This table shows the crisis responses that were implemented in Australia, Canada, Germany, Ireland, New Zealand, Spain, the UK and the USA specifically aimed at protection for rental housing residence. It gives a high-level overview of the relative levels of regulatory assurance of these aspects of renting for each of these countries, necessarily passing over some significant differences in the legal mechanisms used between countries, and some significant differences between jurisdictions within countries.
For indicators of tenure security, the table indicates whether landlords may take termination proceedings without disclosing reasons or where these may be invoked only on certain legally prescribed grounds, and the degree to which tenants’ circumstances are considered by the relevant tribunal in termination proceedings. This may be limited by laws that make termination in some rent arrears and no-grounds proceedings mandatory (as in most jurisdictions in Australia, the UK and the US), that restrict the tribunal’s discretion to decline termination (as in New Zealand), or that put the onus on tenants to dispute termination proceedings (as in some Canadian provinces, Ireland and Spain).