Disclosure is not verification. A listing stating a fact is not the same as that fact being independently checked against official records. Errors, omissions and optimistic framing still happen.
- It doesn't replace searches or a survey. Even a full future “sales pack” is designed to speed up the process, not remove the buyer's own due diligence. You will still want conveyancing searches and, for condition, a survey.
- None of it gives you a verdict. A listing won't tell you whether the price is fair, or whether the combination of issues is a reason to walk away.
Where HouseCheckup fits
A property listing's material information — and any future upfront pack — gives you the facts. A HouseCheckup report tells you what those facts mean and whether to walk away. We start from the same disclosures, then go further:
- •Independent verification from official sources — we check the property against public data rather than relying on what the listing says, so you're not taking the seller's word for it.
- •Plain-English red flags — flood risk, non-standard construction, planning and restriction issues translated into what they actually mean for you, not just listed as line items.
- •A clear verdict — an IQ Score and an indicative value range built from sold-price comparables, so you can see whether the asking price stacks up and how serious the issues really are.
The pack tells you the facts. We tell you what they mean — the difference between reading a listing and deciding whether to spend a quarter of a million pounds.
Check a property before you offerFrequently asked questions
- Is material information legally required in a UK property listing?
- Yes. Sellers and agents must disclose material information, and omitting it can be an unfair commercial practice. Since 6 April 2025 this sits under the Digital Markets, Competition and Consumers Act 2024, enforced by the CMA, which replaced the older Consumer Protection from Unfair Trading Regulations 2008.
- Are the National Trading Standards “Parts A, B and C” still the rules?
- The formal NTSELAT guidance was withdrawn in 2025 because the regulations it was built on were repealed. The A/B/C structure is still a useful, widely used reference for what a listing should contain, but the legal obligation now flows from the DMCC Act, not that guidance.
- What happens if an agent leaves out material information?
- It can be treated as a misleading omission and an unfair commercial practice. The CMA can enforce directly and impose fines of up to 10% of global annual turnover for the most serious breaches — and, importantly, an omission can count even if it didn't change a particular buyer's decision.
- Are mandatory upfront property packs the law yet?
- No. The government consulted on mandatory upfront “sales packs” (closing December 2025) and has published a reform roadmap, but mandatory packs are planned for future legislation “when parliamentary time permits,” with mostly voluntary steps in 2026. Given the scrapped 2007 Home Information Packs, it's wise to treat the timeline as uncertain.
- Will I still need conveyancing searches and a survey?
- Yes. Upfront information is meant to bring facts forward and speed things up, not replace your own due diligence. You should still expect conveyancing searches, and a survey is the right tool for assessing condition.
- Does a listing's material information tell me if the price is fair or if I should buy?
- No. It lists facts — it doesn't verify them independently, interpret what they mean for your situation, or give a verdict on value. That gap is exactly what an independent report is for.
Sources
- National Trading Standards — Material information guidance (Parts A/B/C)
- Propertymark — Material information guidance withdrawn as the DMCC Act takes over
- The Property Institute — Digital Markets, Competition and Consumers Act 2024
- Ashurst — CMA direct consumer enforcement powers (in force 6 April 2025)
- GOV.UK — Home buying and selling reform roadmap (consultation outcome)
- MHCLG consultation portal — Home buying and selling reform