England and Wales share a court system and (until recently) shared housing statute. The Welsh Government took a different path in 2016, so if you let on opposite sides of the Severn, the paperwork is not interchangeable. Here's the practical comparison.
Terminology
| Concept | England (from 1 May 2026) | Wales (from 1 Dec 2022) |
|---|---|---|
| Primary statute | Housing Act 1988 as amended by RRA 2025 | Renting Homes (Wales) Act 2016 |
| The person renting | Tenant | Contract-holder |
| The contract | Assured Periodic Tenancy (APT) | Occupation contract (standard or secure) |
| Written statement window | Start of tenancy | Within 14 days of occupation |
| No-fault possession | Abolished | Section 173 (6 months' notice, 12-month minimum) |
| Rent increase | Section 13, once in 12 months | Section 123 variation notice (form RHW12), once in 12 months, 2 months' notice |
| Deposit schemes | DPS, MyDeposits, TDS | Same three schemes |
| Licensing | Mandatory / additional / selective under Housing Act 2004 | Rent Smart Wales, universal |
Why the terminology matters
An English AST signed for a property in Wales is not a compliant occupation contract. Using English terminology and English notice periods can render your notice invalid and your tenancy un-enforceable under the 2016 Act. Welsh tribunals take the terminology seriously, 'tenant' is not a synonym for 'contract-holder' in Wales. For a Welsh let, start from an occupation contract template for Wales rather than adapting an English document.
Rent Smart Wales
Every Welsh landlord must be registered with Rent Smart Wales. If you self-manage, you must also be licensed. You can appoint a licensed managing agent instead. Registration is at rentsmart.gov.wales, we can't do it for you, but our Welsh Starter Pack links straight to the registration flow.
Notice periods compared
| Scenario | England (post-2026) | Wales |
|---|---|---|
| No-fault possession | Not available | 6 months (s.173), 12-month minimum |
| Rent arrears (mandatory) | 4 weeks (Ground 8, 3 months' arrears) | 14 days (s.181, 2 months'/8 weeks' arrears threshold) |
| Serious breach | Immediate (Ground 14) | 1 month (s.157) |
| Landlord sale | 4 months (Ground 1A) | 6 months (s.173) |
If you have properties on both sides of the border, keep separate tenancy packs, separate notice templates and separate calendar systems. One English template repurposed for a Welsh property is the fastest way to an unenforceable notice.
Scotland and Northern Ireland
Scotland runs under the Private Housing (Tenancies) (Scotland) Act 2016, PRTs only, 18 Schedule 3 grounds, Housing and Property Chamber disputes. NI runs under the Private Tenancies Act (NI) 2022, Notice to Quit scaled to tenancy length, 12-month rent-rise minimum, mandatory rent statement. Our Scotland and Northern Ireland pages have the detail.