Which Country Has the Better Lettings System — UK, Australia or the USA?
- Milton Jannusch
- 6 days ago
- 3 min read
When it comes to managing rental properties, each country thinks its way is best.
But the truth is — every system has its strengths and its flaws. At Pro Property London, we’ve worked with landlords and property professionals who’ve experienced the UK, Australian, and American rental markets — and while the goals are similar, the processes are dramatically different.
So which country actually has the best lettings model? Let’s break it down.
🇬🇧 United Kingdom: Regulation-Heavy, But Lacking Consistency
🔹 Key Features:
Assured Shorthold Tenancies (ASTs) (soon transitioning to periodic tenancies under the Renters Reform Bill)
Tenants typically sign for 6 or 12 months, with fixed-term clauses
Strong regulation: Deposit schemes, Tenant Fee Ban, EPC, Right to Rent, Section 21/Section 8
Inventory and inspection reporting handled by agents or independent clerks
Enforcement largely delegated to local authorities, often under-resourced
✅ Strengths:
High levels of tenant protection
Clearly defined deposit rules and documentation standards
Growing professionalism in the sector
❌ Weaknesses:
Patchy enforcement of legislation
Landlords often feel unsupported or overregulated
Court delays for evictions and possession
No universal property management standard
🇦🇺 Australia: Highly Standardised, State-by-State Governance
🔹 Key Features:
Rental laws governed at the state level (e.g. Victoria’s RTA, NSW Residential Tenancies Act)
Standardised lease forms and processes enforced state-wide
Tenants typically lodge bond with a centralised authority (like the RTBA in Victoria)
Routine inspections conducted every 3–6 months
Strong digital infrastructure — many agents use inspection apps and tenant portals
✅ Strengths:
Highly consistent process within each state
Routine inspections normalised and expected
Digital-first agent practices (automated reminders, mobile inspections, cloud reporting)
Strong dispute resolution channels via tribunals (e.g. VCAT)
❌ Weaknesses:
Complexity for landlords operating across multiple states
Less flexibility in lease structures (strict notice rules)
Ongoing push-pull between tenant rights and landlord flexibility
🇺🇸 United States: Localised, Market-Driven and Private-Sector Led
🔹 Key Features:
Rental laws vary city by city, state by state
Lease terms are flexible (month-to-month or 12-month standard)
Security deposits held by landlord or agent (not always regulated centrally)
Move-in/move-out inspections sometimes handled informally
“Home inspectors” exist, but are different from property managers
✅ Strengths:
Market-driven flexibility for landlords and tenants
Strong use of tech platforms, including AI-powered lease systems and self-guided inspections
Property managers often offer full-service packages (screening, repairs, legal)
❌ Weaknesses:
Inconsistent regulation leads to tenant exploitation in some markets
Less formal documentation (some markets lack clear inventory/check-out process)
Limited deposit protection unless mandated locally
Legal recourse varies heavily by state
🏆 So, Which Country Has the Best Lettings System?
Category | UK 🇬🇧 | Australia 🇦🇺 | USA 🇺🇸 |
Tenant Protections | ✅ Strong | ✅ Very strong | ⚠️ Varies by state/city |
Standardised Process | ⚠️ Inconsistent | ✅ Highly standardised | ❌ Highly variable |
Use of Technology | ⚠️ Growing slowly | ✅ Widely adopted | ✅ Advanced in some markets |
Inspection Process | ✅ Independent-led | ✅ Frequent and expected | ⚠️ Varies, often informal |
Legal Dispute Resolution | ⚠️ Court delays | ✅ Tribunal systems | ❌ Varies (some good, some not) |
💡 What Can UK Agents Learn from Abroad?
From Australia:
👉 Embrace standardisation — especially around inspections, communications, and dispute timelines
👉 Use digital inspection tools and automated workflows to reduce admin pressure
From the US:
👉 Think tech-first — self-service platforms, tenant portals, API integration
👉 Consider full-stack service offerings to increase value per landlord
From Ourselves (UK):
👉 Push for stronger industry-wide enforcement
👉 Promote independent documentation to reduce risk
👉 Educate landlords — compliance is no longer optional
📍 Where Pro Property London Fits In
We’re helping agents modernise their letting operations with:
✔️ Digital, independent inventory reports
✔️ Mid-term inspections and check-outs
✔️ Cloud-based delivery and timestamped images
✔️ Legally compliant documentation — fit for the UK’s changing regulations
✔️ Full service coverage across Greater London
📞 Ready to modernise your letting process and operate at global best-practice standards?
Let’s talk.