Rental rules compared
How rental rules differ, country by country
Deposits, notice periods, rent increases and contract form work differently in every market Brokik supports. Here is how fifteen rental regimes compare — and what each one means for a landlord or property manager.15 countries, 15 rulebooks
There is no single way to rent out a flat. Renting in Germany follows very different rules than renting in Poland; the deposit you can ask for in the Netherlands is capped far lower than in Norway; and a fixed-term contract that is routine in Finland is largely banned in the Dutch market. Brokik builds each country on its own tenancy law, so this comparison is distilled from the contract templates and legal reviews behind the product. Use it to weigh renting in Germany against Poland, understand the rules for renting a flat in the Netherlands, or see what a deposit really means in Switzerland — then manage it all in one place.
Rental rules at a glanceDeposit ceilings, notice periods, rent-increase mechanisms and the required contract form across the fifteen markets Brokik supports today.
| Country | Deposit | Notice | Rent increases | Contract | Renters |
|---|---|---|---|---|---|
| Up to 12 months' rent | Landlord: statutory grounds only | Regulated by tenant-protection act | Written; notarial for occasional lease | 12.9% (4.8% market-rate) | |
| Capped, held separately | Landlord needs a legitimate ground | Reference rent; Mietpreisbremse in tight areas | Written, open-ended | 52.8% (46.8% market-rate) | |
| Protected in a government scheme | Periodic from the start; landlord needs a Section 8 ground | Once a year, via Section 13 notice | Assured (periodic) tenancy | 35% | |
| 3 months + up to 3 months prepaid | Tenant 3 months; landlord limited | Annual net price index | Authorised standard form | 39.1% (38.9% market-rate) | |
| Up to 3 months' rent | Tenant 6 months; landlord at term only | Annual ISTAT (barred under cedolare secca) | Registered; 4+4 or 3+2 | 24.1% (16% market-rate) | |
| 1 month (2 furnished; none for mobility) | Tenant 3 months; landlord 6 months | Annual IRL (frozen for F/G energy) | Mandatory state model | 38.8% (16.9% market-rate) | |
| Up to 6 months, escrow account | 3 months (open-ended) | Annual CPI | Written; 3-year minimum term | 21.2% (19.3% market-rate) | |
| Flanders 3 / Brussels 2 / Wallonia 2 months | Tenant 3 months; landlord 6 months | Annual health index | Written, registered; 9-year default | 29.7% (20.5% market-rate) | |
| Up to 3 months, interest-bearing | 3 months (unspecified term) | By agreement, within statutory limits | Written | 20.7% (8.1% market-rate) | |
| Up to 2x bare rent | Strong statutory protection | Regulated annual increase | Written; open-ended default | 31.2% (5.3% market-rate) | |
| No statutory cap (3-6 months usual) | Landlord: closed statutory catalogue | CPI-linked cap (2026 rules) | Written; tier-dependent term | 45.5% (30.7% market-rate) | |
| Up to 3 months, blocked account | 3 months; official form required | Mortgage reference rate + costs | Written; cantonal form where required | 58% (52.4% market-rate) | |
| Up to 3 months' rent | Tenant 1 month; landlord 3-6 months | By agreed basis (e.g. index) | Written; reform from Oct 2026 | 31.9% (20.1% market-rate) | |
| 1 month (fianza) | 5/7-year minimum term | IRAV index; capped in stressed zones | Written; 5/7-year minimum | 26.3% (17.6% market-rate) | |
| Freely negotiated (market practice ~3 months) | Tenant 60 days; landlord 60 days + a ground | Freely negotiable, no statutory cap | Written; SZ-1 residential lease | 25.2% (6.8% market-rate) |
How renting works in each countryA short profile of the rental culture, the governing law and the details that most often surprise a cross-border landlord.
Poland is Brokik's home market and its largest. Long-term residential letting is shaped by strong statutory tenant protection, alongside landlord-friendlier variants such as the occasional lease (najem okazjonalny).
- Rental market
- 12.9% of the population rents, of which 4.8% at market rates.
- Legal framework
- Governed by the Tenant Protection Act (ustawa o ochronie praw lokatorów) and the Civil Code. A landlord may terminate an ongoing residential lease only on the statutory grounds set out in art. 11 of the Act.
- Deposit
- The deposit (kaucja) is capped by statute at up to twelve months' rent and is settled after the tenancy ends and the handover protocol is signed.
- Notice & termination
- Ordinary termination by the landlord is restricted to the statutory grounds and forms; ongoing indefinite tenancies are strongly protected.
- Rent increases
- Rent increases are regulated by the Tenant Protection Act, which limits how often and on what basis a landlord may raise the rent.
- Worth knowing
- The occasional lease (najem okazjonalny) lets an owner attach a notarial voluntary submission to enforcement, making it far quicker to recover the flat — a landlord-friendly device specific to Poland.
- Landlord risk
- Outside the occasional-lease regime, evicting a protected tenant is slow; getting the lease type right at the start matters.
Germany is a large, mature rental market where most people rent long term and open-ended leases are the norm. Tenant protection is among the strongest in Europe.
- Rental market
- 52.8% of the population rents, of which 46.8% at market rates.
- Legal framework
- Residential tenancies are governed by the Civil Code (BGB). Landlord termination requires a legitimate statutory ground, such as the owner's own use (Eigenbedarf).
- Deposit
- A security deposit (Kaution) is customary; German law caps it and requires it to be held separately from the landlord's own assets.
- Notice & termination
- Notice periods and the grounds for landlord termination are set by statute; tenants enjoy extensive protection against termination.
- Rent increases
- Ongoing rent increases follow a local reference-rent mechanism. In designated high-demand areas the Mietpreisbremse caps the rent that may be charged on a new letting.
- Worth knowing
- The Mietpreisbremse (rent brake) limits the starting rent on new lettings in tight housing markets — a headline feature of the German system.
- Landlord risk
- High tenant protection and strict formal requirements for both rent increases and termination leave little room for error.
Since the Renters' Rights Act 2025 (in force since 1 May 2026), the assured periodic tenancy is the only form of private letting in England; fixed terms and the Section 21 no-fault eviction route have both been abolished.
- Rental market
- 35% of households rent (private and social combined).
- Legal framework
- Private residential lettings are now built around the assured periodic tenancy under the Housing Act 1988, as amended by the Renters' Rights Act 2025.
- Deposit
- The deposit must be placed in a government-backed tenancy deposit protection scheme; failing to protect it exposes the landlord to statutory penalties and can block certain notices.
- Notice & termination
- There is no fixed term — the tenancy is periodic from the start. Section 21 no-fault eviction has been abolished, so the landlord can only end it on one of the Section 8 grounds; the tenant may leave at any time on two months' notice.
- Rent increases
- Rent can now be raised only once a year, through the statutory Section 13 notice; rent-review clauses agreed in the contract are void.
- Worth knowing
- Mandatory deposit protection is the detail that trips up cross-border landlords: the deposit has to sit in an approved scheme, not in the landlord's account.
- Landlord risk
- Non-compliance with deposit protection carries real financial penalties and weakens the landlord's position in a dispute.
Danish letting is tenant-protective, with rents regulated in some municipalities and free in others, and an authorised standard lease form widely used.
- Rental market
- 39.1% of the population rents, of which 38.9% at market rates.
- Legal framework
- Governed by the Lejeloven (recodified in 2022). Clauses that put the tenant in a worse position than the law, if placed outside the special-terms section, are void.
- Deposit
- The deposit may be at most three months' rent, and any prepaid rent may likewise be at most three months' rent.
- Notice & termination
- The tenant may give three months' notice; the landlord's right to terminate is limited to the statutory grounds, with at least one year's notice for own use.
- Rent increases
- Rent is adjusted once a year in line with the net price index (Statistics Denmark), stated in the contract with its base month and index.
- Worth knowing
- A landlord who rents out more than one unit must hand over move-in and move-out reports within two weeks. Missing the deadline forfeits any claim for reinstatement costs tied to the property's condition — though not claims like unpaid rent — unless the tenant acted fraudulently.
- Landlord risk
- The authorised form and the entry-report deadline are formal traps; miss them and deposit claims can fail entirely.
Italian residential letting runs mainly on two regimes: 4+4 free-rent contracts and 3+2 agreed-rent contracts that trade a capped rent for tax breaks.
- Rental market
- 24.1% of the population rents, of which 16% at market rates.
- Legal framework
- Governed by Law 431/1998, the Civil Code and Law 392/1978. Every contract must be registered with the tax authority within thirty days.
- Deposit
- The security deposit (deposito cauzionale) may not exceed three months' rent under art. 11 of Law 392/1978.
- Notice & termination
- The tenant may withdraw at any time for serious reasons with six months' notice; the landlord may refuse renewal at the first expiry only on statutory grounds, with six months' notice and a stated reason, on pain of nullity.
- Rent increases
- Rent is updated annually in line with the ISTAT consumer-price index where agreed; under the cedolare secca flat-tax regime the ISTAT increase is prohibited.
- Worth knowing
- The cedolare secca is a flat substitute tax (21%, or 10% for agreed-rent) that also exempts the contract from registration and stamp duty — but rent must then be paid through traceable means, and cash is excluded.
- Landlord risk
- Registration within thirty days and traceable rent payments are compliance musts; the agreed-rent bands are hyper-local.
France mandates an official contract model for a primary-residence lease, backs the tenant strongly, and caps rent levels in a growing list of tight-market cities.
- Rental market
- 38.8% of the population rents, of which 16.9% at market rates.
- Legal framework
- Governed by the 1989 tenancy law and its decrees. Since 2015 every primary-residence lease must use the official state contract model.
- Deposit
- The deposit is capped at one month's rent for an unfurnished let (two months for furnished); the mobility lease (bail mobilité) allows no deposit at all.
- Notice & termination
- The tenant gives three months' notice (one month in a tight-market zone); the landlord may give notice only at term, with six months' notice and a legitimate, serious reason.
- Rent increases
- Rent is revised once a year by the reference rent index (IRL) where the contract provides — but no increase or indexation applies while the dwelling is rated F or G on its energy certificate.
- Worth knowing
- Rent is frozen for energy-poor F/G homes until they improve, and encadrement des loyers caps the rent level itself in designated cities; late return of the deposit adds a 10%-per-month penalty.
- Landlord risk
- Using the official model, respecting rent controls and the energy-rating freeze are all mandatory, with fines for getting rent caps wrong.
Norwegian tenancy law is mandatory in the tenant's favour: a fixed-term residential lease normally must run at least three years, and anything shorter without a valid exception silently becomes open-ended.
- Rental market
- 21.2% of the population rents, of which 19.3% at market rates.
- Legal framework
- Governed by the husleieloven. A clause less favourable to the tenant than the law is simply void.
- Deposit
- The deposit may be at most six months' rent and must sit in a separate deposit account (depositumskonto) in the tenant's name; interest accrues to the tenant and neither party can touch it during the tenancy.
- Notice & termination
- An open-ended lease carries three months' notice to the end of a calendar month; a single room with shared access to the landlord's home is one month.
- Rent increases
- Either party may adjust the rent once a year by the change in the consumer price index, at least twelve months apart and with one month's written notice; alignment to the going market rent is possible only after two and a half years.
- Worth knowing
- The law gives the tenant a right to keep pets with good reason despite a ban, and the escrow deposit account means the deposit never passes through the landlord's hands; no fee beyond rent, deposit and guarantee may be charged.
- Landlord risk
- The six-month deposit must be escrowed rather than held by the landlord, and a mis-drafted short fixed term quietly turns into an indefinite tenancy.
Belgium regionalised its tenancy law in 2014, so the rules differ across the Flemish, Brussels and Walloon Regions; the default residential lease runs nine years on a 3/6/9 structure.
- Rental market
- 29.7% of the population rents, of which 20.5% at market rates.
- Legal framework
- Governed by the regional housing decrees (Flanders 2018, the Brussels Housing Code, Wallonia 2018) plus the Civil Code, applied according to where the property sits.
- Deposit
- The deposit ceiling depends on the region: up to three months' rent in Flanders, two months in Brussels (reform of 1 November 2024) and two months in Wallonia (since 1 June 2023), held on a blocked account in the tenant's name or via a regional guarantee fund.
- Notice & termination
- The tenant may give three months' notice at any time (with an indemnity of three, two or one month's rent if this falls in the first, second or third three-year period); the landlord can leave early for own use with six months' notice, or without reason only at the end of a triennial period.
- Rent increases
- Rent is indexed annually to the health index; for dwellings with a weak energy label the indexation is restricted in Wallonia and Brussels.
- Worth knowing
- Three regional deposit caps sit side by side, and until the lease is registered with the tax authority (free, within two months) the tenant can walk away with no notice or indemnity.
- Landlord risk
- The rules for deposit, notice and energy-label indexation all depend on the property's region, and registration is mandatory.
Estonia runs a largely flexible tenancy regime with a mandatory tenant-protective core, and a notably tenant-friendly deposit rule.
- Rental market
- 20.7% of the population rents, of which 8.1% at market rates.
- Legal framework
- Governed by the Law of Obligations Act (Võlaõigusseadus). Terms that protect the tenant cannot be waived to the tenant's disadvantage.
- Deposit
- The deposit (tagatisraha) may be at most three months' rent, may be paid in instalments, and must be kept in a separate account earning interest for the tenant.
- Notice & termination
- An unspecified-term residential lease can be terminated on three months' notice.
- Rent increases
- Rent-increase terms are agreed in the contract, within the mandatory tenant-protective limits of the Act.
- Worth knowing
- The deposit is capped at three months, can be paid in up to three instalments and earns statutory interest for the tenant — one of Europe's more tenant-friendly deposit rules.
- Landlord risk
- The protective provisions cannot be contracted away, so a landlord-heavy clause simply will not hold.
In the Netherlands open-ended leases are the rule again since the 2024 reform, which largely put an end to fixed-term residential contracts.
- Rental market
- 31.2% of the population rents, of which 5.3% at market rates.
- Legal framework
- Governed by Book 7 of the Civil Code and the Good Landlordship Act, which imposes a written information duty on the landlord.
- Deposit
- The deposit is capped at twice the bare rent and must be returned within 14 or 30 days after the tenancy ends.
- Notice & termination
- Tenants enjoy strong statutory protection against termination; the grounds and periods for landlord notice are set by the Civil Code.
- Rent increases
- Annual rent increases are regulated, and the landlord owes the tenant a written information duty at the outset of the tenancy.
- Worth knowing
- Since the Wet vaste huurcontracten took effect on 1 July 2024, a fixed-term residential lease is largely no longer allowed — open-ended is the default again.
- Landlord risk
- A fixed-term contract signed as if the old rules applied is largely void, and tenant protection is strong.
Austrian rental law is layered: the Tenancy Act (MRG) applies in full, in part, or not at all depending on the building, and rent regulation only bites where it applies.
- Rental market
- 45.5% of the population rents, of which 30.7% at market rates.
- Legal framework
- Governed by the Civil Code (ABGB) and, where applicable, the MRG. Landlord termination is limited to the closed catalogue of grounds in the Act.
- Deposit
- The MRG sets no statutory deposit cap; the Supreme Court treats three to six months' gross rent as generally acceptable.
- Notice & termination
- A landlord can terminate only on the exhaustive statutory grounds, through the courts.
- Rent increases
- Index-linked rent adjustments are capped: since 1 January 2026 at most once a year, with full CPI pass-through up to 3% and half of the excess above that, plus extra caps in the fully-regulated segment.
- Worth knowing
- The MRG's full, partial and exempt tiers, together with the Mietenpaket 2026 reform, set the minimum fixed term at five years for a business landlord and three for a private one, with a 25% discount for fixed terms in the fully-regulated segment.
- Landlord risk
- Which rules apply turns on the building's MRG tier; getting the tier wrong misprices both the rent and the deposit.
Switzerland has a single federal tenancy law that applies uniformly across every canton, with rents tied to a published mortgage reference rate.
- Rental market
- 58% of the population rents, of which 52.4% at market rates.
- Legal framework
- Governed by the Code of Obligations (OR), art. 253 onwards. A landlord's termination is valid only on the canton-approved official form, and is otherwise void.
- Deposit
- The deposit is capped at three months' rent for a home, held on a blocked account in the tenant's own name; the bank releases it to the tenant if the landlord raises no claim within a year of the lease ending.
- Notice & termination
- An open-ended lease carries three months' notice to the customary local term; the landlord must use the official form.
- Rent increases
- Rent adjustments track the published mortgage reference rate and general cost and index movements, and an increase must be served on the official form.
- Worth knowing
- Several cantons require the initial rent to be disclosed on an official form, and because rent follows the reference rate a tenant can demand a reduction when the rate falls; a free conciliation board must be tried before any court case.
- Landlord risk
- A termination that is not on the correct cantonal form is void, and rent tied to the reference rate can be pushed down as well as up.
Finland lets rents be set freely — there is no rent control — while a core of tenant-protective rules cannot be waived.
- Rental market
- 31.9% of the population rents, of which 20.1% at market rates.
- Legal framework
- Governed by the Act on Residential Leases (481/1995). Most of it is default law the parties can vary, but the protective provisions are mandatory.
- Deposit
- The deposit (vakuus) may be at most three months' rent; a term for a larger deposit is void, and no dedicated blocked account is required.
- Notice & termination
- On an open-ended lease the tenant's notice is always one month; the landlord's is six months once the tenancy has lasted a year, otherwise three.
- Rent increases
- Rent is freely agreed, but a mid-term change needs an agreed basis such as an index clause, notified in writing before it takes effect.
- Worth knowing
- A confirmed reform takes effect on 1 October 2026: landlord notice becomes three or four months, a 14-day deposit-return duty is added, rent-increase notice must give at least a month with no back-dating, and smoking is banned by default.
- Landlord risk
- The regime is mostly dispositive today, but the October 2026 reform changes the notice, deposit and rent-notice rules a landlord relies on.
Spain is strongly tenant-protective: a residential lease runs a mandatory minimum of five years where the landlord is an individual, seven where it is a company.
- Rental market
- 26.3% of the population rents, of which 17.6% at market rates.
- Legal framework
- Governed by the Urban Leases Act (LAU, Law 29/1994), as amended in 2019 and 2023. Its residential rules are imperative in the tenant's favour.
- Deposit
- The compulsory deposit (fianza) is exactly one month's rent for a home, which the landlord lodges with the autonomous community; any extra guarantee is capped at two months' rent.
- Notice & termination
- The lease extends automatically to the five- or seven-year minimum; the tenant may leave after six months with thirty days' notice, and an individual landlord can recover the home for own use after the first year with two months' notice, only if reserved in the contract.
- Rent increases
- For contracts from 26 May 2023 an update clause may reference only the IRAV index; in a declared stressed-market zone the new rent is capped by the previous rent or a reference-price ceiling.
- Worth knowing
- Rent updates are tied to the IRAV index and capped in stressed zones, and management and contract-formalisation costs always fall on the landlord.
- Landlord risk
- The five/seven-year minimum term, the stressed-zone rent caps and a regional habitability certificate in some areas all constrain the landlord.
Slovenia leaves a market-rate residential lease largely to the parties' agreement: beyond a 60-day notice floor and the mandatory written form, rent, deposit and additional termination grounds are all freely negotiated.
- Rental market
- 25.2% of the population rents, of which 6.8% at market rates.
- Legal framework
- Governed by the Stanovanjski zakon (SZ-1), with the Obligacijski zakonik (OZ) applying to anything the housing act does not cover.
- Deposit
- SZ-1 sets no statutory cap on the deposit for a market-rate lease — the three-month ceiling only applies to non-profit housing. In practice landlords typically ask for around three months' rent, freely agreed with the tenant.
- Notice & termination
- The tenant may end the lease at any time without giving a reason, on 60 days' written notice (art. 102 SZ-1). For an indefinite-term lease the landlord's notice period is likewise at least 60 days (art. 112 SZ-1), and must rely on the fault-based grounds of art. 103 or on additional grounds the parties expressly agreed in the contract, which art. 105 permits for market-rate lettings.
- Rent increases
- Rent for a market-rate lease is freely agreed between the parties; SZ-1 sets no statutory index or point system for it — that mechanism only applies to non-profit housing.
- Worth knowing
- Article 105 lets a market-rate lease add its own termination grounds on top of the statutory list, so a well-drafted contract gives the landlord more room than the bare law provides.
- Landlord risk
- Because notice periods and grounds sit largely in the contract itself, an under-specified lease leaves the landlord with only the narrow art. 103 grounds and the 60-day statutory minimum to fall back on.
This overview is for general orientation only, distilled from Brokik's per-country rental agreement templates and market research. It is not legal advice and does not replace the current text of each country's tenancy law, which changes over time and can vary by region. Where a rule differs by region or is set to change, that is flagged in the profile.
Managing rentals in more than one country?Brokik gives every property the rental agreement, tax rules and language of its own market — in a single account.
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