Part 5: Transitional Relief

The Valuation Office technical manual for the rating of business (non-domestic) property.

Transitional relief is a way of reducing the immediate impact of Revaluations to enable businesses in sectors where rental values and therefore rateable values have significantly increased since the previous valuation list time to adjust to their increased tax liability.

It was introduced back in 1990 following the first revaluation since 1973, in which time rents in parts of the country and in some sectors had increased massively with other areas and sectors seeing very little rental growth. To cushion the impact of the revaluation a transitional relief scheme was devised. Wales discontinued a transitional relief scheme after the 1995 revaluation, England has continued to apply a transition scheme to each new list.  

Whenever the list entry for a hereditament is incorrect at any of these dates and cannot be amended the VO must certify what the list value should have been.

The legislation, regulations and explanations for when and how to serve a certificate can be found for each scheme on the following pages.

Transition is applied by comparing either the rateable value or certified value for a hereditament on the last day of a list with the rateable value or certified value for a hereditament on the first day of the next list.

The Billing Authorities then apply the appropriate adjustments to calculate the rate demand that is sent to the ratepayer.

Please direct any queries you have regarding transitional relief to the Litigation and Technical Policy Team via the green button on the Non Domestic Rating Homepage.

The chargeable amounts regulations set out how chargeable amounts are calculated for non-domestic rates in England.

Regulation 14 explains changes in rateable value actually occurring on 1 April 2026.

Where the rateable value shown in a list for 1 April 2026 is affected by a change in relevant factors a material change of circumstances (MCC) or the extent to which the property is exempt that actually occurs on 1 April 2026 the VO must certify the rateable value that would have been shown for 1 April 2026 on the assumption that the factors applicable on 31 March 2026 had continued to apply (for example, that the MCC or change in exemption had not taken place).

Where the VO would have certified an amount under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 1st April 2026 had the circumstances existing on 31st March 2026 continued to apply on that date, that amount.

Template VO7632 and VO7632A.

Regulation 15 explains partly occupied hereditaments apportioned under s44A certificates, transitional relief is calculated by BA, and is based upon s44A apportionment.

Regulation 17 explains inaccuracy in the Rateable Value shown for 1 April 2026. 

This regulation requires the Valuation Officer to certify:

  • the correct RV for 1 April 2026
  • any amount which the Valuation Officer would have certified under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 1st April 2026, had the list been accurate for that date

If the Valuation Officer is of the opinion that the rateable value shown for that day is inaccurate for any reason other than solely due to an MCC occurring on that day (in which case see Regulation 14). 

It is most likely to be necessary where the Valuation Officer has increased the rateable value due to a compiled list inaccuracy and the effective date of that increase has been restricted to the day the list was altered by the Valuation Officer by regulation 14(7) of the Non-Domestic Rating (Alteration of Lists and Appeals)(England) Regulations 2009 SI No 2268. All other errors in the compiled list are capable of being corrected by alteration of the list itself and certification will not be necessary. Even though such a certificate may result from an increase in rateable value there is no need to seek the consent of, or a request from, the ratepayer before issuing the certificate. 

Template VO7633 and VO7633A.

Regulation 18 explains inaccuracy in the Rateable Value shown for 31 March 2026. 

This certificate is used when the Valuation Officer is of the opinion that the RV shown for a hereditament for 31 March 2026 is inaccurate and the list cannot be amended.  The Valuation Officer must certify:

  • the rateable value that should have been shown for that day
  • any amount which the Valuation Officer would have certified under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 31st March 2026, had the list been accurate for that date

Where the rateable value certified is greater than the rateable value shown in the list for 31 March 2026 it will only have effect from either: 

  • the date from which any certificate issued under regulation 17 has effect
  • where no regulation 17 certificate has been issued then the regulation 18 certificate will have effect from the day it is issued
  • any amount which the Valuation Officer would have certified under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 31st March 2026, had the list been accurate for that date

Templates VO7634, VO7634A, VO7635, VO7635A.

Where the rateable value so certified is less than the rateable value actually shown in the list for 31 March 2026 the certified value has effect for liability from 1 April 2026.

Regulation 19: splits, mergers and reconstitutions occurring prior to 1 April 2026

Regulation 19 explains splits, mergers and reconstitutions occurring prior to 1 April 2026.

This certificate is applicable where the actual day on which a split, merger or reconstitution took place was prior to 1 April 2026, but the new hereditament(s) is first shown in a list on 1 April 2026. The Valuation Officer must certify:

  • the rateable value(s) applicable for the new hereditament(s) if it had been shown in a list for 31 March 2026
  • any amount which the Valuation Officer would have certified under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 31st March 2026, had the hereditament been shown in a list on that date

The Valuation Officer has the power until 31 March 2027 to alter the 2023 list to show new hereditaments arising from these circumstances so there was no need to issue regulation 19 certificates until 1 April 2027. 

Templates VO7636, 7636A, VO7637, VO7637A, VO7638, VO7638A

Schedule — Splits, Mergers and Reconstitutions actually occurring on 01 April 2026 

The Schedule sets out the rules that apply when hereditaments are split, merged or reconstituted on 1 April 2026.

The only occasion a Valuation Officer needs to provide a certificate under this Schedule is when a split, merger or reconstitution of hereditaments actually occurs on 1 April 2026. The certificate is of the rateable value(s) that would have been shown for 1 April 2026 but in respect of the hereditament(s) and facts that existed on 31 March 2026. 

In most cases the values to be certified will be the original rateable value(s) shown in the 2026 compiled list prior to the list alteration which reflects the split, merger or reconstitution. 

The Valuation Officer must certify that:

  • the schedule applies 
  • the rateable value which would have been shown in a list for the old hereditament for 1st April 2026 on the assumption that the relevant factors were as they were for 31st March 2026 
  • the value certified by the Valuation Officer as the amount which would have been certified under regulation 5(1) of the Improvement Relief Regulations in relation to a qualifying period including 1st April 2026 were the old hereditament shown in a list for that date on the assumption that the relevant factors were as they were for 31st March 2026

Templates VO7967, VO7967A, VO7968, VO7968A, VO7969, VO7969A

(1) The appropriate valuation officer (AVO) must certify the rateable values which fall to be certified by the AVO under these Regulations as soon as practicable after the circumstances calling for the certification come to the AVO’s attention (whether by virtue of an application by the billing authority, the Secretary of State, the ratepayer or otherwise). 

(2) Where, whether by reason of a decision of the Valuation Tribunal for England or otherwise, the AVO forms the opinion that a certificate under these Regulations (other than such a certificate which has been confirmed on appeal) is inaccurate, the AVO must certify the rateable value which in the AVO’s opinion should be substituted for the rateable value originally certified. 

(3) A certificate under paragraph (2) has effect in place of the previous certificate, and any appeal against the previous certificate under regulation 23 is taken to be withdrawn. 

  • notify the billing authority or, so far as it relates to a liability under section 54 of the Act, the Secretary of State, of the effect of the certificate
  • send a copy of the certificate to the ratepayer

(5) The copy of a certificate sent to a ratepayer under paragraph (4) may be sent to:  

  • the ratepayer’s last known address
  • the address of the hereditament

(6) The copy of a certificate sent to a ratepayer under paragraph (4) must be accompanied by:

  • a statement of the effect of regulation 23
  • for a value certified under paragraph (2), a statement of the effect of paragraph (3)

(7) A certificate issued under these Regulations:

  • must be retained by the AVO who issued it
  • may be inspected by any person at any reasonable time

[Regulation 23] () set out how a ratepayer may appeal a certificate issued by the Valuation Officer under these provisions.

(1) Where an interested person in relation to a hereditament in respect of which a value is certified by an appropriate valuation officer under these Regulations is dissatisfied with the value so certified, the interested person may appeal against the certificate in accordance with this regulation. 

(2) An appeal under paragraph (1) is made by serving a notice on the appropriate valuation officer stating the appellant’s reasons for being dissatisfied. 

(3) A notice mentioned in paragraph (2) must be served within the period of 6 months beginning with the date on which the certificate was issued. 

  • the notice is withdrawn

The disagreement must be referred by that officer to the Valuation Tribunal for England as an appeal against that certification. 

(5) Parts 2, 4 and 5 of the Appeals Procedure Regulations apply in relation to an appeal under this regulation. 

(6) For the purposes of paragraph (1), “interested person” has the meaning given in the Appeals Procedure Regulations.

The Non-Domestic Rating (Chargeable Amounts) (England) Regulations 2022 SI No.1403.

Changes in rateable value actually occurring on 1 April 2023.

Where the RV shown in a list for 1 April 2023 is affected by a change in relevant factors [a material change of circumstances (MCC)] or the extent to which the property is exempt] that actually occurs on 1 April 2023 the VO must certify the RV that would have been shown for 1 April 2023 on the assumption that the factors applicable on 31 March 2023 had continued to apply (i.e. that the MCC or change in exemption had not taken place).

Partly occupied hereditaments apportioned under s44A certificates, transitional relief is calculated by BA, and is based upon s44A apportionment.

Inaccuracy in the Rateable Value shown for 1 April 2023.

This regulation requires the VO to certify–

a) that it applies, and b) the correct RV for 1 April 2023,

if the VO is of the opinion that the RV shown for that day is inaccurate for any reason other than solely due to an MCC occurring on that day [in which case see Reg 16 above].

It is most likely to be necessary where the VO has increased the RV due to a compiled list inaccuracy and the effective date of that increase has been restricted to the day the list was altered by the VO by regulation 14(7) of the Non-Domestic Rating (Alteration of Lists and Appeals)(England) Regulations 2009 SI No 2268. All other errors in the compiled list are capable of being corrected by alteration of the list itself and certification will not be necessary. Even though such a certificate may result from an increase in rateable value there is no need to seek the consent of, or a request from, the ratepayer before issuing the certificate.

Inaccuracy in the Rateable Value shown for 31 March 2023.

This certificate is used when the VO is of the opinion that the RV shown for a hereditament for 31 March 2023 is inaccurate and the list cannot be amended. The VO must certify –

a) that regulation 19 applies, and b) the RV that should have been shown for that day.

Where the RV certified is greater than the RV shown in the list for 31 March 2023 it will only have effect from either:

  1. the date from which any certificate issued under regulation 18 has effect.
  2. where no regulation 18 certificate has been issued then the regulation 19 certificate will have effect from the day it is issued. Template certificate VO7635, VO7635A

Where the RV so certified is less than the RV actually shown in the list for 31 March 2023 the certified value has effect for liability from 1 April 2023.

Regulation 20: splits, mergers and reconstitutions occurring prior to 1 April 2023

This certificate is applicable where the actual day on which a split, merger or reconstitution took place was prior to 1 April 2023, but the new hereditament(s) is/are first shown in a list on 1 April 2023. The VO must certify –

a) that regulation 20 applies, and b) the RV(s) applicable for the new hereditament(s) if it/they had been shown in a list for 31 March 2023.

The VO has the power until 31 March 2024 to alter the 2017 list to show new hereditaments arising from these circumstances so there is no need to issue regulation 20 certificates until after 1 April 2024.

– Splits, Mergers and Reconstitutions actually occurring on 01 April 2023

The only occasion a VO needs to provide a certificate under this Schedule is when a split, merger or reconstitution of hereditaments actually occurs on 1 April 2023. The certificate is of the rateable value(s) that would have been shown for 1 April 2023 but in respect of the hereditament(s) and facts that existed on 31 March 2023.

In most cases the values to be certified will be the original rateable value(s) shown in the 2023 compiled list prior to the list alteration which reflects the split, merger or reconstitution.

Note that as 1 April 2023 is a Saturday it is likely that these certificates will not be commonplace.

The appropriate valuation officer (“the AVO”) must certify the rateable values which fall to be certified by the AVO under these Regulations as soon as practicable after the circumstances calling for the certification come to the AVO’s attention (whether by virtue of an application by the billing authority, the Secretary of State, the ratepayer or otherwise).

Where, whether by reason of a decision of the Valuation Tribunal for England or otherwise, the AVO forms the opinion that a certificate under these Regulations (other than such a certificate which has been confirmed on appeal) is inaccurate, the AVO must certify the rateable value which in the AVO’s opinion should be substituted for the rateable value originally certified.

A certificate under paragraph (2) has effect in place of the previous certificate, and any appeal against the previous certificate under regulation 24 is taken to be withdrawn.

(a) notify the billing authority or, so far as it relates to a liability under section 54 of the Act, the Secretary of State, of the effect of the certificate; and

(b) send a copy of the certificate to the ratepayer.

The copy of a certificate sent to a ratepayer under paragraph (4) may be sent to -

(a) the ratepayer’s last known address, or

(b) the address of the hereditament.

The copy of a certificate sent to a ratepayer under paragraph (4) must be accompanied by -

(a) a statement of the effect of regulation 24, and

(b) for a value certified under paragraph (2), a statement of the effect of paragraph (3).

A certificate issued under these Regulations -

(a) must be retained by the AVO who issued it; and

(b) may be inspected by any person at any reasonable time.

(1) Where an interested person in relation to a hereditament in respect of which a value is certified by an appropriate valuation officer under these Regulations is dissatisfied with the value so certified, the interested person may appeal against the certificate in accordance with this regulation.

(2) An appeal under paragraph (1) is made by serving a notice on the appropriate valuation officer stating the appellant’s reasons for being dissatisfied.

(3) A notice mentioned in paragraph (2) must be served within the period of 6 months beginning with the date on which the certificate was issued.

(a) the notice is withdrawn, or

(b) the appropriate valuation officer and the appellant agree in writing as to the value which should be certified,

the disagreement must be referred by that officer to the Valuation Tribunal for England as an appeal against that certification.

(5) Parts 2, 4 and 5 of the Appeals Procedure Regulations apply in relation to an appeal under this regulation.

(6) For the purposes of paragraph (1), “interested person” has the meaning given in the Appeals Procedure Regulations.

Part 5H Transitional relief: Appeals against certificates of value for transitional purposes

1. General

A right of appeal by an ‘interested party’ unhappy with a transitional relief certificate is limited to 6 months from the date of issue of the certificate.

Read Regulation 24 of The Non-Domestic Rating (Chargeable Amounts) (England) Regulations 2022 SI 1403 for the 2023 list schemes, and Regulation 23 of The Non-domestic rating (Chargeable Amounts) (England) 2026 SI 81 for the 2026 list scheme.

Parts 2, 4 and 5 of the Appeals Procedure Regulations SI 2009/2269 (general provisions relating to appeals) shall apply in relation to such an appeal — Regulation 2 states that an ‘interested person’ in relation to a hereditament means the occupier and any other person (other than a mortgagee not in possession) having in any part of the hereditament:

a) a legal estate or

b) an equitable interest such as would entitle him (after the cessation of any prior interest) to possession of the hereditament or any part of it

VO’s Certificates of Value may have been made following a request from a ratepayer, Billing Authority, Secretary of State or otherwise. It is not a prerequisite for an appeal by an interested party that he or she must have received a copy of a VO’s certificate. Certificates should be served upon the occupier and the Billing Authority. Duplicate certificates to agents or 3rd parties should not be issued, and only in very limited circumstances may a certificate be served on an agent rather than the occupier, and not before obtaining advice from your Technical Adviser.

Appeals are against the Certificate of Value not the decision to certify or in fact the decision to not certify.

Revoked schemes — there is no further requirement for the Valuation Office to certify the 2017 scheme unless you are serving an amended certificate following settlement of a TR certificate appeal.

Regulation 24 of the Non-Domestic Rating (Chargeable Amounts) (England) Regulations 2026 SI No. 81 revoked regulations 16 to 21 of the Non-Domestic Rating (Chargeable Amounts) Regulations 2016; which related to the certificates and appeals against certificates for the 2017 scheme, therefore there is no longer any requirement in England to certify values for the 2017 list scheme after 1 April 2026.

2. Transitional Certificate Appeals received out of time

The same policy adopted for out of time proposals should be adopted for out of time certification appeals. The appellant should be informed that the appeal is considered invalid.

3. Method of appeal

The regulations do not prescribe any statutory requirements for a Notice of Appeal, except that the appellant should state the ‘reasons for being dissatisfied’. The quality of appeals received by VOs may vary considerably and VOs should adopt a common sense approach concerning their completion, especially when they are in the form of a letter.

An appeal should be in writing and contain the following information:

a) the address of the hereditament

b) the name and address of the person making the appeal

c) the reasons, for dissatisfaction

As a general principle, the benefit of doubt as to the validity of an appeal should be given to the appellant.

The appeal must be served on the appropriate VO.

4. Action on receipt of a Notice of Appeal

Whenever a Notice of Appeal has been received by a VO, the following action should be taken:

1) Inform the caseworker who issued the TR certificate and their line manager of the appeal. 2) The line manager should decide whether the appeal should be passed to another caseworker. 3) Acknowledge receipt of the Notice of Appeal.

A copy of each Notice of Appeal should be sent to the appropriate Billing Authority concerned, marked for ‘Information Only’. This action will inform the Billing Authority of a pending appeal against the certified RV being used by the authority for transitional purposes and enable them to deal with any correspondence received from the appellant concerning transitional relief.

5. Filing of documents

When a Notice of Appeal has been registered, all documents should be placed in the Electronic Document and Records Management (EDRM) system within the assessment folder for the property address. The team leader should be notified of the appeal by email in order that they can allocate it to a caseworker.

6. National Valuation Unit (NVU) cases

When a Notice of Appeal is received for a property dealt with by a NVU Valuer the documents should be placed in EDRM under the property assessment folder and an email sent to the NVU mailbox for allocation to the correct caseworker.

7. Transmission of appeal papers to the Valuation Tribunal (VT)

The transmission of papers relating to Transitional Certification appeals to the VT is dealt with through Rating Support Application (RSA).

Unless the appeal against the certified value is withdrawn or agreement as to the value which should be certified is reached between the VO and the appellant, best practice is for the papers to be transmitted to the VT once every 3 months for appeals outstanding more than 4 weeks.

iii) Transmission of documents to VT

See the NDR Procedures Manual, Volume 5 — Section 1 — Part 6 for instructions on the transmission of appeals to the VTE.

8. Inspections

Where an appeal has been made against a Certificate of Value, the facts should be checked and, if possible, agreed when dealing with the appeal before any VT hearing.

9. Settlement of appeals

An appeal can be withdrawn by the maker at any time before the commencement of a hearing by the VT. A withdrawal form or a letter, containing information about the certificate appealed, will also suffice.

Copies of the withdrawal should be made and sent to the Billing Authority (see Para 6(b)(ii)) and to the VT, if the appeal has been transmitted (quoting the reference serial number).

ii) Settlement of appeals by agreement

An agreement between the VO and the appellant can be made at any time before the commencement of a hearing by the VT.

A copy of the agreement should be made and sent to the Billing Authority (see Para 6(b)(ii)). A copy should also be sent to the VT, if the appeal has been transmitted (quoting the reference serial number).

10. Cases heard by VT

When a case is to be heard, the date of the hearing by the VT will be notified to the VO by the Tribunal Clerk, (not less than four weeks prior to the hearing). Upon receipt of a VT decision, the caseworker should place a copy within the property folder within EDRM.

Transitional Relief Certificate appeals are dealt with under the pre-CCA exchange of evidence rules. Read more on the Valuation Tribunal Procedure regulations. So, 2 weeks before the hearing date, both the appellant and the respondent VO must provide any evidence they are to rely on at the hearing to both the VTE and to the other party.

Where discussions take place, and a settlement is reached before the hearing, the clerk must be notified immediately.

A revised certificate of the agreed value is then issued, using either the manual templates or where the original certificate was created in the CDB by selecting the amended certificate option. The amended certificate has the suffix A to advise the Billing Authority that it replaces the original certified value.

Where the appeal is heard, if a different value is determined, again an amended certificate must be issued making it clear that there cannot be an appeal against that amended certificate.

Part 5I Transitional Relief — the 2017 scheme

The 2017 scheme is now closed. No further 2017 scheme certificates should be produced.

Original source Part 5: Transitional Relief

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