If the RTB Rent Register looks too low for your property, the main point is this: you still need to use it, and it still needs to carry significant weight in your decision. But that does not mean you should ignore real differences in quality, BER, size, or current local conditions where the Register results are only a rough match.
The RTB’s own guidance says landlords are legally obliged to consider the Rent Register and provide 3 comparable properties from it. The same guidance also says that if a landlord wants to set a rent above the comparable examples shown by the Register, they must justify that decision with additional evidence, such as an expert valuation.
This guide is for landlords who are trying to deal with weak RTB matches in practice. For the wider rent review rules from 1 March 2026, see How landlords should conduct a rent review in Ireland, New Landlord Rules Ireland: national rent control explained, and New Landlord Rules Ireland: a landlord and property manager guide from 1 March 2026.
Quick answer
If the RTB Rent Register looks wrong, the safe view is not to ignore it. Use it as the starting point, choose the best 3 comparable properties you can from the Register, and then explain clearly why those examples are strong or weak matches.
If your property is materially different from the Register examples, you can support your conclusion with additional evidence. That might include an expert rental valuation, BER evidence, floor area details, renovation records, or other documents that help explain why your property should not be assessed the same way as an older or poorer-quality comparable.
The legal test is still whether the rent is not above market rent. The Register is central to that assessment, but RTB guidance also recognises that landlords may need additional evidence where the Register comparables do not tell the full story.
Why landlords think the register looks wrong
In practice, landlords usually raise the same concerns:
- the Register can show rents that are well below current asking rents on Daft or MyHome
- an A-rated, extended, or recently renovated property can appear to be grouped with older stock
- the local sample can be thin, which means the “closest” results are not always truly close
- the Register includes registrations received in the last 24 months, so some results can reflect older pricing rather than the current market
None of that means the RTB Register is irrelevant. It means the landlord needs to be careful about match quality.
Asking rents and registered rents also do different jobs. Asking rents show where listings are being advertised. The RTB Register shows rent information drawn from tenancy registrations. That is one reason landlords often see a gap between the two.
What the law actually requires
For rent setting and rent review under the current RTB framework, landlords need to work from a few fixed rules:
- consider the RTB Rent Register
- provide 3 comparable properties from it
- make sure the new rent is not above market rent
- keep evidence that supports how the decision was made
The RTB’s guidance also makes two practical points that matter here.
First, the Register should be a landlord’s main reference point and should carry significant weight. Second, landlords should keep clear records because they may need to produce those documents later in a dispute or RTB investigation.
For private tenancy rent reviews, RTB guidance also says the rent review notice must go to the tenant and the RTB on the same day, and it must be served at least 90 days before the new rent takes effect.
What the RTB Register does not prevent
The RTB Register matters a lot, but it is easy to overread what it is doing.
It does not mean:
- you are banned from using supplementary evidence
- you cannot rely on an expert valuation where the Register matches are weak
- current asking rents are a replacement for RTB registered rents
The better way to think about it is this: the Register is the required anchor, not the only document in the file.
If the 3 Register examples are strong matches, they will usually do most of the work. If they are weak matches, you still need to use them, but you should explain the mismatch rather than pretend it does not exist.
When additional evidence helps
Additional evidence is most useful where the Register examples understate the quality or comparability of the property you are pricing.
An expert valuation is usually the strongest extra document where you believe the Register output does not reflect the true market position of the property. That is especially relevant where the dwelling has been materially improved, has a much stronger BER profile, or is competing in a better part of the local market than the Register examples suggest.
| Evidence | What it helps explain | How to use it |
|---|---|---|
| Expert valuation | Why the property supports a higher market-rent conclusion than the Register examples alone suggest | Use as supporting evidence, not as a substitute for the 3 RTB comparables |
| BER certificate and floor area details | Why a better-rated or larger property is not directly comparable with weaker stock | Keep the BER record and the basis for floor area consistent with the RTB process |
| Renovation or extension records | Why the dwelling has materially changed in quality, layout, or usable space | Keep invoices, contractor records, or dated supporting documents |
| Photos and inventory-style evidence | Why finish, condition, or amenities differ from weaker comparables | Use date-stamped photos and keep them tied to the tenancy file |
| Daft or MyHome listing snapshots | What current local asking-rent conditions look like | Treat as supplementary context only, not as a replacement for RTB paid-rent data |
This is where a structured evidence file helps. The goal is not to “beat” the RTB Register. The goal is to show, in a calm and reviewable way, why the Register examples may need explanation.
A practical way to build a defensible file
- Pull at least 3 comparable properties from the RTB Rent Register and save the printout or PDF.
- Pick the examples that are the best available matches, not just the first ones that appear.
- Write down why each comparable is strong or weak by reference to size, type, BER, condition, or recency.
- If the mismatch is material, get an expert valuation and add it to the file with any BER, renovation, or floor area evidence that supports it.
- Keep the Register printout, supporting evidence, notice, statement, and proof of service together in one file.
If there are very few strong matches in the exact area returned by the Register, RTB guidance says landlords can consider nearby or similar areas. If you do that, document the reason clearly and keep the explanation with the file.
Common mistakes to avoid
- ignoring the RTB Register because Daft or MyHome looks higher
- relying on weak Register matches without explaining why they are not truly comparable
- skipping an expert valuation where the property is clearly better than the Register examples
- relying only on asking-rent screenshots with no RTB Register evidence
- failing to explain why a comparable is weak or mismatched
- keeping the notice, Register printout, valuation, and proof of service in separate places
The strongest files are usually the simplest ones. They show the RTB Register first, then explain any mismatch clearly, and then attach only the extra evidence needed to support that explanation.
Short FAQ
Can I charge more than the RTB comparables?
Potentially, yes, but not just because you believe the market is stronger. RTB guidance says that if a landlord wants to set a rent above comparable examples from the Register, they must justify that it still represents market rent and provide additional evidence, such as an expert valuation.
When should I get an expert valuation?
An expert valuation is most useful where the RTB Register results look weak, sparse, or clearly inferior to the subject property. In practice, that often means major differences in condition, BER, floor area, or renovation standard.
Can I use Daft listings as evidence?
Yes, but only as supplementary context. Daft or MyHome asking rents can help show current market conditions, but they are not a substitute for the RTB Register, which remains the main reference point in the RTB process.
What if there are very few similar properties on the Register?
RTB guidance says landlords can consider nearby or similar areas where there are no comparable examples for the Local Electoral Area entered. You should still provide 3 comparable examples and document why you chose those properties or areas.
What should I keep in the file in case of a dispute?
At a minimum, keep the RTB Register printout, the 3 comparable property details, any valuation or supporting evidence you relied on, the completed notice and statement, and proof that the notice was sent correctly.