Topic: Rental deposits and landlord power: how many months, and how easily they can end it
What does Japan require?
Everyday topic
Japan layers several money customs on top of law. The Civil Code's Article 622-2 obliges a landlord to refund the shikikin (security deposit) once the lease ends and the unit is returned, minus what the tenant owes — but reikin ("key money," usually one to two months' rent, paid as a one-off gift to the landlord) is a custom with no statutory basis at all, and it is not refunded; some regions and property types skip it, others don't. A renewal fee (koushinryo), also custom rather than law, is common in the Kanto region. Because personal guarantors are harder to arrange than they used to be, most leases now require a paid rent-guarantee company (hoshou gaisha) instead of a co-signer. The Land and House Lease Act's Article 28 requires "just cause" (seitou jiyuu) before a landlord can refuse to renew or terminate a lease — weighed against both parties' need for the space, the lease's history, and any compensation offered — so a tenant with an ordinary fixed lease is not simply asked to leave when it expires. Disputes over the deposit mostly concern genjou kaifuku (restoring the unit to its original condition): the Ministry of Land, Infrastructure, Transport and Tourism publishes guidelines distinguishing ordinary wear-and-tear, which the landlord must absorb, from tenant-caused damage, which can be deducted from the deposit.
What is this topic?
Taiwan's Housing Rental Market Development and Management Act caps the deposit at two months' rent (Article 7) and lists five grounds on which a landlord may end the lease early (Article 10) — four require thirty days' written notice, reclaiming the unit for reconstruction requires three months'.
Mainland China's Housing Rental Regulation (State Council Order No. 812, in force since 15 September 2025) only requires the deposit amount, refund timing and deduction grounds to be written into the contract — it sets no cap at all.
Japan's Civil Code Article 622-2 requires a landlord to refund the *shikikin* (security deposit), minus what the tenant owes, once the lease ends and the unit is returned; Japan additionally has *reikin* — "key money" paid to the landlord, usually non-refundable, that no statute requires or limits — and the Land and House Lease Act's Article 28 requires "just cause" before a landlord may refuse renewal or terminate, so a tenant cannot simply be told to leave.
The United States has no federal rule at all: HUD's role is limited to anti-discrimination under the Fair Housing Act, and deposit caps are set state by state — California's Civil Code §1950.5, as amended by AB 12 (effective July 2024), cut the limit from two or three months to one.
India's Model Tenancy Act, 2021 is only a template for states to adopt — it proposes a two-month cap for residential premises, six for commercial — but most states still run on their own older Rent Control Acts.
Indonesia's rental law still traces to the Dutch-era Civil Code (Articles 1548 onward); the deposit amount is left entirely to contract, and a landlord cannot evict a tenant who refuses to leave without going through court.
Brazil's Tenancy Law caps the deposit at three months' rent, held in a savings account (Article 38), while Article 46 lets a landlord reclaim the unit without cause once a contract of thirty months or longer expires.
Sources and dates
Dates follow local time zones, calendars, and official notices. Check the source when a date is estimated or locally variable.