British Destinations

Consultation on a registration scheme for short-term lets in England

Posted on April 13, 2023 Updated on April 13, 2023

The DCMS consultation on the next stages of an accommodation registration scheme in England was issued last night alongside a parallel DLUHC consultation on a potential change to the planning use class for short-term lets in England. Closing on 7 June, both have great significance for tourism and the visitor economy.  I would urge anyone with an interest in the outcome for local and national tourism to address them both and to do so mindful of the impact that each has on the other.

First thing to say is that no one should underestimate the likely level of difficulty faced by Minister and officials in getting proposals to introduce any new or additional “regulation” to this point given the current administrations natural leaning towards small government, minimal regulation and a free market approach.  DCMS have done well and should be congratulated on their tenacity to date and now given every reasonable assistance to help get the best possible scheme available in the circumstances over the line.  That should not preclude us being constructively critical where it is justified, or stop us from proposing necessary changes to the scope of what is on the table, particularly where it might avoid entirely predictable failings or adds major gains, for marginal penalties.  

When you read the proposals and the associated questions, I know from several years of debating this subject that there will be considerable disappointment and associated concerns for many destination managers. For example, the consultation is explicitly about a registration scheme for short-terms lets only. Thus, arguably it misses the opportunity to genuinely level the playing field (not all those operating in the traditional accommodation sectors are saints) and potentially opens up loopholes at the occasional letting end of short-term let market and especially, some major loopholes in the grey, ill-defined areas between short-term lets, B&Bs, guesthouses and smaller hotels.  An area that we are only to aware that is already becoming increasingly muddied by the advent of new technology, new practices new routes to market and the blurring of lines between serviced and non-serviced provision.

The options given within and between the 24 questions posed are wide ranging and ask for views on a scheme that could be entirely self-assed with very few checks and balances or far more ordered and methodical.  We are also asked view on things like what might constitute a breach of the rules and what the penalties for such breaches might look like. Other radical options include a scheme that might only be adopted by individual local authorities, if they so wished, to one that is mandated nationally. In their totality the overall scope of the options given are somewhat more limited than perhaps many of us might have wished?  However, in combination within the parameters given, they still allow room for a number of potentially very different outcomes. You will only get a proper sense  of this once you have read and digested the full document (s) (sorry no shortcuts on this one).

At this early stage I already think it is vital that as many destination management organisations and their stakeholder as possible respond to both consultations. However, other than starting to considering how that might be done by whom and by when, I also think we all need to pause take stock, find time to read both consultations and probably do that more than once. Then perhaps we can consider sharing initial thoughts over the next few days and weeks with a view to developing some shared thoughts for inclusion in any individual and joint responses we feel the need to submit.

The DCMS consultation which includes within it a link to the DLUHC consultation is at:

https://www.gov.uk/government/consultations/consultation-on-a-registration-scheme-for-short-term-lets-in-england/consultation-on-a-registration-scheme-for-short-term-lets-in-england#consultation-on-the-registration-scheme

The DHLUC consultation itself is at:

https://www.gov.uk/government/consultations/introduction-of-a-use-class-for-short-term-lets-and-associated-permitted-development-rights