Renting across jurisdictions? Make sure you understand the differences

The Renters' Rights Act 2025 is the most significant shake-up of England's private rented sector in decades. But Great Britain doesn't operate as a single legal market for housing, and if your portfolio spans borders, the question isn't simply "what does the new law say?" — it's "which law applies, and what do you need to do about it?" Understanding the Act in isolation won't be enough for those with properties across multiple jurisdictions.

England, Wales and Scotland each has its own legislative framework — shaped by years of devolved reform, and each now sitting at a different point in its journey. We've put together a cross-jurisdictional comparison so you can see, at a glance, where the rules align, where they differ, and — crucially — where a provision of the Act applies beyond England.

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The risk for anyone operating across more than one jurisdiction is assuming the same rules apply everywhere. The three regimes have developed independently, and the gaps can be substantial — compliance timelines don't always align, rights that tenants enjoy in one jurisdiction may not yet exist in another, and provisions that appear to be England-only sometimes have direct application in Wales or Scotland, though not always in the same form or at the same time.

For investors, the financial implications are real. Yield calculations, asset management decisions and exit strategies all look different depending on where a property sits. Getting that geography wrong — at the planning stage, or during implementation — carries cost.

The devolved nations aren't playing catch-up — in some respects they've been ahead. Scotland and Wales have operated under reformed frameworks for years, and experienced landlords in those markets have already adapted in ways many English landlords are only now beginning to consider. We're helping clients draw on that experience.

The most complex questions concern provisions that cross borders. Certain protections in the Act do apply in Wales and Scotland — but through different mechanisms, with different commencement dates and under different regulatory oversight. Which provisions apply where, and when, is more nuanced than a simple "yes/no" read of the legislation suggests.

Rent economics are diverging across the three nations. Each jurisdiction's approach to frequency, reference points and caps is heading in a different direction — a strategic consideration for cross-border portfolios, not just a compliance one.

If you’d like to discuss how the changes apply to your portfolio, please get in touch with our team.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at April 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.