Comparison Guide · 2026
Assured Shorthold Tenancy (England) vs Private Residential Tenancy (Scotland) UK 2026
Renting a property in England normally means an Assured Shorthold Tenancy (AST), typically granted for a fixed term before becoming periodic, while renting in Scotland means a Private Residential Tenancy (PRT), which has no fixed end date and relies on specific statutory grounds for the landlord to end it. This guide compares the two frameworks for 2026, covering fixed terms, rent increase rules and the eviction grounds available to landlords either side of the border.
At a Glance
| Feature | AST (England) | PRT (Scotland) |
|---|---|---|
| Tenancy structure | Typically fixed term, then periodic | Open-ended — no fixed end date |
| Rent increase frequency | Governed by contract or statutory notice once periodic | Maximum once every 12 months |
| Rent increase notice | Check current gov.uk guidance for the applicable process | At least 3 months’ written notice |
| No-fault eviction route | Historically Section 21 — check current legal position | No equivalent — grounds-based only |
| Eviction decided by | County court | First-tier Tribunal for Scotland |
| Deposit protection schemes | DPS, mydeposits, TDS | SafeDeposits Scotland, LPS Scotland, mydeposits Scotland |
Key Points for Landlords/Tenants in England (AST)
- Fixed-term structure gives both parties certainty over the initial period
- Rent review clauses can be built into the tenancy agreement for the fixed term
- Always check the current legal position on Section 21/Section 8, since rental reform proposals have been under active discussion
Key Points for Landlords/Tenants in Scotland (PRT)
- No fixed end date gives tenants more long-term security in their home
- Rent increases are capped in frequency and subject to tenant referral rights
- Landlords must rely on a specific statutory ground to end the tenancy, decided by the Tribunal
Frequently Asked Questions
What is the fundamental structural difference between an AST and a PRT?
An Assured Shorthold Tenancy (AST) in England is traditionally granted for a fixed term (commonly 6 or 12 months), after which it can roll onto a periodic tenancy if not renewed or ended. Scotland's Private Residential Tenancy (PRT), introduced in December 2017, has no fixed end date at all — it continues indefinitely until either the tenant chooses to leave or the landlord ends it using one of the specific legal grounds set out in Scottish law. This is a fundamentally open-ended tenancy model rather than a fixed-term one.
How are rent increases handled differently in each country?
Under a PRT in Scotland, a landlord can only increase rent once every 12 months, must give the tenant at least 3 months' written notice, and the tenant can refer an increase they consider above market rate to a rent officer/First-tier Tribunal for adjudication (with additional rent control/pressure zone rules that have applied at various points). In England, rent increases during a fixed-term AST generally require the tenant's agreement (or a rent review clause in the contract) unless using the statutory Section 13 process once the tenancy is periodic, which requires at least one month's notice for a periodic tenancy — check gov.uk for the current process and notice periods, as rules have been reviewed as part of wider rental reform.
What grounds does a landlord need to end the tenancy in each country?
In Scotland, a landlord ending a PRT must rely on one of the specific statutory eviction grounds (for example, selling the property, moving in themselves, or tenant rent arrears/breach), and the case is decided by the First-tier Tribunal for Scotland — there is no equivalent of a no-fault Section 21 notice. In England, landlords have historically been able to use the Section 21 "no-fault" eviction route to end an AST without giving a reason, alongside Section 8 grounds-based eviction for issues such as arrears — though reform to abolish Section 21 has been under active discussion, so always check the current legal position before relying on either route.
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Do deposit protection rules differ between England and Scotland?
Both nations require deposits to be protected in an approved scheme, but the specific schemes differ — England uses the Deposit Protection Service, mydeposits and Tenancy Deposit Scheme, while Scotland has its own approved schemes (SafeDeposits Scotland, Letting Protection Service Scotland and mydeposits Scotland). Protection deadlines and the maximum deposit amount permitted also follow separate legislation in each country, so check the specific rules for the nation your property is in.
Can I use an AST for a Scottish property or a PRT for an English property?
No — the tenancy type is determined by the location of the property, not the landlord's or tenant's preference. A residential tenancy for a property in Scotland created since December 2017 will almost always be a Private Residential Tenancy under Scottish law, while a property in England will be governed by the Housing Act 1988 AST framework (subject to any wider rental reform changes). Landlords letting property in both countries need to understand and comply with both separate legal frameworks.
Key Sources
Related Comparisons
Right to Rent vs Referencing, Custodial vs Insured Tenancy Deposit Scheme
Disclaimer: This comparison is general information, not legal advice. Tenancy law differs between England and Scotland and has been subject to ongoing reform — always check current gov.uk/gov.scot guidance or speak to a solicitor before relying on any specific rule described here.