COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on data collection and sharing relating to short-term accommodation rental services and amending Regulation (EU) 2018/1724
Date: 2022-11-07
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: Internet, data collection, digital single market, exchange of information, hiring, information system, property leasing, provision of services, tourism

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   EUROPEAN COMMISSION  Brussels, 7.11.2022  SWD(2022) 349 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on data collection and sharing relating to short-term accommodation rental services and amending Regulation (EU) 2018/1724 {COM(2022) 571 final} - {SEC(2022) 393 final} - {SWD(2022) 348 final} - {SWD(2022) 350 final}  
 
 
Executive Summary Sheet 

Impact  assessment  on  the  proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  on  data 
collection  and  sharing  relating  to  short-term  accommodation  rental  services  and  amending  Regulation  (EU) 
2018/1724 

What is the problem and why is it a problem at EU level? 

A. Need for action 

Short-term  accommodation  rentals  (STRs)  are  an  increasingly  important  part  of  the  tourism  sector.  They 
represent nearly one quarter of the total EU supply of tourist accommodation, and this has been boosted by the 
emergence  of  online  platforms.  STRs  create  benefits  and  opportunities  for  guests,  hosts,  and  the  tourism 
ecosystem, but they are also a source of concern, notably for local communities dealing with overtourism and a 
lack of affordable housing. Public authorities increasingly regulate STRs, at national, regional or local level, but a 
lack of precise data on STRs makes it difficult for them to define policy responses and enforce rules. At the same 
time, online platforms of all sizes are increasingly confronted with numerous and diverging requests from public 
authorities to share data on STRs and introduce more transparency (e.g. by displaying certain information). This 
imposes  a  heavy  burden  on  platforms,  which  often  refuse  to  comply  with  data  requests  or  submit  only 
incomplete  data  sets.  Difficulties  in  data  sharing  are  due  to:  i)  inefficient  and  diverging  registration  schemes 
managed by public authorities (which therefore cannot efficiently obtain identification data for hosts and listings); 
ii) a lack of  effective and enforceable  legal frameworks, standards  and tools for sharing data among  platforms 
and  public  authorities;  and  iii)  the  lack  of  a  proper  legal  framework  governing  transparency  and  data  sharing. 
The identified problems have a strong EU dimension. For platforms, which usually operate across borders, the 
divergence  and  complexity  of  rules  and  data  requests  undermines  their  ability  to  offer  services  in  the  single 
market. Throughout the EU, public authorities that need STR data face similar difficulties in efficiently obtaining 
quality data. There are therefore strong calls for EU action, notably in the transition pathway for tourism and the 
urban agenda. This initiative is part of the EU’s SME strategy - given the need of the many SME players in the 
STR segment, including platforms, for solutions. 
What should be achieved?  

This  initiative  should  enhance  transparency  in  the  STR  segment,  which  is  necessary  in  order  to  promote  a 
balanced  tourism  ecosystem.  Specifically,  the  initiative  aims  to  reduce  burdens  on  online  platforms  caused  by 
fragmented  and  complex  data-sharing  and  transparency  requirements.  It  also  aims  to  ensure  that  public 
authorities have the data they need to design and enforce appropriate STR policies.  

What is the added value of action at EU level (subsidiarity)? 

Action  at  EU  level  is  needed  in  order  to  overcome  the  problems  related  to  fragmented,  burdensome  and 
inefficient  efforts  to  generate  and  share  STR  data.  Online  platforms  need  an  EU-level  framework  for  data  in 
order  to  be  able  to  prosper  in  the  single  market  and  to  be  sure  that  they  comply  with  EU  regulations  when 
dealing  with  data-sharing  requests.  Public  authorities  across  the  EU  also  need  a  clear  EU-level  framework  in 
order  to  be  able  to  obtain  the  data  they  need  (national  solutions  have  often  proven  to  be  inefficient).  The  EU 
framework  would  not  affect  the  authorities’  ability  to  manage  STRs  in  their  locality  as  they  see  fit  -  or  their 
competences in areas such as urban planning and health.  

B. Solutions 

What are the various options to achieve the objectives? Is there a preferred option or not? If not, why? 
In  addition  to  the  baseline  which  entails  a  ‘no  policy  change’  approach,  the  initiative  identifies  three  policy 
options. Option 1 proposes soft measures to promote data generation and data sharing. Option 2 consists of an 
EU legislative framework containing a common approach to data generation and data sharing. It requires public 
authorities  that  want  data  on  STRs  to  manage  registration  systems  for  hosts  (involving  the  grant  of  a  unique 
registration number per listing). Such registration systems can be managed at national, regional  or local level, 
but need to be consistent with an EU template (which contains some procedural and substantive requirements). 
Public  authorities  must  also  provide  for  a  Single  Digital  Entry  Point  that  offers  information  that  platforms  and 
hosts  need,  and  allows  hosts  to  complete  formalities  online.  Platforms  will  be  required  to  allow  the  display  of 
registration  numbers  and  to  share  (via  a  Single  Digital  Entry  Point)  a  closed  set  of  activity  data  with  public 
authorities that have registration schemes. Small and micro platforms with a limited activity will benefit from more 
lenient data-sharing requirements. Option 3 consists of the same measures as option 2, but is broader in scope 
and intensity, because it would require the creation of national registration schemes to ensure the registration of 
all hosts across the EU. Option 2 is the preferred option, because it would ensure transparency and data sharing 

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on STR activity by platforms in an effective manner, but allow regional/local  authorities to decide whether they 
need data and what kind of data they can obtain when requiring hosts to register (identification of the hosts and 
the unit). 
What are different stakeholders' views? Who supports which option? 
All  stakeholders,  including  residents  associations,  have  confirmed  their  broad  support  for  a  more  harmonised 
data-sharing  framework  between  public  authorities  and  online  platforms,  and  for more  harmonised  registration 
schemes  across  the  EU.  4875  of  5695  total  respondents  (85.6%)  in  the  public  consultation  believe  that  such 
tools should be put in place and/or facilitated at EU level. Public authorities and online platforms have stressed 
the  limited  ability  of  soft  approaches  to  achieve  transparency  and  improve  data-sharing  processes.  Public 
authorities,  online  platforms  and  hosts  agree  on  the  measures  under  options  2  and  3.  Public  authorities  and 
hosts  support  option  2,  because  it  leaves  discretion  to  public  authorities  and  reduces  the  impact  of  the 
registration  obligation  on  hosts.  Online  platforms  prefer  option  3,  because  it  would  harmonise  the  registration 
obligation across the EU and would make it easier to display registration numbers and share data (which applies 
to  all  hosts  across  the  EU  and  not  just  in  selected  areas).  NGOs,  residents  associations,  and  other  services 
providers such as hotels prefer the maximum degree of transparency and data sharing from platforms. 

C. Impacts of the preferred option 

What are the benefits of the preferred option (if any, otherwise main ones)? 

Online  platforms  will  benefit  economically  from  cost  savings  related  to  the  replacement  of  uncoordinated  data 
requests with a much more streamlined approach, because this will reduce compliance costs and increase legal 
certainty. It is estimated that savings for online platforms over a period of 5 years will amount to between EUR 
54 and EUR 115 million. Public authorities will also benefit from more legal certainty and cost savings (once the 
new system is in place, there  will be a regular  inflow of data from platforms at a very low cost for authorities). 
Hosts  will  benefit  from  more  user-friendly  and  less  burdensome  registration  schemes.  Based  on  moderate 
estimations,  it  could  be  possible  to  save  more  than  EUR  1480  million  (monetisation  of  time  saved  in  the 
registration process) for the new hosts that will be starting their activities (hence need to register in those areas) 
in the first 5 years after implementation. There will also be other indirect economic benefits for a wider group of 
players  (e.g.  hotels  will  benefit  from  less  unfair  competition,  because  public  authorities  will  be  better  able  to 
regulate and enforce STR rules). The social and environmental benefits will come mainly from public authorities’ 
increased capacity to manage tourism and the effects of STRs on local communities, the environment and the 
wider tourist ecosystem. This initiative will also enhance the protection of personal data. 
What are the costs of the preferred option (if any, otherwise main ones)? 

The  costs for  online  platforms  will  mainly  be  the  one-off  administrative  costs  of adapting  their  IT  infrastructure 
and connecting to the Single Digital Entry Point (these are estimated at around EUR 30 000 per online platform), 
while  annual  maintenance  costs  are  estimated  at  EUR  36 000.  Under  these  hypotheses,  the  total  one-off 
administrative  costs  are  estimated  at  around  EUR  8.2  million,  while  annual  maintenance  over  a  period  of  five 
years  will  amount  to  a  total  of  EUR  10  million.  For  small  and  micro-enterprises  that  would  qualify  for  the  less 
stringent reporting obligations, the costs are estimated at EUR 2 400 a year. These costs are likely to be offset 
by the savings gained from reducing the time spent processing uncoordinated and varied data-sharing requests 
and  challenging  them  in  court.  Public  authorities  implementing  the  framework  will  incur  one-off  administrative 
costs (estimated at EUR 3 million) to adapt to the new registration system and the Single Digital Entry Point. The 
annual costs of hosting and maintaining the IT infrastructure are estimated at EUR 96 000 per Member State, for 
a total cost of EUR 2.4 million. Where the framework is implemented at regional or local level, the costs for the 
registration system and links to the national  Single Digital Entry Point will be borne by the relevant authorities. 
Based  on our estimations,  it is possible to foresee a  cumulative  one-off cost for  regional  or  local authorities of 
around EUR 3.6 million and a cumulative annual cost for hosting and maintenance at around EUR 4.3 million. 
What are the impacts on SMEs and competitiveness? 

The STR segment and the tourism ecosystem should become more competitive. This will benefit hosts and other 
services providers. Online platforms, which are mostly SMEs, and hosts will directly benefit from a streamlined 
and automated EU framework for data sharing. Small and micro online platforms will directly benefit from a less 
stringent  data-sharing  system.  Other  tourism  players  will  indirectly  benefit  from  greater  transparency  and 
predictability.  All  parties  will  be  able  to better  allocate resources,  improve processes, scale  up  or expand,  and 
innovate (e.g. establish new services). 
Will there be significant impacts on national budgets and administrations? 
The administrative , hosting and maintenance costs for public authorities are presented above. These short-term 
costs  are  expected  to  be  offset  by  the  long-term  benefits  that  the  framework  will  bring  to  public  authorities  in 

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terms of time and efficiency gains (facilitated collection of data and enforcement). 
Will there be other significant impacts? 
No other significant impacts have been identified. 

Proportionality? 
The measures address the objectives proportionately. Options which create disproportionate burdens and costs 
have been disregarded. 

D. Follow up 

When will the policy be reviewed? 
The  Regulation  will  be  reviewed  through  an  evaluation  5  years  after  it  becomes  effective  (there  will  be  a 
transition period of 2 years as from the date of adoption). 

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