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Do you know if there is supplementary bonding in the bathroom? If there isn't it would be much easier to change the CU than to add it.And a difficult question to answer, but I won’t hold you to it, if nothing changes, is the Flat likely to fail a EICR on the Consumer Units alone I.e. age and lack of ECB, assuming everything else in the flat is ok?
Assuming it does have the supplementary bonding, and noting it is a a top floor so no sockets are likely to be used outside, it wouldn't have automatic C2's fail for lack of RCD protection according to BPG4. This assumes the installation tests as fault-free in every other regard.
No one should be entertaining a rental property without RCD protection these days though, it's just common sense that you want tenants to have a level of safety that is now commonplace among dwellings.