The Stonegate Pubs Code investigation: what it covers, what can happen, and what to keep if you're a Stonegate tenant

As of 7 October 2026 there's no finding. The Pubs Code Adjudicator opened a formal investigation into Stonegate on 15 July 2026, covering what it did between 15 July 2021 and 14 July 2026. The call for evidence closed at 5pm on 12 August. The PCA's own guidance says it's likely to finish an investigation within 12 months, though there's no legal deadline. If it finds breaches, it can make binding recommendations, make Stonegate publish information, and fine it up to 1% of its total UK turnover. Until then, nobody knows the outcome, and anyone telling you otherwise is guessing.

Stonegate comes up in the pub groups more than any other pubco, by a distance. Most of it is people trying to work out what this investigation actually means for them, and most of the replies are opinion. So here's what's on the public record, in plain English, what can happen at the end, and what a Stonegate tenant should be keeping in a folder right now, whatever the PCA decides. I'll update this page when the PCA publishes anything new.

Where it's up to

Date	What happened
10 June 2026	PCA tenant survey published. Stonegate lowest of the six regulated pubcos on tenant satisfaction, at 39%
15 July 2026	Formal investigation opened. Conduct period 15 July 2021 to 14 July 2026
17 July 2026	PCA publishes its questions and answers on the investigation
12 August 2026, 5pm	Call for evidence from current and former tenants closes
Now	PCA considering the evidence. No conclusion reached
Likely by mid-2027	Report, going by the PCA's guidance that investigations are likely to finish within 12 months. Not a legal deadline

What it's actually looking at

The PCA says it has reasonable grounds to suspect Stonegate may have broken the Code, mainly around giving accurate and transparent information to existing and prospective tenants. The notice lists five areas, plus one about Stonegate's reporting to the regulator itself. Here's each one, with what it looks like from behind the bar and the piece of paper that would prove it either way:

Suspected breach (PCA's wording, shortened)	What it looks like from behind the bar	The document that settles it
No full and clear description of the premises, including an accurate Schedule of Condition, or not disclosing specific problems	You took the pub on and found the roof, the cellar cooling or the drains weren't what the paperwork said	The Schedule of Condition you were given, your own photos from before you signed
Defective lists of initial works	Works promised at the viewing that never made the written list, or never got done, or had no completion date	The initial works list, emails and BDM notes from before you signed
Unreasonable and unrealistic projections behind rent proposals	The turnover or barrelage in your business plan was never going to happen, and the rent was built on it	The rent proposal, the projections you were given, your actual sales since
Not answering reasonable requests for information during rent negotiation, or not explaining within 7 days why not	You asked how they got to the rent and got nothing back, or nothing in writing	Your written requests and the dates of any replies
BDMs not dealing fairly and lawfully, and notes of discussions not recorded properly	Meeting notes that never arrived, or arrived and didn't match what was said	The BDM notes you were sent, and your corrections
Annual compliance report to the PCA not detailed and accurate	Nothing you'd see directly	That's between Stonegate and the regulator

The PCA also says it'll look at whether any problems it finds are one-offs or point to something wider. And it's explicit that the investigation includes Stonegate's Craft Union agreements, from when it granted intermediate tenancies to those operators in or around the end of 2024.

Read that table again if you've ever had a dilaps schedule land. The first two rows are the starting point for every repairs argument at the end of an agreement. I've written up how dilaps work on a tied lease separately, because a wrong Schedule of Condition on day one becomes a wrong bill on the last day.

What the PCA can do

The investigation runs under section 53 of the Small Business, Enterprise and Employment Act 2015. The PCA can make a pubco hand over documents and information, and it's a criminal offence to intentionally fail to, or to knowingly give false information. It can also take evidence from tenants, former tenants and anyone else. People who gave evidence won't be named in the report without their consent.

If the PCA's satisfied there's been a breach, the options it lists are binding recommendations, a requirement to publish information, and a financial penalty of up to 1% of total UK turnover. It can use more than one.

There's a precedent, and it wasn't small

The PCA's first investigation was into Star Pubs & Bars, Heineken's pub arm. In October 2020 the Adjudicator fined it £2 million after finding 12 breaches over nearly three years, mostly around the stocking terms it offered tenants who asked to go free of tie. One detail stuck with me. The job description of Star's Code Compliance Officer, the person meant to check the Code was being followed, included making sure the Code was "interpreted to the commercial benefit of Heineken UK". The PCA called Star a repeat offender.

That's not a prediction about Stonegate. Different company, different suspected breaches, and the PCA has been clear it hasn't reached a conclusion. It's just the clearest evidence of what this regulator does when it does find something.

What Stonegate has said

When the investigation was announced, Stonegate said it was fully committed to complying with the Code and treating publicans fairly, that it had communicated at length with the PCA over the specific cases that form the basis of the investigation, and that it would cooperate fully. That's its position and it's entitled to it. Nothing's been decided.

Not a Stonegate tenant? It still matters

The same PCA survey that put Stonegate bottom also showed satisfaction falling across all six regulated pubcos:

Pubco	Tied tenants satisfied, 2026
Admiral	72%
Greene King	71%
Star Pubs	67%
Marston's	63%
Punch Pubs	55%
Stonegate	39%
All six	56%, down from 61% in 2025

Awareness of each pubco's Code Compliance Officer fell from 46% to 36% in a year. Seventy percent of tenants know about Market Rent Only, and 85% know the BDM has to send meeting notes within 14 days. Those last two are the rights that make the paperwork exist in the first place, so it's worth knowing who your CCO is before you need them. The rest of your rights, including MRO and what counts as a significant price increase, are in the tied price rises guide.

What I'd keep now, if I was a Stonegate tenant

The evidence deadline's gone, but the PCA says it may follow up with people who gave evidence to ask for supporting documents, and it still takes information from tenants through its enquiry form. And whatever the report says, it won't settle your own pub's issues for you. Your paper does that. So:

• The Schedule of Condition and initial works list you signed against, plus every email about works promised.
• Your rent proposal and the projections in it, next to your real weekly sales since. If the gap's big, that's the clearest evidence you'll ever have.
• Every BDM note, with the date it arrived. If one didn't arrive within 14 days, write down that it didn't.
• Your written information requests and the dates of any replies.
• Your invoices with prices by date, so any price rise is a fact, not a feeling. My price-rise tracking guide shows the layout I use.
• Your stock results. If your rent was built on a barrelage you never got near, the audit history is the record of what actually went through the cellar.

Thinking of taking on a Stonegate pub while this runs? I wrote about the 100 managed pubs moving to Pub Partners in September. The short version is to stress-test the rent projection with your own accountant and your own numbers, not theirs, before you sign anything. The PCA's survey found only 12% of tied tenants took surveyor advice before signing. Be in the 12%.

My take

I'm not going to guess the result. What I'd say is that the suspected breaches are almost all about information: what tenants were told, what was written down, and whether the two matched. Whatever the PCA concludes, the tenants who come out of the next year in the best shape will be the ones who kept the paper. That's true at every pubco, not just this one. It's the same lesson as the stocktake, oddly. The person with the dated record wins the argument.

I'll update this page when the PCA publishes anything. If you're tied and want to see the profit side of all this, how much profit a pub actually makes puts the rent in context.

Common questions

Has Stonegate been found to have broken the Pubs Code?

No. As of 7 October 2026 the Pubs Code Adjudicator says it has reasonable grounds to suspect breaches but has not reached any conclusion on whether Stonegate broke the Code or how far.

When will the Stonegate investigation finish?

There's no legal time limit. The PCA's statutory guidance says it's likely to complete an investigation within 12 months, which from a 15 July 2026 start points to around mid-2027.

What can the PCA do if it finds Stonegate breached the Code?

Make binding recommendations, require Stonegate to publish information, and impose a financial penalty of up to 1% of total UK turnover. It can use more than one of these.

Can I still give evidence to the Stonegate investigation?

The formal call for evidence closed at 5pm on 12 August 2026. The PCA still takes information from tenants through its online enquiry form, and says to contact it if you're unsure whether what you hold is in scope.

Does the investigation cover Craft Union pubs?

Yes. The PCA says it includes Stonegate's Craft Union agreements from when it granted intermediate tenancies to those operators, in or around the end of 2024.

This is a summary of public information, not legal advice. Last checked against the PCA's pages on 7 October 2026.