What is fair wear and tear?

The deterioration that comes from ordinary use over the time of the tenancy: worn carpet in a hallway, small nail holes, faded paint. Damage is what ordinary use would not cause: a burn, a broken door, a stain that cleaning cannot lift.

Can I deduct for cleaning?

Only to bring the property back to the standard recorded at the start, and only with evidence of that standard.

The tenant will not give me a forwarding address. When does my deadline start?

In British Columbia, and in a number of US states, not until you receive it, and you should record every attempt to obtain one; in England, Australia and New Zealand the scheme or authority holds the money and the claim runs on its own clock.

Can I keep the whole deposit against the final utility bills in Germany?

A reasonable retention for a pending Betriebskostenabrechnung is accepted; keeping the whole deposit for months without a stated reason is not.

End of tenancy and deposit return checklist, market by market

Every market lets a landlord deduct unpaid rent and damage beyond fair wear and tear from the deposit, and every market punishes a late or unexplained return. What differs is who holds the money, how many days you have, and who decides a dispute. The checklist below is the same in every market; the table gives each country's answer.

The checklist, everywhere

Confirm the end date in writing and the notice that produced it, and diarise the deposit deadline from the day the tenant hands back the keys, or, where the rule says so, from the day you receive their forwarding address.

Inspect against the entry condition report or inventory, with the tenant present if they wish, and with dated photographs of every item you may claim for.

Separate fair wear and tear, which is never deductible, from damage, cleaning beyond the entry standard, and unpaid rent or bills, which are.

Price each deduction with an invoice or a quote, and account for the age of the item: a ten-year-old carpet is not replaced at new-carpet cost anywhere.

Send the tenant an itemised statement of deductions with the evidence, and pay the balance by the market's deadline and method.

Where a scheme or authority holds the deposit, file the claim or release with it rather than paying the tenant directly.

If the tenant disputes, use the market's dispute route first; self-help retention past the deadline is what the penalties are for.

Close the ledger: final rent and bills reconciled to zero, keys and access devices logged, meter readings recorded, the owner told what was deducted and why, and the file kept for the retention period.

The country table

Deposit return rules by market, as at 21 September 2026
Market	Who holds it	Cap	Deadline to return or claim	Disputes	Penalty for getting it wrong
United States	The landlord or manager, in a trust or escrow account where the state requires it	By state; some states none	By state: a set number of days after move-out with an itemised statement (the Cuvanti state guide holds the table)	Small-claims court in most states	By state; many impose a multiple of the deposit for bad-faith retention
England	A government-approved deposit protection scheme; the landlord must protect the deposit within 30 days of receiving it	Five weeks' rent where the annual rent is under £50,000, six weeks at £50,000 or more	Within 10 days of the landlord and tenant agreeing the amount to be returned	The scheme's free dispute resolution, then court	Not less than the deposit and up to three times the deposit for failure to protect (Housing Act 2004, section 214)
Australia	The state or territory bond authority (Rental Bonds Online in New South Wales, the RTBA in Victoria, the RTA in Queensland)	Four weeks' rent in New South Wales and Queensland; by state elsewhere	Either party lodges a claim with the authority after the tenancy ends; the other party has 14 days to dispute in New South Wales, Victoria and Queensland before it is paid out. In Victoria the rental provider must tell the renter at least three business days before lodging a claim with the RTBA and give the renter the supporting evidence (invoices, receipts, quotes or photographs), which must not contradict the condition report	The state tribunal (NCAT, VCAT, QCAT), in Victoria after Rental Dispute Resolution Victoria	Tribunal orders and penalties under the state Act
New Zealand	Tenancy Services; the landlord must lodge the bond within 23 working days of receiving it	Four weeks' rent; a pet bond up to two weeks' more	The landlord submits the refund request in Bond Hub after the tenancy ends; every tenant on the tenancy must agree or disagree with the amount	The Tenancy Tribunal	Unlawful-act damages for failing to lodge
Canada	By province: Ontario allows no damage deposit, only a rent deposit applied to the last month; British Columbia and Alberta allow a security deposit held by the landlord	Ontario one month's rent (rent deposit); British Columbia half of one month's rent, plus a pet deposit of the same size; Alberta by the provincial Act	British Columbia: 15 days from receiving the forwarding address, to return it with interest or apply for dispute resolution; Alberta: 10 days from the day the tenant gives up possession, to return it with interest or send a statement of account	The provincial tribunal (RTB in British Columbia, RTDRS in Alberta, LTB in Ontario)	British Columbia: double the deposit for a late return
Germany	The landlord, at a bank in an account separate from their own money, interest to the tenant (section 551 BGB)	Three months' cold rent, payable in three instalments	No statutory deadline; the courts allow the landlord a reasonable period to inspect and settle claims, plus a reasonable retention for a pending operating-cost statement	The local court (Amtsgericht)	Interest and costs; no statutory multiple

The move-out checklist, the condition report with photographs, the itemised deduction statement and the deposit ledger are one workflow in Cuvanti, with the deadline for the property's market shown from the day the keys are returned; the owner statement shows the deduction and the refund as separate lines. General information, not legal advice: the figures above carry their source and the date checked, and the state or province rule is the one that binds.