Short-term lets consultation: response analysis

Independent analysis of the responses submitted to the short-term lets consultation on a regulatory framework for Scotland.


139. The consultation paper noted that concerns have been expressed about the lack of appropriate safety standards relating to short-term lets. The Advisory Panel recommended there should be parity in health and safety regulation for all short-term let accommodation that is not the owner's primary residence, regardless of the frequency or method of booking of accommodation. Question 11 asked,

Q11: 'Do you have any comments on safety issues related to short-term lets?'

140. A total of 761 respondents commented at this question. The following table provides a breakdown of those who chose to respond.

Table 15: Q11

Affected resident 391
Community organisation 51
Guest 51
Host with 1 property 163
Host with 2+ properties 79
Platform 2
Host intermediary 16
Hotel / B&B owner 10
Local authority 17
Other (non short-term let) landlord 15
Other business 27
Other 87
Total organisations 90
Individuals 671
Total respondents 761

141. There were two common themes to this question. The first, noted by a large minority of respondents across all sub-groups (there were particularly high levels of support from local authorities, other landlords and host intermediaries), was that safety standards short-term lets should be the same as tenancies in the private rented sector the Repairing Standard[10]). While the Repairing Standard is required for any privately rented home, some of these respondents felt it is not necessarily applied by owners of short-term lets; they suggested that all short-term lets should be required to comply with this requirement. Some of these respondents cited tenement blocks specifically where one property which is not protected against fire can impact on all other flats and residents in the tenement. A smaller number of respondents suggested that safety standards should be the same as apply to B&Bs, hotels and guest houses.

142. The second common theme, mentioned by a small minority of respondents across all sub-groups, was that short-term lets should be licensed or regulated with regular inspections to ensure they adhere to all relevant regulations.

143. Another issue cited by a few respondents was a general comment on the need for owners to comply with regulations and that these regulations should be enforced. A similar number of respondents felt that owners are usually safety-conscious.

144. Very small numbers of respondents felt that platforms should have some responsibility in relation to short-term lets, with suggestions that booking platforms could carry out safety checks or insist on these being carried out to enable an owner to use the platform, and / or that booking platforms should have to provide information on health and safety requirements with which owners have to comply.

145. A number of safety issues were highlighted as concerns; each mentioned by a very small number of respondents. These included:

  • Strangers staying in short-term lets and coming and going through common stairwells (primarily in relation to tenements and blocks of flats).
  • The use of key boxes.
  • Overcrowding, with some reference to party flats where large numbers of guests may be staying.
  • A lack of insurance.
  • Fire risks.
  • The need for smoke alarms, carbon monoxide detectors.



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