Almost every deposit dispute is an argument about what a room looked like before someone moved in. One side remembers a mark on the wall. The other remembers a clean wall. Neither has anything better than memory, and memory loses.

The inventory is the baseline that makes the argument testable. It has to exist before the argument, which is the part that makes it easy to deprioritise. Nobody has ever regretted a thorough check-in at the moment they were doing it. They regret it fourteen months later.

This guide covers how to produce an inventory that works, what to capture at check-in, and how to run the process so the document holds up. For what applies to your particular contract, go to the Welsh Government's guidance for landlords.

The Welsh Position

Wales handles inventories differently from England, and the difference is structural rather than cosmetic.

Regulation 27 of the Renting Homes (Supplementary Provisions) (Wales) Regulations 2022 sets out an inventory provision that is incorporated into occupation contracts as a supplementary term. It sits in Part 6 of the Regulations, which applies to standard contracts other than introductory standard contracts, prohibited conduct standard contracts and supported standard contracts so check which category yours falls into before assuming it applies.

Where it does apply, the provision says:

• The landlord must provide the inventory no later than the date by which the written statement of the occupation contract must be provided under section 31 of the Act

• The inventory must set out the dwelling's contents, including all fixtures and fittings, and must describe their condition as at the occupation date

• If the contract-holder disagrees with the information in it, they may provide comments

• Where no comments are received within 14 days, the inventory is deemed to be accurate

• Where comments are received within 14 days, the landlord must either amend the inventory and send the amended version, or inform the contract-holder the comments are not agreed and re-send the original with the comments attached, or amend it in part and send it with a record of the comments not agreed

Four things follow.

1. Describing condition is part of the provision, not an optional refinement. An inventory that lists items without describing their state does not do what regulation 27(2) describes.

2. The condition described is condition at the occupation date. Not the date you got round to writing it up.

3. There is already a comment period, and silence has a consequence. You do not need to invent your own window.

4. Receiving comments creates work. You cannot simply note them and move on. Each of the three permitted responses involves sending something back, which means the process has a second step most landlords never build into their workflow.

Note also that supplementary terms can be modified or omitted by agreement at the creation of the contract, provided that does not render the contract incompatible with a fundamental term. So the position is not identical for every contract, and yours is the document that tells you.

What an Inventory Is For

• It records contents:
  The fixtures and fittings, and any furnishings. Welsh Government notes that if a property is unfurnished the inventory would reflect that and may refer only to fixtures. Shorter, not absent.

• It records condition:
  The state of those things at the occupation date, in enough detail that changes are demonstrable rather than arguable.

The contents function gets used when something goes missing. The condition function is what gets used in disputes, and it's the one people skimp on.

Producing One That Holds Up

Room by room, in a fixed order. Same order every time, every property. It makes gaps visible and it makes two inventories comparable.

Describe, don't grade. "Good condition" means nothing eighteen months later, and it isn't a description of condition in any useful sense. "Magnolia emulsion, two small scuffs left of window, approximately 2cm" is. If you find yourself writing "fair" or "acceptable," replace it with what you're actually looking at.

Photograph properly. Wide shot of each room first for context, then close-ups of anything specific. A close-up with no wide shot leaves you unable to prove which room it was. Date the photographs and keep the originals a copy pasted into a document usually loses the metadata that makes it useful.

Capture the things nobody photographs. Inside cupboards and the oven. Behind doors. Window frames and sills, which is where condensation damage starts. Carpet edges and thresholds. Under sinks. The seals around baths and showers. These generate disputes precisely because nobody documented them.

Record meter readings and serial numbers. Five minutes, and it resolves a category of dispute entirely.

Note what's missing or already broken. A cupboard door that doesn't close, a cracked tile, a light fitting with no bulb. Recording an existing defect protects both sides, and it starts the clock on whether it needs attention.

Say who prepared it and when. Name, role and date on the document itself.

The Check-In Itself

The document is only half of it. The process is what makes it evidence rather than an assertion.

Do it with the contract-holder present if you can. Walking through together turns the inventory from something you wrote into something you both saw, and it surfaces disagreements immediately, when they cost nothing.

Prove they received it. A signature, an email reply, a portal confirmation. This matters more in Wales than elsewhere, because the comment period runs from receipt and silence has consequences. An inventory you can't show was delivered is one whose deeming provision you'd struggle to rely on.

Say plainly that they can comment. Not buried in a covering note. A contract-holder who spots something you missed in the first fortnight should know they can tell you, and it should be easy. Something reported at the start is documented before it can later become the subject of a check-out dispute.

Build the response step into your process. If comments arrive, something has to go back — amended inventory, or the original re-sent with the comments attached, or a partial amendment with a record of what wasn't agreed. Log the comments the day they arrive, and log what you sent back.

Do the practical handover at the same time. Where the stopcock is, how the heating works, which bin day, where the fuse board sits, what to do about a leak and who to call. Half the emergency call-outs in a first month are someone not knowing where something is.

File it where the property lives, not in a folder of inventories. Kept alongside the contract and the maintenance history, it's findable when someone asks.

Check-Out, and Why It Depends on Check-In

A check-out is a comparison. Without a baseline it's just a second opinion.

Use the same document and the same order. Walk the check-out against the inventory, item by item, rather than writing a fresh description.

Distinguish wear from damage in your notes. The Regulations provide that a contract-holder is not liable for fair wear and tear to the dwelling or to fixtures and fittings, while requiring them to take proper care of the dwelling and of items listed in any inventory. Where a particular mark falls between those is a judgement for the deposit scheme's process and the terms of the contract, not for your check-out note but "carpet worn in doorway, consistent with three years' use" is a far more useful note than "carpet damaged."

Photograph the same angles. Matching wide shots make change obvious in a way two unrelated photographs never will.

Note anything reported and fixed during the contract. A repaired wall looks different from an undamaged one. If your [repair records](INTERNAL LINK: repair handling article add slug) show it was reported, attended and resolved, that explains the difference before anyone has to ask.

Conclusion

The inventory is the only document in residential letting whose entire value is realised at a future point, by someone who may not be you. Which is why it gets rushed. The person writing it has no immediate use for it, the contract-holder wants the keys, and thirty minutes photographing cupboard interiors feels disproportionate on a Tuesday afternoon.

It isn't. It's the baseline every later argument gets measured against, it describes a condition at a fixed date that cannot be recreated afterwards, and where the provision applies it sits inside the contract rather than beside it.

Frequently Asked Questions

1. What must a Welsh inventory contain?
Where regulation 27 applies, the inventory must set out the dwelling's contents including all fixtures and fittings, and describe their condition as at the occupation date.

2. Which contracts does the inventory provision apply to?
It sits in Part 6 of the Regulations, covering standard contracts other than introductory standard contracts, prohibited conduct standard contracts and supported standard contracts. Check your contract type.

3. When must it be provided?
No later than the date by which the written statement of the occupation contract must be provided under section 31 of the Act.

4. What happens if the contract-holder doesn't respond?
Where no comments are received within 14 days, the inventory is deemed to be accurate. That makes proving delivery important.

5. What if they do comment?
The landlord must amend and send the amended inventory, or inform the contract-holder the comments are not agreed and re-send the original with the comments attached, or amend in part and send a record of the comments not agreed.

Important Notice

This article applies to Wales only. Housing law is devolved, and Wales operates under the Renting Homes (Wales) Act 2016, using occupation contracts and contract-holders rather than tenancies and tenants. Guidance written for England does not apply here.

The inventory provision described above is regulation 27 of the Renting Homes (Supplementary Provisions) (Wales) Regulations 2022. It applies to standard contracts other than introductory standard contracts, prohibited conduct standard contracts and supported standard contracts. Supported standard contracts are dealt with by separate regulations. Supplementary provisions may also be modified or omitted by agreement at the creation of a contract, provided that does not render the contract incompatible with a fundamental term. Which provisions apply to your contract, and in what form, depends on that contract.

Beyond the provisions described, nothing in this guide states how wear and damage should be assessed, which depends on your contract and the relevant deposit scheme's process. Confirm your position using Welsh Government guidance and take advice where it matters.

This content is general information only and does not constitute legal advice. RIOO is not a law firm.