Your views needed - how the register of short-term lets should work
We’re drafting a response to the Government’s new consultation on a register of short-term lets, which would affect properties on platforms like AirBNB - and we’d like your views!
We’re asking for feedback to find out if there are potential data use cases, or design challenges, that we’ve missed. Please make any suggestions by commenting on the draft response, or mailing contact@centreforpublicdata.org.
About the consultation
Over the past decade, AirBNB and its competitors have grown rapidly in the UK - and so have concerns about AirBNB’s impact on local communities and housing availability. So the Government is consulting on introducing a register for short-term lettings (alongside a separate consultation on a planning use class for short-term lets).
About our response
We agree that a register of short-term lets is essential, which is why we supported it in our earlier response (pdf) to DCMS’s call for evidence on the sector.
We support registers not only because they could help make short-term renting safer - but also because they could be essential data infrastructure for the whole rental sector. The data generated by a short-term lets register could:
give policymakers, researchers and stakeholders much better visibility over an opaque sector, supporting better policy
provide a technical infrastructure for meaningful regulation
provide useful data to support tax compliance, among other things.
Registers are supported by everyone from AirBNB itself, to campaigners like Generation Rent and Action on Short-Term Lets. However, there’s less consensus about what ‘a register’ actually means.
And the detail matters. It’s the difference between a token change that mainly helps the platforms, and meaningful data infrastructure to support local communities.
Our views
We’re concerned that at the moment, the technical design proposed for the register won’t really help local communities address concerns about AirBNB.
Firstly, it won’t provide reliable information about how often properties are actually rented - which means it won’t help enforce any restrictions that communities create:
Most importantly, the consultation lacks any mention of a requirement on platforms to share data about lettings activity. The lesson from other countries that authorities need reliable data on how often properties are actually rented - so it’s strange that it’s missing from the UK’s consultation. (The EU is working on legislation for mandatory data sharing, having found voluntary data-sharing arrangements to be ineffective. And here, London has reported that its 90-day limit on short-term lettings is effectively unenforceable without data sharing - as it stands, the register won’t help with this or any future local restrictions.)
Secondly, it places all responsibilities on owners, none on platforms - even though it would be far more effective to give platforms some responsibility for ensuring that listings are registered too, rather than relying on ad hoc penalisation of landlords:
We also highlight the lack of responsibilities and penalties for platforms. The consultation asks what penalties owners should face, but not platforms. Again, it’s odd that this isn’t mentioned - platforms should take some responsibility too. We suggest that platforms should be required to include a valid registration number on all listings (i.e. be penalised for listing unregistered properties), and to supply data as above, and be penalised if they don’t.
And finally, it simply misses some opportunities to use the data that it will generate:
We suggest that DCMS should think more about the broader value of the data from the register. Non-sensitive information from the register should be published online, as it is in other countries, so that guests can check their property is safe. And NI/company numbers should be collected by the register, so that it can be joined to other datasets to support e.g. identification of rogue landlords, broader analysis of housing supply, and tax compliance.
Over to you
Our draft response covers these points, plus a bunch more detail. We leave bigger questions like licensing design to the experts, but we think it’s important that the technical design supports flexible policy in future, including in places like London that have already tried to introduce local restrictions.
We’d love to hear from you where we’re wrong or where we’ve missed a trick! Please make any suggestions by leaving a comment on the document itself, or by getting in touch at contact@centreforpublicdata.org.
The deadline is 7th June, so we’d appreciate any thoughts before then - and we’d also encourage anyone interested to submit their own response.