BDM visits under the Pubs Code: the 14-day notes rule, your 7 days to disagree, and what to write down yourself

If you're a tied tenant of one of the six big pub companies, your BDM has to give you written notes of any conversation about rent, rent assessments, repairs or your business plans within 14 days, and those notes have to invite you to say within 7 days if anything in them is wrong. That's regulation 41(4) of the Pubs Code. It covers people still negotiating for a pub too, and in March the Pubs Code Adjudicator said only one of the six could show it had consistently done that for new tenants.

I'm a tied tenant. The BDM visit is the conversation where the things that cost money get said out loud: the repair that's "being looked at", the discount "until trade picks up", the rent figure that's "only a starting point". If it isn't written down, it didn't happen. The Code gives you a way to make sure it is.

What the Code actually says

Regulation 41(4) of the Pubs Code etc. Regulations 2016 says a pub-owning business must make sure its business development manager does three things:

• makes appropriate notes of any discussions with you about rent proposals, rent assessments (or money paid instead of rent), repairs to the pub, and your current or future business plans;
• gives you a record of the discussion within 14 days, counting the day it happened;
• asks you to tell them, within 7 days of getting the record, if you disagree with any of it.

"Business development manager" isn't just the person with that job title. The regulation also covers anyone else who represents the pub company in negotiations with you on those four subjects. If an area manager or an estates surveyor talks rent with you, the duty follows the conversation.

The same regulation says the pub company has to give its BDMs a copy of the Code before they deal with you on Code matters, train them on it at least once every 12 months, and train them before they carry out a rent assessment. Worth knowing. You can't take the training side to arbitration, though, as I'll come to.

What counts, and what probably doesn't

The four subjects are wider than they look. "Matters relating to your current or future business plans" covers a lot of what a BDM visit is actually about: trading, pricing, a new food offer, a refurb, putting on a guest line, what you're forecasting for next year. Here's how I'd read it in practice.

Said on the visit	One of the four subjects?	Why it matters
"We'll look at the rent at review, this is just a starting figure"	Yes, rent proposal	The number you hear first is the one you'll be anchored to
"The roof's on the list, we'll get someone out"	Yes, repairs	Who pays is the dilapidations fight at the end of the lease
"We can do you a discount on that lager until summer"	Yes, business plans (it changes your trading)	A verbal discount is the easiest promise to lose
"Your barrelage is down on last year"	Yes, business plans, and it feeds rent	Barrelage drives the rent conversation, so the numbers need to be right
Chat about the football	No	Nobody needs a note of that

That's my reading of the regulation, not legal advice. If something matters to your money and you're not sure it'll be in their note, put it in your own (more on that below).

It covers you before you sign

This is the part most people don't know. The PCA says the duty applies to prospective tied tenants as well as existing ones, so the viewings and the negotiation before you sign are covered. That's exactly when the deals get done: rent concessions, repairs before you move in, a discount to help you get going.

In October 2025 the PCA asked all six regulated pub companies, Admiral, Greene King, Marston's, Punch, Star and Stonegate, how they were meeting the rule for prospective tenants. Its review, published in March 2026, found a mixed picture. Only Admiral could show it had consistently had processes in place to meet the requirement. Stonegate had recently brought in a new digital onboarding system designed to meet it. Among the problems the PCA found:

• interview checklists, Heads of Terms and business planning notes being used as "the notes", without telling the prospective tenant about their right to challenge them within 7 days;
• compliance with the 14 days largely left to BDMs managing themselves, with Code Compliance Officers not always able to check it had been done;
• property viewing conversations sometimes meant to be confirmed by email, with no reliable way to check the emails went;
• IT systems built for existing tenants, leaving gaps for people still negotiating.

The PCA asked each company to write to it with short-term fixes and longer-term changes, and it's reviewing the responses. It also asked to hear from current, former and prospective tenants affected by this while negotiating. If that's you, the route is your pub company's CCO, and you can copy the PCA in.

Separately, the PCA has said the pub companies agreed good practice with it to extend the notes to tenants on short agreements, such as a tenancy at will, which on paper have fewer Code protections.

Your 7 days: the reply to send

When the notes arrive, read them the same day. The 7 days start the day you receive them, not the day you get round to opening them. If anything is missing or wrong, reply by email. Short, factual, no temper. Something like this:

Hi [name], thanks for the notes of our meeting on [date], received [date]. Under regulation 41(4) I'm letting you know within 7 days that I don't agree with two points. First, the notes don't mention that you said [the cellar cooler repair would be booked by the end of the month]. Second, the notes say [barrelage is down 8%]; my own figures for the same weeks show [3%], and I've attached them. Could you amend the record and send me the corrected version? Thanks, [name]

Keep the email and any attachment. If the corrected record never comes, that email is your evidence that you objected in time.

If the notes never come

Count 14 days from the meeting. If nothing's arrived, the PCA's factsheet sets out the route:

1. Raise it with your pub company's Code Compliance Officer. The CCO is there to check the company complies with the Code, must be independent of the BDMs, and has to be reasonably available to you. The PCA publishes each company's CCO contact details.
2. If that doesn't sort it, you may be able to refer the failure to the PCA for arbitration. You notify the pub company of the alleged breach, allow 21 days to pass, and make the referral within 4 months of the date you could first have made it.

For general questions about your rights, the PCA's enquiry line is 0800 528 8080, or office@pubscodeadjudicator.gov.uk. It can explain the rules but it can't advise on your case.

Arbitration over a missing meeting note sounds like a sledgehammer, and usually it would be. The point is knowing the duty is real. Most of the time a polite email to the BDM copying the CCO does the job.

Write your own note anyway

The 14-day rule is a floor, not a filing system. Some BDMs send notes the same afternoon, and the PCA's account of a day out with one Punch BDM in Bradford described exactly that. Others don't. Either way, the only record you fully control is yours. After every visit I'd do this:

• Write a few lines the same day: date, who was there, what was said on rent, repairs, prices and plans, and anything promised with a date on it.
• Send it to the BDM as a "thanks for today, here's what I took away" email. That turns your note into something they've seen, and it gives them the chance to disagree with you in writing.

Then keep every BDM email, note and reply in one folder. When a rent assessment, a dilapidations schedule or a buying-out letter lands years later, that folder is what you'll wish you had.

Repairs deserve a special mention. When you took the pub, the Code's Schedule 1 says the pub company should have given you a schedule of condition and a statement of the initial works and who's doing them. Every repair conversation since builds on that document. In the PCA's 2025 tenant survey, 68% of tied tenants said they understood the repair process, but only 45% were satisfied with how repairs were handled. Written notes are how the gap between those two numbers gets argued.

Bring your own numbers to the visit

The business plan conversation is where your trading figures get discussed, and in a tied pub they feed straight into the rent assessment later. If the only numbers on the table are the pub company's, the conversation goes their way by default.

So walk in with your own: barrelage by line for the last few months, your wet GP%, your wastage, and what your last few stocktakes said. If the BDM says barrelage is down and your counts say otherwise, you want that disagreement in writing within 7 days, with your figures attached. It's the same principle as answering a pubco stock audit: records you kept every week carry more weight than a memory.

That's where StockTap fits, and only there. It doesn't do Pubs Code admin. What it gives you is weekly counts with the variance worked out, GP% by product and a history you can export as a CSV, so the figures you bring to the visit are your own and they're dated.

Common questions

Does my BDM have to give me notes of our meetings?

Yes, for certain discussions. Under regulation 41(4) of the Pubs Code, a regulated pub company must make sure its business development manager makes notes of discussions about rent proposals, rent assessments, repairs to the pub and your current or future business plans, and gives you a record within 14 days of the discussion.

How long do I have to disagree with BDM notes?

The record must ask you to respond if you disagree with any part of it within 7 days, starting with the day you receive it. Reply in writing, by email, and keep a copy.

Does the 14-day rule apply before I sign the agreement?

Yes. The Pubs Code Adjudicator says the duty applies to prospective tied tenants in negotiations as well as existing ones, and the pub companies have agreed good practice with the PCA to extend it to people on short agreements too.

What can I do if my BDM never sends notes?

Raise it with your pub company's Code Compliance Officer first. If the pub company hasn't complied, the PCA's factsheet says you can refer it for arbitration: notify the pub company, wait 21 days, and refer within 4 months of when you could first have done so. The BDM training requirements can't be referred to arbitration.

Which pub companies does the Pubs Code cover?

The six regulated pub companies the PCA names in its 2026 review: Admiral, Greene King, Marston's, Punch Pubs, Star Pubs and Stonegate. It covers their tied tenants in England and Wales.