Position Paper on the European Commission’s Proposal on Short-Term Rentals

In November, we welcomed the European Commission’s proposal on data collection and sharing relating to short-term accommodation rental services as a great step forward in ensuring greater transparency and clarity in this growing market.

Today, we detail our position and view on the proposal further by sharing initial high-level recommendations on the areas for improvement and clarification of the draft text.

While recognising the proposal’s balanced approach with regard to the different roles and responsibilities of hosts, platforms and public authorities, we also note that the proposal falls short of providing any clarity regarding the proportionality and compliance with EU law of local market access rules. In this regard, we recommend adding clarifications in the current text or ensuring that further guidance is provided as soon as possible following the adoption and implementation of the STR framework.

In addition, we encourage negotiators to:

• Consider the merits of an EU-wide registration scheme and central digital infrastructure to ensure greater simplification and make the rules more easily operational;
• If the intention is to keep the current approach of national registries and Single Digital Entry Points, provide guidance including by means of secondary acts to ensure a standardised approach to this digital infrastructure in a dialogue with online platforms;
• Clarify the definition of STRs to avoid fragmentation;
• Ensure the STR regulation becomes the main instrument for B2G data sharing on STRs, in compliance with the GDPR; and
• Ensure a swift implementation of the rules, including by considering bringing the implementation timelines of the DSA and of the STR proposal closer together.

We look forward to engaging with all relevant stakeholders in the coming weeks and months to help make the rules truly operational.