The proposed Short Term Rental Registration Register and a new use class for the short term rental sector

Governments across Europe have started to clamp down on short term rentals (STRs), and England is no exception. The regulatory environment for STRs is set for major reform, aimed at addressing community concerns such as noise, housing shortages, affordability pressures, and the need to create a “level playing field” with hotels and B&Bs in respect of safety, regulation, and planning.

The Short Term Rental Registration Register (the Register) was first proposed in April 2023 by then Secretary of State Michael Gove through the Levelling-up and Regeneration Act 2023 (the 2023 Act), claiming it would balance the interests of tourists, homeowners, and residents and provide local councils with a clearer picture of STR activity and its impact on local housing markets.

Whilst the Renters’ Rights Act 2025 (RRA) introduced the Private Sector Rented Database (the Database), a database for the private rented sector (generally, to capture dwellings let under assured shorthold tenancies), the Act specifically reserves the right for Government to include any dwellings let under licences (such as those rented through the STR sector) in the database. Although it is expected that the Database will go live in April 2026, in September 2025, Prime Minister Sir Keir Starmer confirmed that the Register (for STRs) remains on the Government’s agenda, with an intended “go live” date of April 2026. It is highly unlikely that the Register will be launched by this date; however, it is more a question of ‘when’, not ‘if’, the Register will be launched.

While the core principles are clear, many operational details are still under review. The Register forms the first step in regulating STRs under the 2023 Act and the RRA.

What might fall within the Register’s scope?

The Register would introduce a national register for all short-term let properties, defined in the 2023 Act as “a dwelling or part of a dwelling provided for use by a guest as accommodation (other than the guest’s only or principal residence), in return for payment and in the course of a trade or business”.

Under current proposals, operators may need to submit:

• Proof of compliance with safety regulations (e.g. fire, gas, electrical).
• Details of annual occupancy (nights let per year).
• Confirmation of planning permission and use class.

Although the Government originally intended to issue detailed guidance by the end of 2024, this is still awaited. Options under consideration include:

1. Whether registration applies per property, per owner, or per premises.
2. Whether online travel agencies (OTAs) should be restricted to listing only registered units.
3. Whether registration fees should be fixed or scaled based on portfolio size.
4. Whether registration is one-off or renewable periodically.
5. Enforcement mechanisms remain unclear but could include fines and removal of unregistered listings from OTA platforms.
6. Whether registration should be one-off or periodically renewed.

A key point of confusion within Government concerns categorisation. A second home rented occasionally as a “holiday let” would technically fall within the same definition as professionally managed STR units. The blurring of categories may cause uncertainty for casual hosts.

The Register will not affect individuals renting out their primary residence for fewer than 90 nights a year, hotels and hostels operating under planning use class C1, or traditional B&Bs.

The effects of the Register

The proposed Register presents both opportunities and challenges for operators and owners:

Potential upsides:

1. Reduced competition: stricter registration may deter casual hosts or non-compliant operators, giving established, compliant STR businesses a competitive edge.
2. Increased property value: compliant properties could see a rise in value, as regulatory hurdles reduce the pool of eligible STR units.

Downsides:

1. Planning exposure: registration will draw attention to properties lacking the appropriate planning use class, bringing them under local authority scrutiny. This issue is particularly salient in areas where housing is considered to be in short supply.
2. Rising rents and owner expectations: owners of compliant properties may demand higher rents or management fees, increasing operator costs. STR operators will need to decide whether to absorb or pass on these costs to guests.
3. Portfolio growth constraints: tighter rules may restrict access to suitable properties, slowing expansion for professional operators compared to today’s relatively unregulated environment.
4. Landlord consent issues: where an STR operator leases or manages a property, seeking planning permission changes may require landlord consent. Landlords may have discretion to refuse such changes, particularly if they trigger a shift from council tax to business rates.

Mandatory licensing, new C7 use class, and taxes

The Prime Minister has hinted that after the Register is launched, the sector can expect additional reforms beyond registration, potentially including mandatory licensing, extra taxes, and tighter integration with planning controls. The details remain uncertain but could have significant cost implications for professional operators, especially those locked into long-term leases or management agreements.

For instance, councils already have powers to levy a council tax premium on second homes of up to 100%, discouraging speculative ownership that reduces permanent housing supply.

The Government has also announced broader planning reforms running parallel to the Register. The 2023 Act discussed the proposed introduction of a new “C5” use class for short-term lets (covering properties not used as a host’s main home) and possibly removing permitted development rights that currently allow conversion between residential and short-term use without planning approval. However, the last version of the Renters’ Rights Bill from the House of Lords suggested inclusion of a new planning use class for STRs, use class C7. The House of Lords also proposed to restrict converting a dwelling let as an assured tenancy within the last three years into an STR without a change-of-use to use class C7.

Preparing for the Register

A 2023 Government consultation found that 61% of respondents supported a mandatory registration system. Despite the target launch of April 2026, no detailed implementation guidance has yet been released. In the interim, a voluntary register could serve as a valuable testing ground and allow responsible operators to demonstrate compliance readiness.

While a national register may appear modest, it represents a foundational step toward broader oversight of the STR sector. Professional operators should begin preparing now, focusing on data transparency, compliance, and financial resilience.

1. Strengthen data management: professional STR operators that invest early in compliance systems, maintain accurate property records, and build cooperative relationships with local authorities will be best positioned to thrive under the new regime.
2. Standardise compliance: future enforcement is likely to prioritise safety and record-keeping. Operators should ensure they carry out fire, life, and safety assessments required by legislation, maintain evidence of appropriate insurance (including public liability), and keep documentation of planning use and lawful operation.
3. Reassess financial models: operators should model different scenarios, including potential licensing fees, inspection costs, or night caps, to understand future profitability and resilience.

The Register marks a major shift in the Government’s approach to regulating STRs. While it aims to improve transparency, safety, and community balance, it also introduces new administrative and financial burdens for operators.

A national register may be only the first step, but it signals a long-term regulatory direction: greater accountability, tighter planning control, and professionalisation of the STR sector. Operators who anticipate these changes, rather than react to them, will be far better prepared for the future landscape of short-term letting in England.

If you have questions or concerns about STRs, please contact Nadia Milligan.