Julie Kislev julia1272@hotmail.com

Paying a fine in installments - in which cases is this possible?

July 24, 2023 /

The provisions of tenant law can sometimes be confusing, especially when it comes to modernization measures. However, the Federal Court of Justice (BGH) has clarified that the replacement of smoke detectors does not necessarily constitute a modernization measure that justifies a rent increase. This primarily applies if the renewal does not involve any technical improvement or other upgrading. Even if a landlord has not increased the rent after the initial installation of smoke detectors, this does not give him the right to increase the rent retrospectively.

Landlady replaces old smoke alarms and demands more rent

In a recently decided case, a landlady in Halle replaced old smoke detectors rented by her with new ones and attempted to increase the rent as a result of this measure. She claimed that the replacement of the smoke detectors constituted modernization and invoked Section 559 – Rent increase after modernization measures of the German Civil Code (BGB) to justify a rent increase.

Lower courts affirm rent increase

The rent increase was deemed legally permissible in the lower courts. Both courts, the district court and the regional court in Halle, agreed with the landlord and upheld the claim for payment of the increased rent. In their opinion, the installation of the new smoke detectors fulfilled the requirements of a modernization measure in accordance with Section 555b No. 6 BGB and was therefore a rent-increasing measure.

No rent-increasing modernization

The tenants lodged an appeal against this and the BGH ruled in favor of the tenants. The BGH found that the replacement of the smoke detectors did not meet the requirements for a rent-increasing modernization measure, as they were equivalent devices and therefore did not constitute a technical improvement. The BGH also pointed out that the mere fact that the landlord now installed its own devices instead of the previously rented ones made no difference.

This ruling is an important reminder for landlords and tenants. Modernization measures that can lead to a rent increase should offer added value and represent an improvement on the status quo. Simply replacing old appliances with new, equivalent appliances does not necessarily justify a rent increase.

Image source: AdobeStock 536645680 by Julia

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