Short-term letting has spent a decade in a planning grey area. Government policy is to close it, through a mandatory national register and a new planning use class that lets councils decide when a change to short-term letting needs permission. For anyone holding or considering holiday-let stock, the effect is to make the use itself a permission you can be refused rather than a decision you simply take.
Registration and the planning rule
Two separate things, often conflated. The first is a mandatory national registration scheme for short-term lets in England, giving councils data on what is operating in their area.
The second is a planning change. The government has consulted on a new use class for short-term lets, proposed as class C5, with associated permitted development rights. The intended design is that a property can move from residential to short-term let under permitted development, and back again from short-term let to residential. Only the first direction is proposed as removable: a council could switch off the right to convert a home into a short-term let by making an Article 4 direction. The route back to housing is intended to stay unrestricted.
Homeowners letting their own main or sole home are intended to keep flexibility for up to 90 nights a year without needing permission. Do not confuse that proposal with the separate 90 night limit that has applied in Greater London since 2015 under its own legislation. The London rule is already law; the England-wide one is not. Hotels, hostels and B&Bs are outside the scope of both measures.
Where the short-term let rules stand
The register is government policy with a legal basis already in place, but no confirmed start date. Ministers have repeatedly targeted a 2026 go-live, and that date has already slipped more than once. Treat any 2026 date as a target rather than a commitment. The planning use class has been consulted on, and the published material gives no firm date for amending the use classes order.
So the honest summary is: announced policy with an intended design, not yet a set of rules you can look up and comply with. Anyone telling you the use class exists today, or that a register is already mandatory, is ahead of the published position. Equally, anyone assuming it will not happen is ignoring a clear and repeatedly stated government intention.
Note also that this is England. Scotland and Wales have run their own licensing and registration regimes on different timetables, so cross-border comparisons are not a guide to what applies here.
Why planning powers decide it
The critical mechanism is the council’s ability to remove permitted development rights. That is the same tool used for HMOs through Article 4 directions, and the pattern there is instructive: once one council in a pressured area adopts it, neighbours tend to follow.
Where rights are removed, converting a dwelling to short-term letting needs a full planning application that can be refused. In tourist-heavy or housing-pressured areas, refusal becomes a realistic outcome rather than a formality.
That creates the same two-sided effect Article 4 produces for HMOs. New entrants are shut out, and existing lawful operations become scarcer and, in the right location, worth more. The risk sits with anyone buying on the assumption they can convert, and the benefit with whoever already holds an established use.
What this means for property investors
Never buy on an assumed conversion to short-term letting. If the model depends on switching a dwelling to holiday letting, that assumption is exposed to a planning change with no fixed date. Price the property on what it lawfully is today, and treat the conversion as upside rather than the plan.
Establish and document existing use now. If a property is already let short-term, the evidence of that use, its duration and its continuity is what will matter when a new regime arrives. Booking records, accounts and correspondence are worth organising before you need them, not after.
Watch the same councils that moved early on HMOs. The authorities already using Article 4 directions to control HMO conversions are the ones most likely to use the equivalent power here. Our guide to Article 4 directions covers how to check what a council has in force, proposed, or out for consultation, and the same discipline applies.
Remember the register is a data-gathering exercise with consequences. Its immediate purpose is visibility, but visibility is what makes enforcement and targeted planning restrictions practical. Councils that could not previously identify short-term lets will be able to.
Consider whether the yield premium still compensates. Short-term letting carries higher gross yields and higher management, void and now regulatory risk. If a planning restriction could remove the use entirely, the premium needs to be large enough to justify that, and it should be assessed against a conventional letting of the same property.
If you are weighing short-let stock against conventional lettings, the planning position is the first thing to establish. Browse our current listings or join the insider list for deals before they are advertised.