Updated October 2026
CM Law’s Ultimate List Top 50 FAQs on Buying a Residential Investment Property Article 32
When buying a residential investment property in NSW, adequate storage can make a home more practical and appealing to tenants. Built-in wardrobes, kitchen cupboards, garages, garden sheds and storage cages all deserve attention during inspections. However, the space must be usable, safe and legally available to the owner and tenant. Before buying, check what is included in the sale, whether storage rights are documented and what improvements are permitted. Attractive presentation alone does not establish ownership or guarantee higher rent.
1 Understand why storage matters
Storage affects everyday living. Families may need space for prams and sporting equipment, while apartment residents may need somewhere for luggage, bicycles and seasonal belongings. Convenient cupboards can help tenants use living areas comfortably without relying on freestanding furniture or external storage.
Adequate storage may strengthen a property’s appeal, but its effect on rent and vacancy depends on the local market. Assess the likely benefit using comparable local rentals and advice from a property manager. Consider the cost of installation, ongoing repairs and lost floor space. Expensive cabinetry will not necessarily recover its cost through additional rent.
2 Inspect the space rather than relying on photographs
Open cupboards and measure their usable depth, width and height. Check whether doors open properly, shelves are secure and stored items would interfere with ventilation or access. Inspect garages, sheds and basement cages for water staining, dampness, damaged locks and signs of unauthorised use.
Ask how tenants reach external storage and whether access requires a key, lift or stairs. A large cage is less useful if bulky items cannot fit through its entrance. Check whether parking remains practical when the storage is used. Record promised inclusions and ask your solicitor to resolve discrepancies between the advertisement, contract, strata plan and what you actually inspect.
Ask what will remain at settlement. Freestanding shelving or a shed shown during an inspection may be excluded from the sale, while a seller may intend to keep belongings in a garage temporarily. Ensure the contract addresses any agreed removal or continuing access. For a tenanted purchase, review the existing lease as well: the tenant’s current rights may differ from the selling agent’s description.
3 Confirm ownership and access rights
A storage cage near an apartment’s car space does not automatically belong to that apartment. It may form part of the lot, be a separate lot, or sit on common property subject to a by-law or other arrangement. An informal understanding with a neighbour may not provide reliable ongoing rights.
The NSW guide to buying strata property recommends checking the strata plan, by-laws and records before purchase. Ask your solicitor to identify the relevant boundaries, access rights, restrictions and maintenance obligations. Confirm whether any separate storage lot is included in the contract. A number painted on a cage is not a substitute for checking the documents.
4 Distinguish rental obligations from design standards
Under the Residential Tenancies Act 2010, landlords must provide premises fit for habitation and keep them in a reasonable state of repair. NSW’s minimum rental standards address matters including structural soundness, ventilation, water and bathroom facilities. They do not prescribe a general minimum storage volume for every rental home.
A tenant’s preference for more cupboards does not, by itself, establish that the premises are uninhabitable. However, promised storage, defective fixtures or loss of access to an included area can raise separate contractual and repair issues. Existing cupboards and storage facilities should be assessed under the landlord’s repair and maintenance obligations.
For apartment developments to which it applies, the NSW Apartment Design Guide, Objective 4G-1, provides storage design criteria of 4 cubic metres for studios, 6 for one-bedroom apartments, 8 for two-bedroom apartments and 10 for apartments with three or more bedrooms. At least half should be inside the apartment, additional to kitchen, bathroom and bedroom storage.
These are planning design criteria, not an automatic obligation to retrofit every existing rental. Check the development’s approval, applicable planning controls and approved plans before asserting a breach or budgeting for changes.
5 Improve storage with the right approvals
Start with practical options such as adjustable shelving, better cupboard layouts and durable wardrobes. Preserve comfortable movement through rooms. Obtain professional advice before adding overhead racks, using roof spaces or altering structural elements. Storage must not obstruct escape routes or building services.
Under NSW’s strata renovation rules, installing or replacing built-in wardrobes can be cosmetic work where the relevant conditions are met. Kitchen renovations involving cupboards generally require minor-renovation approval. Structural work and waterproofing follow different approval processes. Check the scope and scheme’s by-laws before ordering work.
For design inspiration, Adrian William’s profile of Marrickville joinery studio FAF Woodwork and Design discusses custom wardrobes, cabinetry and built-in furniture. Investors can use those ideas to consider how awkward spaces might become functional, while keeping the budget and likely tenant needs in view.
Ray White’s Three tips for better storage in your residential property explores under-stair cupboards and using vertical space. These are starting points for a design discussion; check structural capacity, safe access and approvals for the particular property. Neither agency article establishes a guaranteed rental premium.
A real NSW case about storage rights
In White v Betalli (2007), a two-lot strata scheme at Gymea Bay included a registered by-law allowing the owners of one lot to store small watercraft on a designated area within the neighbouring owner’s lot. Landscaping reduced that area from approximately 15 square metres to eight and made moving boats more difficult.
The NSW Court of Appeal upheld the by-law by majority and dismissed the appeal. The earlier orders requiring removal of the obstructing works remained in place, and the appellant was ordered to pay the respondents’ appeal costs.
The case was decided under earlier strata legislation. Its practical lesson remains useful: investigate registered rights before assuming you can use or alter an entire area. Here, the storage was within a private lot, and another lot’s owners had enforceable rights over it.
6 Advertise accurately and document what tenants receive
Describe the actual storage available and any restrictions. Specify whether a garage, shed or cage is included in the tenancy and record keys, access devices and condition. Do not advertise private storage when only a shared area is available.
The NSW property advertising guidelines require accurate representations. Photographs should not conceal defects or imply that excluded areas are included. Keep copies of the listing, agreed inclusions and condition report so any later disagreement can be assessed against clear records.
What verified statistics tell us
The Australian Institute of Health and Welfare’s National Social Housing Survey 2025, published in May 2026, reported that 70% of public housing tenants nationally had their indoor storage needs met, while 62% had their outdoor storage needs met. Storage was among the least well-met amenities in that group.
These are national social housing findings, not NSW private rental statistics or evidence of higher returns. Separately, the ABS 2021 NSW Census results recorded 32.6% of occupied private dwellings as rented and 21.7% as flats or apartments. Those figures describe housing conditions in 2021; they do not measure the financial benefit of storage.
7 Address requests and disputes promptly
Tenants generally need authority in the lease or written permission before making alterations. Landlords cannot unreasonably refuse minor changes; the NSW alterations guidance explains the requirements and exceptions. Separate strata approvals may also be necessary.
Respond to storage complaints in writing and investigate the agreed inclusions, condition and access. NCAT hears NSW tenancy disputes, but the available remedy depends on the legal basis, evidence and applicable limits. A complaint about insufficient space does not automatically entitle a tenant to compensation.
Contact CM Lawyers before purchasing an investment property if storage ownership, strata permissions or contract inclusions are unclear. Early review can help you understand what you are buying and what you can confidently offer tenants.
Key resources
- NSW minimum rental standards and repair obligations — Habitability and maintenance duties.
- Apartment Design Guide Part 4 — Objective 4G-1 storage criteria, printed page 101.
- Buying a strata property and strata renovation rules — Ownership checks and approvals.
- White v Betalli (2007) — NSW Court of Appeal decision about registered watercraft storage rights.
- AIHW National Social Housing Survey 2025 — Storage needs, published May 2026.
- ABS NSW Census QuickStats 2021 — Rental tenure and dwelling structure figures.
- Adrian William on FAF Woodwork and Design — Marrickville joinery and fitted storage.
- Ray White storage tips — Practical storage design ideas.
- Property advertising guidelines, rental alterations and NCAT tenancy disputes — Marketing, changes and dispute pathways.
