Renting around the World: Comparing Europe to England

In the first Renting around the World piece, we look at how some European countries compare to England on security of tenure.

Security of tenure is one of the biggest worries for renters in England. With rents rising and the enormous cost of moving in terms of money, time and stress, no one wants to face an unwanted move.

The Renters (Reform) Bill offers some assurances for the security of renters when it is passed. The Bill, in its present form, will ban Section 21 “no fault” evictions. Section 21 allows a landlord to evict a tenant with two months’ notice for no stated reason. It is one of the leading causes of homelessness. Generation Rent has been campaigning to abolish Section 21 for nearly a decade and the number of evictions have got worse in the past couple of years.

England is almost unique in Europe for having such weak security of tenure, so the Bill is a much-needed step in the right direction.

However, the Bill doesn’t go far enough. Landlords will still be able to evict you if they want to sell or move a relative or themselves into the property. Under the proposals this is possible after the sixth month of the tenancy – we’re pushing for this to be extended for at least two years to allow renters to enjoy a stable home for longer.

Another change we would like to see, is to ensure that when a landlord sells a property, they sell it with the tenant in it. This is standard practice in Portugal, for example, where the landlord must offer the tenant, if they have been renting for 2 years or more, the first chance to buy the property by law if they are seeking to sell it and the landlord cannot evict the tenant whilst attempting to sell the property.

This is similar to the situation in many European countries which are much better than in England. In Sweden, Belgium, Denmark, Germany and Switzerland, for example, no fault evictions are banned, giving renters a greater feeling of security.

Switzerland prides itself on its flexibility for tenants – there are “National Moving Days” instituted so that if someone wants to move they have a full day set aside to do it. Whilst you can move on any day, these National Moving Days help to encourage certainty into what can often be an uncertain process. Tenants can also demand the extension of a lease if they feel that the landlord is terminating too early; this will be adjudicated by a court with the longest extension that can be granted on residential properties being four years. 

In Spain and Germany, the situation is somewhat different. Spanish renters can end their lease early with one month’s notice and as long as they end the lease six months after the start of the tenancy agreement, they do not have to pay any money to the landlord. This gives renters great flexibility over where they wish to move to without fear of a financial penalty. When faced with evictions, Spanish renters are also in a better position than their English counterparts. This is because in Spain, renters are generally only evicted if their landlord wishes to move in or if they fall behind on their rent. Contracts also automatically renew for five or seven years unless the tenant and landlord agree for the contract to be extended for a different length of time. This ensures that renters in Spain have a greater sense of autonomy when choosing where they wish to rent and providing them with greater protection.

In Germany renters can give notice that they wish to leave their property, via a formal cancellation letter, dependent on how often they pay their rent – for example if a renter pays their rent every month, they are required to only give a month’s notice; if it is three months’ then it will be three months’ notice. Renters in Germany also have greater protection when their landlord wishes to evict them, with reasons only being if the tenants breaks the rental contract in some way (for example being in rent arrears) or if the landlord wishes to move themselves or a relative in. The notice period for this can vary between 3 to 9 months, based on how long they’ve lived there, giving renters greater opportunity to find an alternative home if they have to. On average German renters remain in their homes for 11 years as compared to 2.5 years for their English counterparts.

Italy and France similarly have much stronger protections than England. In Italy, landlords can only use no fault evictions if they intend to move into the property themselves and they must provide six months’ notice to their tenant.  Italian rental contracts by standard are much longer than UK contracts with the average contract being between three and four years. In France, you can terminate your tenancy at any point as long as you provide 3 months’ notice – the landlord must provide six months in comparison. In Italy, a renter can end their contract early as long as they provide their landlord with six months’ notice if they have “serious and grounded reasons.” As Italian rental contracts renew after four years on the same terms as the original contract, this means many renters are paying the same rent over a period of eight years, giving them an even greater sense of stability than if they were to expect rental increases every year as tenants could still face after the Bill is passed. The checks and balances in the Italian system demonstrate a greater balance between tenant and landlord than in England and mean that tenancies are not only more stable but set for a longer term.

What’s clear is that the situation for renters in other parts of Europe is much better than in England. There is no reason that we cannot learn from our European neighbours and make renting better here; all it takes is the right legislation and the willingness of government to make the changes that we all deserve and need.


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Individual Advice

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