Why is reform being proposed?
Under the current framework, each category of tourist accommodation must meet defined criteria and is subject to inspection and certification. DfE and Tourism NI aim to modernise these arrangements to reflect market changes , including the growth of short-term lets and newer forms of accommodation.
The consultation proposes four main changes:
- Amendments and modernisation of existing statutory minimum criteria
- Creation of a new statutory category called “Alternative Accommodation”
- Changes to the rules on keeping a Visitors Register
- Changes to requirements for the Display of Charges
Why short-term lets (STLs) matter
STLs serve a wide range of users beyond typical holidaymakers, including people between homes during the buying and selling process and those temporarily relocating for work or study. They offer flexibility and additional income for property owners as well as opportunities for agents to expand services.
Regulation must support high standards without creating unnecessary barriers for responsible agents and landlords.
Our key concerns and recommendations
We agree that most of the proposed criteria will improve quality across the sector. However, we have highlighted some improvements which would strengthen the reforms.
Importantly, we recommend a new statutory category specifically for short-term private rented accommodation. While STLs can fall within the self-catering definition, they have distinct characteristics. They are often former long-term rental properties, are lived in for longer periods than traditional holiday accommodation and are commonly managed by letting agents. A separate category would allow criteria to reflect these differences more accurately.
We also welcome clarification that both proprietors and their agents are responsible for managing self-catering properties. However, we suggest revised wording to make clear that the person identified in the tenancy agreement should be contactable in an emergency.
Clarification is needed on the proposal that properties must have “suitable arrangements” for reception, check-in and check-out. Many STLs use online systems or contractual arrangements, and we have asked for confirmation that signing a tenancy or letting agreement can meet this requirement. We have also recommended that responsibility for linen during a stay should be clearly set out in the contract, with landlords or agents responsible for cleaning between lets.
