COMMISSION STAFF WORKING DOCUMENT 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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.11.2022  SWD(2022) 350 final  COMMISSION STAFF WORKING DOCUMENT  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) 349 final}  
 
 
Contents 

1. 

2. 

INTRODUCTION: ECONOMIC, POLITICAL AND LEGAL CONTEXT ........................................ 3 

PROBLEM DEFINITION ..................................................................................................................... 7 

3.  WHY SHOULD THE EU ACT? ......................................................................................................... 17 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................ 19 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 20 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................ 29 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................. 49 

8. 

PREFERRED OPTION ....................................................................................................................... 52 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 53 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................. 55 

ANNEX 2: STAKEHOLDER CONSULTATION ....................................................................................... 67 

ANNEX  2A:  RESULTS  OF  THE  ADDITIONAL  TARGETED  SURVEY  TO  PUBLIC 

AUTHORITIES ................................................................................................................................... 87 

ANNEX 2B: RESULTS OF THE ADDITIONAL TARGETED SURVEY TO PLATFORMS ................ 102 

ANNEX 3: WHO IS AFFECTED AND HOW? ......................................................................................... 124 

ANNEX 4: ANALYTICAL METHODS & SME TEST ............................................................................ 129 

ANNEX 5: DESCRIPTION OF THE SECTOR ..................................................................................... 157 

ANNEX 6: LIST OF EXISTING AND PLANNED INSTRUMENTS ...................................................... 183 

ANNEX 7: EXAMPLES OF LITIGATION ............................................................................................... 197 

ANNEX  8:  OVERVIEW  OF  REGISTRATION  PROCEDURES  AND  REQUIREMENTS  ON 

PLATFORMS CONCERNING STR IN EU MEMBER STATES ................................................... 200 

ANNEX 9: LITERATURE REVIEW ......................................................................................................... 206 

1 

 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

B&B 

B2G 

CJEU 

CoC 

DAC7 

DSA 

DMA 

EU 

GDPR 

IA 

IIA 

TFEU 

SDG 

STR 

SME 

Bed and Breakfast accommodation 

Business to Government 

Court of Justice of the European Union 

Code of Conduct 

7th Directive on the Administrative Cooperation 

Digital Services Act 

Digital Markets Act 

European Union 

General Data Protection Regulation (EU) 2016/679 

Impact Assessment 

Inception Impact Assessment 

Treaty on the Functioning of the European Union 

Sustainable Development Goal 

Short-term accommodation rental 

Small and medium sized enterprises including micro enterprises 

2 

 
 
 
 
1.  INTRODUCTION: ECONOMIC, POLITICAL AND LEGAL CONTEXT 

1.1 

Economic and societal context 

Short-term  accommodation  rentals  (STRs)  are  accommodations  used  for  short-
stays by guests. STRs may take the form of a room in a dwelling, an entire apartment 
or  house  where  very  minimal  complementary  services  (e.g.  cleaning  services, 
breakfast), if any, are provided on location.1 STR services consist of the repeated letting 
(on  a  daily,  weekly  or  monthly  basis),  for  remuneration,  whether  on  a  professional  or 
non-professional basis, of furnished accommodation. 

STRs have existed for many years as an alternative to more traditional accommodation 
services  such  as  hotels.  The  number  of  STRs  is  however  increasing  significantly 
across  the  EU,  a  trend,  which  has  been  confirmed  during  the  COVID  crisis 2.  For 
example, the number of listings on Airbnb grew from 2 500 listings in 2007, to over 5.6 
million  listings  in  2021.3 The  growth  of  STRs  is  mainly  driven  by  the  emergence  of 
online  platforms4, which allow hosts to  reach out  directly  to  guests from  all over the 
world and facilitate bookings by the latter. ‘Platformisation’ has greatly contributed to 
the  diversification  of  the  STR  offer,  both  in  terms  of  property  rented  out  (room  in  or 
entire  apartment  or  primary  or  secondary  residences)  and  locations.  In  2019,  512 
million  guest  nights  were  booked  in  the  EU  via  the  main  online  platforms  (Airbnb, 
Booking.com,  Expedia  Group  and  TripAdvisor)5,  representing  an  increase  of  15.8% 
compared  with  2018.6 Together,  the  four  online  platforms  referred  to  above  represent 
approximately  83%  of  the  STR  segment  in  terms  of  number  of  guest  nights  booked, 
with Airbnb leading with an average traffic share of 55%7. There are also many smaller 
STR online platforms, many of which have developed in the EU.8 Several of them offer 
more ‘niche’ services, focusing on specific types of STR accommodation (e.g. Fairbnb9, 
promoting fair and sustainable hosting) or STRs located in specific geographical areas. 
Some  smaller  players  also  combine  intermediation  services  with  management 
services.10 It is estimated that there are a total of 710 online platforms in the EU, many 
of which operate cross-border.  

Cities: 

1 The Nomenclature of Economic Activities (NACE) codes provide a definition of STR. See Group 55.2 
(available here). It excludes forms of accommodation such as hotels or camping grounds.  
2 The number of STR bookings during the summers of 2020 and 2021 were above 2018 levels during the 
same period; see ESTAT data and ECFIN data. 
3 2021 Airbnb Statistics: Usage, Demographics, and Revenue Growth (stratosjets.com); About us - 
Airbnb Newsroom; 
4 C.  Colomb,  T.  Moreira  de  Souza,  Regulating  short-term  rentals.  Platforms-based  property  rentals  in 
European 
(2021): 
https:/www.propertyresearchtrust.org/short_term_rentals.html. 
5 See ESTAT data of June 2021. See also Annex 5. 
6 See ESTAT data on COVID-19 effects. 
7 Based  on  Eurostat  data,  554  million  nights  were  booked  in  2019  via  the  four  main  platforms,  while 
664.1  million  nights  were  booked  in  all  STRs;  see Duch  Brown  N.  (coord),  The  Short-Term 
Accommodation Rentals market in the EU, JRC Digital Economy Working Paper 2021-09, Table 2.1.; see 
also Annex 5, for an indication of the traffic shares of the TOP 20 STR platforms. 
8 EU platforms include e.g. Fairbnb, Dogwelcome, MrBnb or Vacanzeanimali, Kidandcoe.  
9 See Fairbnb.  
10 See for instance Ardn-Bnb. For a detailed mapping the STR segment, see Annex 5.  

debates 

policy 

the 

3 

 
 
                                                           
New  profiles  of  hosts  have  also  developed.  Whilst  STRs  mainly  started  as  an  offer 
from  one  individual  to  another  individual  (peer-to-peer),  the  share  of  ‘professional’ 
hosts,  letting  several  properties  on  a  more  commercial  basis11,  has  more  than  doubled 
between 2014 and 2020, with professional hosts accounting today for more than 45% of 
the offers and representing the 13% of all hosts.12 A small minority of them have STR 
listings in several EU Member States: between 2014 and 2019, 2.5% of EU hosts have 
offered STR services in more than one Member State.13 It should be noted that 16.3% of 
the hosts that responded to the public consultation stated that they offer STR services in 
an EU country that is not their country of residence/place of establishment.14 

STRs  create  opportunities  for  guests,  hosts  and  the  entire  tourism  ecosystem. 
Guests  appreciate  STRs  because  they  increase  choice  and,  often,  provide  more 
competitive  prices,  better  facilities  and  better  locations.15 For  hosts  and  other  service 
providers  active in the tourism  sector,  STRs  are a source of income  and employment. 
Some public authorities also help promote STRs, e.g., as a means to attract tourism to 
more  rural  or  undervalued  areas  (in  France,  for  example,  rural  areas  have  developed 
partnerships  to  create  15  000  new  STRs 16 ),  as  a  means  to  complement  the  hotel 
infrastructure17 and/or  to  pursue  other  objectives,  such  as  the  renovation  of  buildings. 
The development of the STR segment has also boosted the development of a multitude 
of auxiliary service providers, such as companies offering management, cleaning and/or 
reception services, some of which operate cross-border.18 

However, the growth of STRs is also triggering concerns  and  challenges. STRs have 
deeply impacted certain areas, in particular touristic urban and coastal areas in the EU.19 
Public  authorities  and  citizens  in  these  areas  have  expressed  concerns,  ranging  from 
increase  in  nuisances  by  tourists,  such  as  noise,  congestion  and  waste,  to  negative 
impacts on price and availability of long-term housing.20 Studies point at a correlation 
between the increasing number of STRs in certain neighbourhoods and the affordability 
of  housing21 and/or  the  quality  of  life  in  those  neighbourhoods,  although  findings  are 

11 There  is  no  EU-wide,  agreed  definition  of  ‘peer’  hosts  versus  ‘professional’  hosts.  In  general,  peers 
tend to put on the market their own primary or secondary residences. Professional hosts are, by contrast, 
renting  out  multiple  properties  (assumed  more  than  2  listings),  without  using  them  for  residential 
purposes.  The  figures  here  take  the  number  of  listings  as  the  basis  to  differentiate  between  peers  and 
professionals, see Annex 5 
12 Raising from 18.7% to 45.6%. See Annex 5, Figure 15. 
13 See  Annex  5,  Table  16.  These  hosts  have  at  least  two  properties  rented  out  as  STR  in  2  different 
Member States. 
14 See Annex 2. This probably reflects the fact that lettings often concern secondary residences. 
15 Surveys  -  Eurobarometer  (europa.eu);  a  representative  sample  of  citizens,  aged  15  and  over  was 
interviewed  in  each  of  the  27  EU  Member  States.  Between  1  and  9  September  2021,  25700  interviews 
were conducted over the telephone. 
16 See the Association des Maires Ruraux de France, AIRBNB – AMRF 
17 Feedback received from the city of Cannes and from Croatia (public consultation). 
18 See  Cocola-Gant,  A.  et  al.  "Corporate  hosts:  The  rise  of  professional  management  in  the  short-term 
rental industry." Tourism Management Perspectives 40 (2021): 100879. See also data available at  Inside 
Airbnb. Adding Data to the Debate. Management companies operating cross-border include for instance 
GuestReady. 
19 C. Colomb, T. Moreira de Souza, Regulating short-term rentals. op. cit. 
20 Short-term rentals in the EU - October 2021 - - Eurobarometer survey (europa.eu). 
21 Barron, Kyle, Edward Kung, and Davide Proserpio. "The effect of home-sharing on house prices and 
rents: Evidence from Airbnb." Marketing Science 40.1 (2021): 23-47. 

4 

 
 
                                                           
mixed.22 STRs also raise concerns related to health and safety and tax compliance.23 For 
representatives of hotels,  STRs  create  allegedly  unfair  competition in  certain  areas,  as 
they  are  not  subject  to  similar  requirements  as  hotels. 24 Associations  (e.g.  of  local 
residents) often denounce the negative impacts of STRs on their neighbourhoods.25  

1.2 

Political context and legal context 

As  a  result  of  the  abovementioned  challenges,  STRs  are  increasingly  regulated,  at 
national, regional and/or local level. Public authorities have taken actions to enhance 
the  transparency  of  the  STR  segment,  by  imposing,  for  instance,  registration 
requirements and/or by requesting online platforms to share data. In some cities, steps 
have  been  taken  to  limit  the  offer  of  STRs  by  imposing  a  variety  of  market  access 
restrictions (e.g. zoning restriction, limit on the number of nightly stays). In some areas 
STRs have been subject to outright bans.26 STR regulations are often being challenged 
in  court  however,  often  on  grounds  of  incompatibility  with  EU  law  (notably  the 
Services Directive and the e-Commerce Directive).27  

This situation has triggered increasing calls for action at EU level. In 2016 and 2018, 
the Commission  offered  guidance on how to  design proportionate market  access  rules 
and  obligations  on  online  platforms,  via  its  Communication  on  the  collaborative 
economy28 and  the  development  of  policy  principles.29 A  number  of  stakeholders  did 
not  consider  this  sufficient,  however,  as  exemplified  by  calls  for  more  legal  certainty 
and transparency coming from the Council30 and the Parliament.31  

Recently,  the  Court  of  Justice  of  the  EU  (CJEU)  in  its  Cali  Apartments  decision  has 
confirmed that under the TFEU and the Services Directive public authorities can impose 
market access restrictions on STRs in order to protect public interest objectives, such as 
combating  the  long-term  rental  housing  shortage,  as  long  as  the  rules  adopted  are 
proportionate.  In  this  context,  the  CJEU  emphasized  the  importance  of  available  data 
and analysis for proportionate policy making.32  

However, public authorities struggle to have reliable data. A first step to obtain specific 
data  on  STRs  at  EU  level  was  achieved  in  2020,  when  the  Commission  signed  a 
landmark agreement with Airbnb, Booking, Expedia Group and Tripadvisor, to publish 

22 Short-term accommodation rental in Amsterdam - Publications Office of the EU (europa.eu). 
23 DocsRoom - European Commission (europa.eu). 
24 Feedback received from associations of hotels such as HOTREC during the consultation process. 
25 See feedback collected during 2021 workshops with Valencia and Lisbon. See also Parisvsbnb - Search 
(bing.com) 
26 Total bans have been introduced (and sometimes reversed by the courts) in Nice, Amsterdam, Balearic 
Islands or Barcelona. 
27 More information in Annex 2. For examples of litigation, see Annex 7. 
28 2016 Communication 'A European agenda for collaborative economy’ (COM/2016/0356 final). 
29 DocsRoom - European Commission (europa.eu). 
30 Council Conclusions on ‘The competitiveness of the tourism sector as a driver for sustainable growth, 
jobs and social cohesion in the EU for the next decade’ (adopted on 27/05/2019). 
31 European Parliament Report ‘on access to decent and affordable housing for all (2019/2187(INI)). 
32 Judgment of 22 September 2020, C-724/18, Cali Apartments SCI and HX v Procureur général près la 
cour d'appel de Paris and Ville de Paris, para. 88. 

5 

 
 
                                                           
data on STRs offered via these online platforms across the EU.33 These online platforms 
now provide regular statistical/aggregated data on the number of nights booked and the 
number  of  guests,  per  municipality  in  the  EU.  The  Digital  Services  Act 34 and  the 
taxation  transparency  requirements  under  DAC7 35  will  also  help  to  bring  more 
transparency  for  public  authorities  on  STRs,  without  however  fully  addressing  the 
specific problems and drivers of this initiative.36  

In its SME strategy for a sustainable and digital Europe37, the Commission announced 
that  it  would  look  into  developing  a  framework  for  STRs.  In  its  IIA  published  in 
September 2020, the Commission identified problems related to a lack of transparency 
and  data  sharing,  and  problems  related  to  burdensome  market  access  restrictions  for 
hosts.  Stakeholder  consultations  following  the  IIA  clarified  a  need  for  EU  action  to 
bring more transparency and clearer rules on data access and sharing, whilst pointing at 
the  local  dimension  of  market  access  requirements  for  hosts.38 In  the  context  of  the 
Transition Pathway for Tourism39 and the Urban Agenda40, stakeholders also called for 
the adoption of an EU framework bringing more transparency to the STR segment.  

It has therefore been decided to focus, as a matter of priority, on problems relating 
to transparency via a dedicated initiative. As will be explained, it is expected that the 
initiative  will  help  reduce  unjustified  market  access  restrictions  for  hosts  as  well.  The 
Commission  will  continue  to  monitor  market  access  restrictions  and  might  take  steps 
(including possible guidance) at a later stage. 

Any  action  under  this  initiative  will  seek  to  address  gaps  and  overcome  remaining 
uncertainties in a targeted manner, to facilitate a balanced development of STRs. It will 
be in line with, and contribute to, the fulfilment of the Sustainable Development Goals 
(‘SDG’)41, in particular SDG 11 (sustainable cities and communities), by giving public 
authorities  the  tools  and  the  data  to  regulate  the  STR  sector  in  a  proportionate  and 
sustainable way. It will also support the proposed measure from the Conference on the 
Future of Europe to “invest in an economy based on tourism and culture, including the 
many small destinations in Europe”42. It will complement and build on all existing legal 
instruments be in line with EU competition law, international trade commitments43 and 
the proposed European Declaration on Digital Rights and Principles.44 

33 See https://ec.europa.eu/commission/presscorner/detail/en/ip_20_194. 
34 COM/2020/825 final. 
35 Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative 
cooperation in the field of taxation, OJ L 104, 25.3.2021, p. 1. 
36 See Section 2 ‘Problem definition’ and Annex 6 (description of EU law applicable to STRs). 
37 COM(2020)103. 
38 See infra and Annex 2. 
39 Transition pathway for tourism - Publications Office of the EU (europa.eu) 
40 See Final Action Plan of the Partnership on Culture/Cultural Heritage | Futurium (europa.eu) .  
41 THE 17 GOALS | Sustainable Development (un.org) 
42  Conference on the Future of Europe, Report on the Final Outcome, proposal 12, 
https://futureu.europa.eu/pages/reporting; see also COM/2022/404 final 
43 GATS – General Agreements on Trade in Services. Available here. 
44 COM/2022/28 final. 

6 

 
 
                                                           
2.  PROBLEM DEFINITION  

2.1  

 What are the problems?  

This  impact  assessment  focuses  on  two  interrelated  problems,  which  both  concern 
transparency.  

Public  authorities  that  are  concerned  by  STRs  need  specific  and  granular  data 
about hosts and their offers to be able to monitor, regulate and control the fast-moving 
STR  segment.  Consultation  results  show  that  a  large  majority  of  public  authorities 
across  the  EU  need  reliable  data  on  STRs.    Needs  for  data  have  been  expressed  by 
public authorities from 20 Member States45, reflecting the importance of STR bookings 
in  these  areas46.  In  response  to  a  targeted  survey,  72  out  of  80  authorities  said  they 
needed  reliable  data  on  STRs.  Needs  are  expressed  by  all  types  of  public  authorities, 
mainly cities but also regional authorities, and to a lesser extent by national authorities. 

Among the authorities that require data, the type of data needed is very similar across 
the EU. They need identification data about hosts (i.e., who is renting out) and about 
the  accommodation  rented  out  (in  particular  address,  type  of  real  estate  unit  and 
accommodation capacity)47 to understand who is renting out what and where, and verify 
compliance  with  local  rules  (e.g.,  local  health  and  safety  requirements).  Public 
authorities  wanting  to  monitor  and  control  STRs  also  need  activity  data,  that  is  the 
number  of  nights  each  accommodation  is  rented  out  for48 and  the  number  of  guests 
welcomed. Activity data aim to trace and measure the activity of STR service providers, 
helping public authorities to monitor tourism flows, design appropriate policy responses 
and enforce  the  rules. Survey results indicate that  public authorities need activity data 
on a very regular basis, at least once a month (29 out of 80 authorities) or once per year 

45 AT, BE, CZ, DE, DK, EE, EL, ES, FIN, FR, HR, IE, IT, LUX, MT, NL, PL, PT, SI, SK 
46 See ESTAT Map-Guests night spent at short-term accommodations 
47 See results of workshop 1 and public consultation in Annex 2. 
48 According  to  some  stakeholders,  this  information  would  include  number  of  nights  per  visit,  total 
number of nights the premise rented out and which specific nights an accommodation is rented out. 

7 

 
 
 
                                                           
(14), with a significant minority (16) asking for such data in real time and 3 authorities 
requesting data on a daily basis. 

Public  authorities  often  use  a  variety  of  means  to  obtain  data,  with  diverse 
efficiency results. The most used and also most successful tool for public authorities to 
obtain identification data is the use of a registration system, whereby hosts offer details 
about who they are and the accommodation they offer. Activity data, however, cannot 
be  obtained  via  registration  schemes.  Public  authorities  tend  to  turn  to  platforms  to 
obtain activity data. Only 16 out of 80 authorities in the targeted survey indicated that 
they oblige hosts to report their activity ex-post.49 This can be explained by the fact that 
the  data  received  from  online  platforms  is  considered  more  reliable,  as  hosts  may  not 
always  declare  properly  their  activity,  and/or  easier  to  manage  one  source  of  data 
instead of data from individual hosts). In cases where data is received from hosts, public 
authorities may need to cross-check it with data from online platforms. 

At  present,  there  are  two  main  problems  relating  to  data  generation  and  data 
sharing  on  STRs.  First,  online  platforms  are  increasingly  confronted  with  numerous 
and divergent  data sharing requests and or type of transparency requirements  (such as 
an obligation to display of registration numbers). Second, public authorities struggle to 
get the data they need about STRs in an efficient manner. These problems have a series 
of negative consequences, as will be explained below.  

Problem  1:  Online  platforms  are  confronted  with  numerous  and  divergent 
requests  for  transparency  and  data  sharing  on  STRs  creating  market 
fragmentation and barriers 

Online platforms, in particular those operating in more than one city or Member State 
and having more data, are increasingly confronted with  a variety of national and local 
rules concerning data sharing requirements and other transparency obligations (such as 
obligations to display registration numbers). A growing number of public authorities are 
putting in place regulations to collect specific STR data from online platforms50 and in 
some  places,  authorities  have  entered  into  voluntary  agreements  with  platforms  to 
obtain  data.  Also  outside  these  frameworks,  authorities  increasingly  reach  out  to 
platforms  with  requests  for  data.  This  is  confirmed  by  the  survey  targeted  for  public 
authorities  (out  of  80  public  authorities  replying,  33  state  that  their  national  law  has 
rules  allowing  them  to  obtain  data  from  platforms,  nine  state  to  have  voluntary 
agreements with platforms).  

This  is  an  EU-wide  phenomenon  which  appears  to  affect  the  large  majority  of 
platforms:  requests  come  from  almost  all  over  the  EU51 and  from  all  levels  of  public 
authority  (national52,  regional  or  local  level53).  For  example,  based  on  the  15  replies 

49 Based on the results of the targeted survey to public authorities. See Annex 2a. 
50 See  for  example  in  France:  Ce  qui  va  changer  pour  les  hôtes  en  matière  de  transmission  de  données 
(airbnb.com). See also Annex 8. 
51 Based on the responses to the targeted survey, platforms declared that they received requests from all 
Member States except Belgium, Latvia and Portugal. 
52 Based on the responses to the targeted survey, this is the case for Italy, Poland, Sweden. 
53 This is the case in the remaining Member States. 

8 

 
 
                                                           
received  to  a  targeted  survey  sent  to  online  platforms54,  12  online  platforms  declared 
that  they  have  received  at  least  one  data  request  from  a  public  authority.55 Not  only 
larger  platforms  are  requested  to  share  data,  also  small  platforms  are.  In  terms  of 
numbers  of  data  requests  received,  online  platforms  indicate  that,  in  2017,  they  have 
received a total of 13 data requests from public authorities. This number has increased 
over the years, with 43 requests received in 2018, 616 in 2019, 1 732 for 2020 and 869 
so far for 202156. 

While the core type of data requested is similar, platforms declare that the data requests 
otherwise  diverge  in  terms  of  frequency,  origin  of  the  data  request  (the  type  of 
authority), additional information or evidence requested (in addition to the core data set) 
and  procedural  requirements/technical  means  used  to  request  and  transfer  the  data.57 
Data requests from public authorities for public policy purposes often have a regional or 
local focus, concern specific information and frequencies and thus are different by their 
very  nature.  Increasing  and  divergent  requests,  combined  with  regulatory  complexity 
and a lack of legal certainty, make it difficult and costly, in particular for smaller online 
platforms  who  would  like  to  expand  their  services  in  other  Member  States,  to  enter 
markets  and/or  scale  up.58 In  their  response  to  the  targeted  survey,  7  online  platforms 
indicated  they  have  already  denied  a  data  request  from  a  public  authority,  mainly  for 
legal  and  cost-related  reasons. 59  Platforms  are  also  confronted  with  diverging 
requirements  to  display  information  on  their  web  interface,  such  as  e.g.,  registration 
numbers, although such  requirements are not  always  complied with  (see  below, under 
the drivers).  

This market fragmentation affects small, medium and larger platforms which operate in 
several  cities or have a cross-border activity, or have the intention to do so.60  Indeed, 
this is not a problem that affects only larger operators. Evidence points to the fact that 
also smaller platforms active in this sector operate cross-border.61 

54 The survey was sent to 27 platforms operating in the EU, including big and SME platforms. 
55 See Annex 2b. 
56 This decrease can probably be explained by the COVID-19 crisis. 
57 See Annex 2b. 
58 This was confirmed by two EU SME online platforms during bilateral consultations. 
59 Based on the results of the targeted survey to platforms. 
60 Feedback from small and medium platforms that were consulted during the consultation process as well 
as  in  bilateral  exchanges,  for  example  with  Fairbnb  or  Badi.  These  platforms  have  indicated  that  they 
encounter  several  barriers  to  expansion,  including  the  legal  uncertainty  and  the  costs  associated  with 
potential data requests coming from all levels of public authorities. 
61 Calculations  indicate  that  around  40%  of  smaller  platforms  provide  their  intermediation  services  in 
more  than  one  Member  State.  The  application  of  the  results  of  this  sample  to  the  full  list  of  platforms 
indicates that 50% of online platforms active in this sector operate cross-border (corresponding to 97% of 
total traffic), another 30% have listings in several regions or localities within the same Member State, and 
the remaining 20% operate at a purely local level. This means that, for smaller platforms, the likelihood 
of receiving  multiple and fragmented data  sharing requests from public authorities is very  high. This is 
confirmed  by  the  results  of  the  platform  survey,  where  80%  of  total  respondents  and  75%  of  smaller 
platforms indicate having received data requests from a public authority. See Annex 5 for a more detailed 
analysis. 

9 

 
 
                                                           
 
In  addition,  fragmentation  also  limits  the  capacity  of  local  platforms  to  expand  their 
operations  to  other  markets.62 Neither  network  effects63   nor  economies  of  scale64 can 
develop  in  fragmented  markets,  where the potential  numbers of users and transactions 
are  limited  by  the  reduced  dimension  of  local  or  national  markets  and  by  the  existing 
barriers to market integration.  

Problem 2: Public authorities struggle to get the data they need about STRs  

Consultation  results  show  that  public  authorities  have  similar  needs  with  regards  to  a 
core set of data (identification of the host, the accommodation and the activity),  while 
certain  public  authorities  can  require  additional  information  or  evidence  based  on  the 
local needs. Public authorities report that they use different sources to obtain this data: 
registration  schemes  for  hosts,  data  from  platforms,  reporting  from  hosts,  or 
independent data sources. 

This consultation also indicates that public authorities that need data have difficulties in 
obtaining  them,  and  often  end  up  with  insufficient,  incomplete  or  inaccurate  data  on 
STR65. This is not the case for other forms of accommodation such as hotels66. Out of 
80  replies  from  public  authorities  to  the  targeted  consultation,  77  declared  they  have 
difficulties  in  getting  data. 67  Problems  occur  at  all  levels  of  government,  national, 
regional  and  local,  and  problems  relate  to  both  identification  and  activity  data.  These 
findings are also corroborated by a study carried out in 12 large touristic cities (from 12 
Member States).68 Whilst the situation may vary across and even within Member States, 
public authorities report similar difficulties across the EU, including delays, oppositions 
or rejections of their data requests.69 In spite of national, regional or local initiatives to 
obtain  data,  public  authorities  are  often  confronted  with  several  data  gaps.  Public 
authorities put two main reasons forward to explain why they are not able to obtain the 
data they need: insufficient level of cooperation of online platforms, and the difficulties 
in  enforcing  registration  schemes,  in  particular  without  the  cooperation  of  online 
platforms. These causes are further explained below. 

62 The  assumption  is  that  a  relevant  proportion  of  platforms  not  operating  cross-border  would  want  to 
expand their operations to other Member States. 
63 Network  effects  imply  that  the  efficiency  and  user  benefits  of  platforms  increase  with  their  size. 
Network effects  emerge when the benefits a user receives from a particular service directly grow as the 
number of other users increases. For more in-depth analysis, see Néstor Duch-Brown, “The Competitive 
Landscape of Online Platforms”, JRC Digital Economy Working Paper 2017-04, available at https://joint-
research-centre.ec.europa.eu/publications/competitive-landscape-online-platforms_en. 
64 Most online platforms are characterised by a cost structure that has a relatively high proportion of fixed 
costs  and  relatively  low  variable  costs.  For  instance,  the  costs  of  developing,  establishing,  and 
maintaining  the  algorithms  and  databases  needed  to  operate  are,  to  a  certain  extent,  independent  of  the 
volume of transactions.  
65 See results of Workshop 1. More details in Annex 2. 
66 Hotels report monthly to authorities and this requirement is normally based on national law. Hotels also 
report their activities to national statistics bodies, which report to EUROSTAT (Regulation 692/2011). 
67 See results of the targeted survey to public authorities, Annex 2a. 
68 C. Colomb, T. Moreira de Souza, Regulating short-term rentals. op. cit. 
69 Examples include authorities from DE, BE, FR, AT, NL (11 distinct Member States out of 19: 62%). 
93% of public authorities (77 out of 80) say that their data requests have been rejected/opposed/delayed 
by platforms. 

10 

 
 
                                                           
2.2   What are the drivers? 

Several root causes lead to the two main problems identified. 

Driver 1: Registration schemes differ widely and are often not complied with 

As mentioned above, registration schemes have proven to be an effective way for public 
authorities 
identification  data.  Registration  numbers,  granted  per 
accommodation, are a key tool to enforce registration schemes.70 However, there are a 
few challenges connected to registration schemes.  

to  obtain 

First,  there  is  a  significant  level  of  divergence  of  registration  schemes  across  (and 
sometimes within) Member States. An increasing number of national or local authorities 
have put in place registration schemes. Registration schemes now  exist in 22 Member 
States and at various levels (national, regional and/or locally) and other Member States 
are considering introducing them too. Some Member States have registration schemes at 
local level (e.g. the Netherlands, with currently nine local registration schemes71, France 
with  over  50  local  registration  schemes72),  or  both  at  regional  and  local  levels  (e.g., 
Spain  has  regional  registration  schemes  in  place  in  19  regions  and  at  least  6  local 
registration  schemes73).  Registration  requirements  differ  however  significantly  both  in 
terms of procedural and substantive requirements. Some authorities impose particularly 
burdensome  requirements  (e.g.,  requirements  to  submit  a  variety  of  documents)  or 
procedures74. This, in turn, can have a chilling effect on the number of hosts, and hence 
on the business opportunities for online platforms.75  

In  addition,  public  authorities  also  impose  diverging  requirements  on  platforms  to 
co-operate in the enforcement of registration schemes (e.g., diverging requirements 
relating  to  the  control  on  and/or  display  of  registration  numbers).  This  is  particularly 
burdensome for online platforms. 

Second, according to public authorities who answered the public consultation, hosts do 
not  systematically  register, even where an obligatory  registration scheme is in place. 
This may be because they are not aware of the obligation to register, or, if they are, they 
chose  not  to  comply  and  are  not  technically  prevented  from  offering  their 
accommodation  on  online  platforms  without  registering  (or  in  other  words,  online 
platforms allow hosts without a registration number to publish their accommodation on 
the  platform).  Research  indicated  that  87%  of  Berlin  listings  on  the  AirBnB  platform 
did  not  include  a  registration  number76,  and  it  appears  that  this  trend  is  widespread 
across the EU77. Non-compliance with registration requirements is not only a problem 
for public authorities, but may negatively affect platforms as well.  

70Oxford Research, “Study on national regulatory approaches to short-term accommodation…”, op cit. 
71 Overzicht registratieverplichting | Toeristische verhuur | Woningmarktbeleid 
72 Hébergement responsable en France - Centre d'aide Airbnb 
73 Islands of Mallorca, Menorca, Ibiza, Formentera, Madrid, Valencia. 
74 Oxford Research. “Study on national regulatory approaches to short-term accommodation….”op cit. 
75 Oxford Research. “Study on national regulatory approaches to short-term accommodation...” op cit. 
76 RBB and information provided by insideairbnb.com, see Der Tagesspiegel. 
77 For  instance,  in  Rome,  estimates  show  that  there  are  currently  50  000  apartments  offered  for  STR 
online, while only 11 000 units are officially registered. Source: presentation by Marco Celani, AIGAB, 

11 

 
 
                                                           
 
In  certain  jurisdictions,  hosts  experience  challenges  in  understanding  and  completing 
the  registration  procedures. 78 Public  consultation  results  also  show  that  platforms  are 
not always aware of registration requirements, in particular where schemes are local and 
are changing.  In addition, registration requirements are often not being taken seriously 
by  hosts.79 Registration  avoidance  most  often  occurs  where  online  platforms  do  not 
cooperate  with  public  authorities  to  share  data  or  do  not  require  (and  then  display) 
registration  numbers when a host is  listing  its  accommodation on their  websites, even 
when they are required to do so80. Public authorities cannot identify hosts who do not 
register and need therefore data from online platforms intermediating STR services. As 
a result, the ability of public authorities to enforce registration obligations is weakened, 
and they are likely to rely even more on data from online platforms to carry out checks 
on  the  legality  of  the  offers.  The  cooperation  of  online  platforms  is  therefore  key  to 
reduce the burden resulting from data sharing requests.81  

When online platforms disregard their obligations, some public authorities have decided 
to initiate legal proceedings leading in some cases to fines under national law.82  

Driver 2: Lack of effective and enforceable legal frameworks, standards and tools 
for sharing data on STRs 

Even  where  effective  registration  systems  are  in  place,  public  authorities  struggle  to 
have  complete  sets  of  data  on  STRs,  offering  them  insights  on  STR  activity  on  their 
territories, for different reasons.  

Data  requests  from  public  authorities  are  often  rejected  by  online  platforms,  notably 
because  of  an  alleged  absence  of  a  (clear  and  undisputed)  legal  basis  for  data  sharing 
(48%  of  the  replies)83.  Online  platforms  also  have  pointed  out  they  sometimes  do  not 
have the requested data (14% of the answers), or have technical (e.g. mismatch between 
data sets and data collection systems) and practical problems. Platforms also point at the 
heavy resources they needed to respond to data-sharing requests (costs, manpower and 
time). 

In  fact,  diverging  national  data  sharing  requirements  create  fragmentation  and 
additional complexity for online platforms operating cross-border. Whilst the number of 
data  requests  is  starkly  increasing,  the  type,  the  format  and  the  frequency  of  the  data 
requested by public authorities differs across the EU.84 This creates a lack of traceability 
and  interoperability  of  the  data.  In  particular,  a  lack  of  standardisation  and  legal 
framework including an agreement for a shared identifier (e.g. the registration number, 
the host’s name and address, the cadastral number of the STR) used by both hosts and 

at the Short Stay Week on 26 November 2021. 
78 Oxford Research. “Study on national regulatory approaches to short-term accommodation...” op cit. 
79 See Annex 2. 
80 This is for instance the case in France where Airbnb was eventually fined for not displaying registration 
numbers; or in the Netherlands. 
81 The “Study on national regulatory approaches to short-term accommodation services”, op cit, indicates 
that cooperation of platforms has proven key for effective enforcement.   
82 See the example of Paris and the 1.2 million euro fine imposed on Booking.com. 
83 See Annex 7 on litigation. 
84 See Annex 2a and Annex 2b. 

12 

 
 
                                                                                                                                                                          
online platforms makes it difficult to have compatible data and easy to process.85 This 
implies that the same data produced by different stakeholders might not be reconcilable 
because data is  not  generated  and stored in  the same format  (or, more  generally, with 
the same IT standards). 

In addition, electronic tools to share data might not be in place or may be inadequate. 
For  example,  large  amount  of  data  might  be  shared  by  online  platforms  through 
inefficient and inappropriate tools – e.g. excel sheets. The absence of a standard for data 
sharing  might  result  in  corrupted  data.  Finally,  using  non-automated  data  sharing 
systems  increase  the  probability  of  data  corruption.  This  creates  extra  costs,  possibly 
mistakes and translates into further delay of the availability of data about STR activity. 
All this leads to additional barriers for online platforms to operate in the single market. 

Driver 3 - Newly introduced data sharing requirements are not sufficiently timely 
and granular and data is not reaching local authorities 

A number of initiatives have been taken recently at the EU level to address the calls for 
greater  transparency  on  STRs,  and  on  the  collaboration  of  online  platforms  in  this 
regard. However, they still do not fully address the needs of public authorities.86 

In  March  2020,  ESTAT  entered  into  a  voluntary  data  sharing  agreement  with  the 
four  main  online  platforms.87 The agreement allows ESTAT to obtain key data from 
these  online  platforms  and  publish  experimental  statistics  on  STRs.  Public  authorities 
thus have access to data about STRs offered via these online platforms. This offers an 
interesting but yet not fully complete picture of the sector, because the data that ESTAT 
receives  and  publishes  is  aggregate  (non-personal)  data  and  therefore  not  granular, 
detailed and timely enough, in particular for local authorities, for policy making and law 
enforcement purposes. Public authorities therefore impose further obligations on online 
platforms to share data with them, which can, in turn, create barriers for these platforms 
to operate in the single market.  

Some  online  platforms  have  also  started  making  available  aggregated  data88 through 
dedicated portals. Public authorities consider however that this data is often incomplete 
or  difficult  to  process89 and  not  sufficient  for  policy-making  purposes,  in  particular  at 
local level, where much targeted measures, which may differ depending on the districts 
or  streets  concerned,  are  often  needed  to  regulate  STRs.  Aggregated  data  may  for 
example provide a number of STRs but not the type of STRs (room or apartment…) and 
do not provide any information on the owner (natural or legal persons), which are often 
essential for policy-making purposes90. 

85 For example, data  shared by  platforms  might refer to the  transactions operated by property  managers 
who  have  been  entrusted  by  owners  to  manage  their  properties.  This  data  cannot  be  consolidated  with 
data referring to the owners of the accommodation or with data referring to accommodation. Information 
is therefore incomplete. 
86 See Open Public Consultation, results of workshop 1.  
87 See data sharing agreement between Eurostat and four main booking platforms. 
88 City Portal (airbnb.com). 
89 Feedback from public authorities during bilateral meetings. 
90 See Saint-Malo, who has specific rules for natural persons and legal persons. Le Monde, 12 November 
2021. 

13 

 
 
                                                           
In the area of taxation, under DAC7, new rules create an obligation for online platforms 
to report the income earned by sellers pursuant to, among other activities, the rental of 
immovable property on a short-term basis91. A significant part of the information to be 
reported  by  online  platforms  is  relevant  for  the  enforcement  of  STR  rules,  too. 
However,  this  data  is  not  immediately  reusable.  A  legal  basis  would  have  to  be 
introduced in each national legal system in order to allow the transfer of data from the 
tax authorities to the relevant public authorities enforcing STR rules. Data under DAC7 
may also not be sufficiently granular, as it does not provide information on the number 
of  nights  and  the  number  of  guests  hosted.  In  addition,  the  reporting  frequency  under 
DAC7 is annual, after closure of the fiscal year, and that is too late for STR purposes (as 
explained above).92  

Finally, whilst the DSA imposes certain obligations on platforms to respond to specific 
requests for information, it does not  require online platforms to share data with public 
authorities  on  a  systematic  basis.  In  addition,  the  DSA  requires  online  platforms  to 
enable the display of registration numbers only for hosts that qualify as ‘traders’ (a term 
which does not necessarily cover all hosts active in the short-term rental sector) and this 
may  lead  to  enforcement  gaps  in  a  sector,  like  the  STR  sector,  where  hosts  are  often 
private individuals offering assets or services on an occasional peer-to-peer basis.93 

2.3  

 What are the consequences? 

As  a  consequence  of  the  insufficient  and  inefficient  gathering  of  STR  data  by  public 
authorities,  and  the  fact  that  online  platforms  are  confronted  with  numerous  and 
divergent requests for data sharing and obligations to display registration numbers, both 
public  authorities  and  online  platforms  are  faced  with  burdensome  efforts  (in 
terms  of  costs  and  time)  to  get  and  share  data.  Online  platforms  have  stressed  the 
increasing costs related to data requests.94 Current costs for online platforms to manage 
each  request  for  data  submitted  by  a  public  authority  concerning  STRs  on  its 
geographical territory are estimated to amount on average to EUR 13 549 and take from 
one  to  three  months  to  be  processed  and  dispatched 95.  These  costs  result  from  the 
diversity  of  the  requests  in  terms  of  data  requested,  format,  frequency  and  technical 
means  used  to  transmit  the  data.  Resources  spent  by  online  platforms  to  handle  data 
requests  in  2019  is  estimated  to  have  amounted  to  around  EUR  30  million96.  Over 
recent years and due to the increasing number of data requests, the number of requests 

91  For  more  information  on  the  obligations  included  in  the  Directive  and  content  of  the  reporting 
requirements under DAC7 see Annex 6. 
92 See above the explanation about the frequency needs for STR data. 
93 See Annex 6.2.1. 
94 See Annex 2. 
95 The  cost estimation takes into consideration  many  factors: assessment of the request, data  processing 
and preparation, follow up to ensure proper communication to public authorities and internally. It is based 
on  the  calculation  of  an  average  cost  for  one  data  request  per  platform,  following  a  model  of  the  cost 
function detailed in Annex 4.2. The model is based on the information provided by a limited number of 
platforms  during  the  consultation  process,  and  does  therefore  not  reflect  the  different  costs  possibly 
incurred by platforms of different sizes. See Annex 4.2 for further details. 
96 This estimation is made assuming that only 60% of the biggest online platforms identified received 
data-sharing requests by 40% of the total number of public authorities requesting data. See Annex 4, 4.1 - 
Table 3 Costs for Platforms data-sharing requests in the baseline scenario. 

14 

 
 
                                                           
that  online  platforms  have  answered  and  the  associated  costs  have  also  increased 
significantly.  The  fragmentation  of  data  sharing  requests  and  obligations  to  display 
registration numbers increases the costs for online platforms, which in turn, may affect 
their ability to expand cross-border and offer their services in the internal market. 

Public authorities, in turn, indicate that the data they receive from online platforms often 
needs to be double checked, as there can be incomplete or contain incorrect values even 
for identification data, and that no clear improvement in quality has been observed over 
the  years.97 As  a  result,  they  have  to  continue  collecting  data  with  techniques  such  as 
web scraping, which are time consuming and costly (for example, a big EU city signed 
a  yearly  contract  in  2022  of  EUR  7  500  to  collect  this  kind  of  data  from  online 
platforms).98  

The  insufficient  and  inefficient  gathering  of  STR  data  also  creates  difficulties  for 
public  authorities  to  design  proportionate  STR  rules,  even  if  other  factors  (e.g. 
political factors) can affect the design of such rules. For example, the city of Barcelona 
explained that before they started a collaboration with online platforms to obtain data on 
STRs,  there  were  around  6  000  illegal  listings  in  the  city;  the  exact  location  of  such 
listings was impossible to determine without data from online platforms; the city had to 
rely  on  citizens  to  flag  the  illegal  activity;  and  the  absence  of  data  possibly  made  it 
difficult to design new tourism and housing policies.99 There is a vast body of literature 
confirming  that  better  regulation  and  sound  policies  must  be  based  on  evidence  and 
data,  in  any  sector. 100  The  CJEU  has  also  stressed  the  importance  of  data  for 
proportionate  policy  making. 101  There  are  also  a  number  of  initiatives  aiming  at 
improving policy making, e.g. urban planning processes, with data.102 Ill-designed STR 
rules can have a negative impact on the STR / tourism ecosystem. 

Finally, these problems can contribute to poor enforcement of local STR rules, where 
such  rules  exist.  As  mentioned  earlier,  data  is  needed  for  enforcement  purposes.  For 
instance,  where  no  registration  exists,  authorities  may  simply  not  be  aware  of  STR 
offers on their territories; where  registration exists but online  platforms  fail  to  display 
registration  numbers,  identifying  illegal  STR  listings  (i.e.  without  valid  registration 
number) may be challenging for authorities. In addition, where online platforms do not 
share  activity  data,  authorities  are  unable  to  assess  whether  possible  restrictions  (in 
terms  of  numbers  of  nights  a  property  can  be  rented  out,  or  how  many  guests  can  be 
accommodated)  are  being  respected103.  The  problems  identified  can  therefore  create 
problems  of  illegal  STRs  in  local  markets  and  possibly  problems  of  unfair 
competition (e.g. with hotels). 

97 Based on confidential information submitted by major EU cities in June 2022. 
98 Based on confidential information submitted by a major EU city in June 2022. 
99 Based on a position paper received from the Adjutament de Barcelona in May 2022. 
100  See  Principles  of  Evidence-Based  Policymaking,  2016;  Cartwright,  Nancy,  and  Jeremy  Hardie. 
Evidence-based policy: A practical guide to doing it better. Oxford University Press, 2012. 
101 Judgment of the Court, C-724/18, Cali Apartments SCI and HX para. 88. 
102 See for example Barcelona bets on ‘digital twin’ as future of city planning – POLITICO. 
103 See  workshop  on  “Enhancing  transparency  on  short-term  accommodation  rentals  in  the  EU”  of  22 
October 2021, available here. 

15 

 
 
                                                           
2.4  

 How will the problem evolve? 

STRs  are  expected  to  stay  and  some  studies  project  a  possible  significant  growth  of 
STRs in the EU104. Public authorities will need to monitor the development of STRs and 
new trends like the greater use for teleworking or increased professionalization of hosts. 
As  STRs  may  develop  in  new  locations,  more  authorities  may  need  to  carry  out 
monitoring  activities  and  adopt  rules  (either  limiting  their  presence  to  combat 
negative  societal  externalities  or  to  promote  STRs  in  order  to  attract  more  tourists). 
They will have to ensure compliance with their rules and be able to adapt them swiftly 
once they are in place. For these reasons, it is likely that public authorities will  need 
more, better quality and sufficient detailed data, on a more frequent basis in order to 
pursue their policy objectives in a justified and proportionate manner. The City of Porto 
for  example  indicated  that  they  needed  more  data  on  the  compliance  of  the 
accommodation with health and safety regulations.  

Online platforms are likely to receive an increasing number of diverse data requests 
from  local  and  national  public  authorities  and  could  be  subject  to  new  obligations  to 
share  data.105 This  will  increase  burdens  on  platforms,  in  particular  smaller  platforms. 
However, it is likely that online platforms would not be able to address all the requests 
they receive, or address them swiftly, particularly should it remain unclear on what legal 
basis they can share data to comply with the request.  

As  public  authorities  would  not  get  the  data  they  request,  litigation  would  likely 
increase  as  public  authorities  could  try  to  turn  to  courts  to  force  data  sharing  and  to 
ensure  that  requests  to  delist  illegal  listings  are  acted  on 106.  In  order  to  avoid  such 
litigation, online platforms may agree to share data on a case-by-case basis to avoid the 
risks  if  they  do  not  reply  to  public  authorities’  requests.  Only  case-by-case  solutions 
would  therefore  be  provided  that  may  be  detrimental  especially  for  smaller  /  less 
organised urban areas that are not able to negotiate with big online platforms or do not 
have in place a legal framework to request data.  

In  the  absence  of  change,  the  size  of  the  data  gap  for  public  authorities  could 
continue  to  increase.  The  data  needs  of  public  authorities  may  never  be  fully 
addressed,  and  more  and  more  authorities  will  experience  the  same  problems  (costs, 
time) when they try to get the data from online platforms. This may limit their ability to 
enforce existing rules and deprive them of relevant information e.g., on trends or limit 
the possibility to compare their local situations with others. Possibly, future STRs rules 
will  not  be  based  on  evidence.  Public  authorities  would  still  be  required  to  combine 
several methods to collect data, including web scraping, and several types of data sets 
which  may  not  be  interoperable.  Inefficiencies  in  data  collection  and  processing  are 
likely to remain or increase. 

104 Duch-Brown, N. (Coord.), The Short-Term Accommodation Rentals market in the EU, op cit 
105 Source: confidential information shared by one online platform. 
106 See the example of Paris and the 1.2 million euro fine imposed on Booking.com. 

16 

 
 
                                                           
Online  platforms  however  could  also  try  to  improve  their  cooperation  with  public 
authorities. Airbnb for example has created a city portal open to  communities, which 
provide certain data and tools to their partners.  

3.  WHY SHOULD THE EU ACT?  

3.1   Legal basis 

If the EU intervention takes the form of a legislative proposal, Article 114 TFEU would 
be  the  appropriate  legal  basis.  Article  114  TFEU  allows  for  the  adoption  of  measures 
that are considered necessary for the approximation of the provisions laid down by law, 
regulation  or  administrative  action  in  Member  States  that  have  as  their  object  the 
establishment  and  functioning  of  the  internal  market.  It  is,  therefore,  the  appropriate 
legal basis for a legislative intervention covering online service providers in the internal 
market  and  addressing  divergences  between  Member  States’  regulations  and 
requirements, which affect the functioning of the internal market for online platforms.  

This initiative intends to ensure the proper functioning of the single market, in particular 
in relation to the provision of intermediating services. The majority of online platforms 
intermediating the offer of STR services operate across the EU and are confronted with 
several  and  diverging  requirements  and  requests  concerning  information  sharing  on 
hosts and their activity and the display of information on STR services. Differences in 
national laws exist and are likely to increase, as national laws will continue to develop, 
given  that  some  Member  States  have  legislated  or  intend  to  legislate  on  the 
intermediation  of  STR  services.  Online  platforms  will  also  continue  to  be  confronted 
with more and diverging data requests as a result of the growing need for transparency 
in the STR segment. Moreover, as a matter of Union law, information society services 
are in principle subject to the law of the Member State in which the service provider is 
established,  and  the  adoption  of  national  measures  that  restrict  the  cross-border 
provision of such services is subject to strict substantive and procedural conditions107. 

In  line  with  this  objective,  this  intervention  aims  to  establish  a  harmonised  European 
framework for data generation and data sharing on STR services. The approximation of 
rules applicable to intermediary services is necessary to avoid the diversity of rules and 
requirements in the single market and facilitate data-sharing with public authorities and 
the  cross-border  provision  of  STR  services.  The  data  sharing  framework  proposed  is 
expected  to  have  a  positive  effect  on  market  access,  as  it  will  provide  the  authorities 
with  the  data  they  need,  supporting  Member  States  in  discharging  their  obligation  to 
enact and maintain proportionate rules. This initiative will complement other horizontal 
acts/proposals (e.g. the DSA) which are also based on Article 114 TFEU.108 The use of 
Article 114 is also justified by the fact that the vast majority of data will be provided by 
online platforms operating cross-border (giving their share in the traffic). Covering, as a 
complement, online platforms with no or limited cross-border activity will contribute to 
giving a comprehensive set of data to public authorities and thus make the proposed EU 
framework fully efficient. 

107 See Article 3 of Directive 2000/31. 
108 See Annex 6. 

17 

 
 
                                                           
If the intervention takes the form of recommendations, then Article 292 TFEU would be 
the appropriate legal basis. 

3.2  

Subsidiarity: necessity and added value of EU action 

According to the subsidiarity principle109, the EU should only act where the objectives 
of the proposed action cannot be achieved sufficiently by Member States alone and can, 
therefore, by reason of the scale or effects of the proposed action, be better achieved by 
the EU. 

Several Member States have established mechanisms that require hosts to register their 
activity; without prejudice to the compliance of such rules with EU law, in some cases 
Member  States  have  introduced  an  obligation  for  online  platforms  to  display  these 
registration  numbers  on  STR  services  intermediated  by  them.  Several  Member  States 
are  also  imposing  data  reporting  requirements  on  platforms.  However,  without  the 
cooperation of online platforms in enabling that only listings with registration numbers 
are displayed, public authorities struggle with the enforcement of the obligation on hosts 
to register.  

therefore 

In  addition,  as  explained  in  more  details  in  chapter  2,  divergent  and  burdensome 
frameworks  concerning  data  sharing  are  affecting  the  ability  of  online  platforms  to 
comply  with  such  requirements  and 
to  operate  cross-border.  The 
fragmentation  of  data  sharing  requirements  therefore  currently  creates  barriers  for 
online  platforms  to  operate  in  the  single  market.  In  addition,  even  where  data  sharing 
rules  are  in  place  at  local,  regional  or  national  level,  online  platforms  do  not  always 
share the data with public authorities for legal, technical or cost-related reasons. For all 
of these reasons, the current interventions at national, regional and local level are often 
not  effective,  and  authorities  are  complaining  that  they  have  difficulties  in  enforcing 
existing data generation and sharing requirements and therefore in obtaining data from 
platforms and hosts. 

This  proposal  primarily  aims  at  streamlining  data  requests  across  the  EU  to  facilitate 
compliance with such data requests for online STR platforms, hence reducing costs and 
removing barriers to operate in the single market for these platforms. An EU legal basis 
for  data  sharing  by  online  STR  platforms  with  public  authorities,  as  well  as  an  EU 
framework for such data sharing to take place, will increase legal certainty, ensure that 
the obligation to share data is compliant with EU law (GDPR, DSA…) and consistent 
with  other  reporting  requirements  (e.g.  DAC7).  It  will  also  ensure  that  the  data 
exchanged  is  standardised  and  interoperable.  The  EU  framework  will  be  applicable 
across  the  EU  and  will  in  particular  simplify/streamline  the  landscape  of  reporting 
obligations  on  platforms.  This  harmonised  framework  will  also  prevent  differentiated 
implementation of the obligation on platforms between Member States as the conditions 
for data sharing are the same for all (no selective avoidance).  

The combination of an  EU obligation for authorities to issue registration numbers and 
for  online  platforms  to  enable  hosts  to  display  only  listings  with  such  registration 
numbers, where a registration system is in place, will ensure that such requirements on 

109 Article 5(3) TFEU. 

18 

 
 
                                                           
hosts  are  easily  enforceable.  It  will  also  increase  the  traceability  and  facilitate  data 
exchanges  based  on  this  registration  number.  The  common  EU  framework  will  hence 
offer  national  and  local  authorities  the  level  of  transparency  they  need  to  enforce  the 
rules and adopt informed policy responses in line with existing EU law. 

The  principle  of  subsidiarity  is  also  respected  by  giving  local,  regional  or  national 
authorities  flexibility  with  regards  to  the  implementation  of  registration  schemes 
(whether  to  introduce  them  or  not,  and  at  which  level),  but  also  with  regards  to  the 
information and evidence that each authority can request from hosts, to ensure that local 
circumstances and needs are respected and taken into account. The measures proposed 
also  strike  a  balance  between  the  interests  of  all  stakeholders  involved,  by  requiring 
concrete action from public authorities, hosts and online platforms, and offering benefits 
to these actors, ensuring the proportionality of the foreseen intervention. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1   Objectives tree 

4.2  

General objective 

The  main  policy  objective  of  this  initiative  is  to  enhance  transparency  in  the  STR 
segment as part of efforts to promote a balanced tourism ecosystem. The initiative will 
improve and harmonise the framework for data  generation  and sharing on STR across 
the EU, remove related barriers to the provision of online services by online platforms 
and  ensure  that  public  authorities  have  sufficient  and  reliable  data  to  develop  sound 
policies in line with public policy objectives. This will ensure that online platforms do 
not  face  unjustified  and  disproportionate  barriers  to  offer  their  services  in  the  internal 
market.  It  will  also  help  ensure  that  illegal  STR  services  would  no  longer  be  offered, 
providing more certainty on enforcement of registration. 

4.3  

Specific objectives 

The specific objectives pursued with this initiative are to: 

19 

 
 
 
1.  Reduce the burden on online platforms of STR data collection and sharing, and 

avoid fragmentation of these transparency requirements across the EU; 

2.  Ensure that public authorities have the tools they need to gather data for policy 

making and enforcement of STR rules.  

In order to reduce the burden on online platforms and avoid fragmentation of these 
transparency  requirements  across  the  EU,  the  initiative  aims  to  put  in  place  a 
common  approach  to  data  generation  and  data  sharing,  whilst  clarifying  the 
responsibilities of online platforms, hosts and public authorities. 

With respect to the second objective, the intervention aims at ensuring that authorities 
have access to the information that is needed for policy making and enforcement of 
STR rules (e.g. to ensure a sufficient supply of affordable long-term rental housing), in 
accordance with the applicable national rules.  

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS?  

5.1   What is the baseline from which options are assessed? 

The baseline scenario entails a ‘no policy change’ approach.  

The EU would not specifically act to solve the transparency issues of the STR segment. 
It  is  expected  that  an  increasing  number  of  Member  States  and/or  public  authorities 
would  continue  to  develop  STR  rules  and  mechanisms  to  obtain  data  from  hosts  and 
online  platforms  at  national,  regional  and  local  level.  The  STR  framework  would 
therefore remain fragmented, uneven regulatory burdens would remain (and might even 
increase, as online platforms are confronted with increasing data sharing requests), and 
fragmented enforcement issues are likely to persist. Litigation is, in particular, likely to 
continue  and  increase,  with  STR  rules  being  challenged  in  national  courts  and  the 
CJEU. 110  Public  authorities  and  online  platforms  could  also  continue  developing 
voluntary  cooperation solutions, which take time to negotiate and only bring solutions 
for  parties  to  the  agreement.  In  their  general  contract  conditions  with  hosts,  certain 
online platforms provide that hosts are responsible for complying with local STR laws, 
or require hosts to acknowledge that they have complied with all the existing local rules 
before  proceeding  with  the  listing  of  the  STR  property.111 These  conditions  may  also 
foresee  the  possibility  for  these  platforms  to  take  appropriate  action  in  response  to  a 
host’s breach of applicable rules that they may become aware of, in particular following 
a notification of an illegal listing by public authorities. 

With no specific policy action, existing voluntary agreements for data sharing, as well 
as  the  recent  DAC7  and  DSA  will  bring  some  improvements  to  the  data  sharing  and 
enforcement  landscape  in  the  EU  without,  however,  comprehensively  solving  the 
problems  identified  (see  above,  section  2  ‘problem  definition’).  The  DSA  introduces 
due  diligence  requirements  for  online  platforms  to  make  sure  that  they  behave  more 
responsibly  and  transparently.  Among  these,  a  specific  provision  (applicable  to  online 

110 For examples of litigation see Annex 7. 
111 Information based on feedback received by certain platforms. 

20 

 
 
                                                           
platforms that constitute marketplaces) will, in particular, require online marketplaces to 
ensure  ‘compliance  by  design’  through  an  obligation  to  enable  the  display  of 
registration numbers (where a registration procedure is in place), but only with respect 
to listings offered by hosts who qualify as ‘traders’112, a term which does not necessarily 
cover  all  hosts  active  in  the  short-term  rental  sector.  In  addition,  the  DSA  will  give 
public  authorities  a  tool  to  facilitate  the  enforcement  of  orders  to  provide  specific 
information  about  individual  users,  and  thus  to  investigate  in  more  detail  individual 
providers of STR services that authorities suspect act in a fraudulent manner. However, 
its provisions to do not extend to an obligation to collect and share data that applies to 
all  hosts  and  their  activities  from  platforms. 113  These  limitations  may  lead  to 
enforcement gaps with respect to hosts’ compliance of STR rules, including compliance 
with registration obligations.  

A common European data space  for tourism is  currently being developed.114 This  data 
space aims to bring together various data sets on tourism for use by tourism businesses 
and  public  authorities  alike  (e.g.,  allowing  them  to  monitor  tourism  trends).  The 
creation of a tourism data space will not, however, solve the problems identified above 
(inter alia because it will not as such lead to generation of the data that is required by 
public  authorities).  Public  authorities  would  still  require  specific  STR  type  of  data, 
notably  specific  identification  and  activity  data  regarding  host  offers  with  a  certain 
frequency to design precise policy responses and to enforce STR rules.  

Finally,  CJEU  jurisprudence  will  provide  binding  interpretation,  the  Commission’s 
2016 Communication on the collaborative economy and the 2018 policy principles and 
good practices will continue to serve as a guidance115, notably to ensure that measures 
taken  by  public  authorities  in  relation  to  STR  are  justified  in  light  of  the  TFEU,  the 
Services  Directive  and  the  e-Commerce  Directive  in  particular.  The  Commission  will 
continue monitor and might update its guidance documents. 

5.2   Description of the policy options 

Three policy options have been identified. All aim to facilitate data generation and data 
sharing,  by  clarifying  the  respective  duties  of  public  authorities  and  online  platforms 
and  ensuring  that  effective  tools  are  in  place.  Whilst  the  three  options  contain 
comparable measures, there differ considerably in terms of intensity of the intervention. 
The below intervention logic shows how the measures considered relate to the drivers, 
the problems and the specific objectives. 

112 As mentioned above, in section 2.2, the concept of ‘trader’ does not necessarily cover all hosts active 
in  the  short-term  rental  sector.  Traders  are  defined  under  the  DSA  as  any  natural  or  legal  person 
“acting…for purposes relating to his or her trade, business, craft or profession”. STR service providers 
(i.e., hosts) are often private individuals offering assets or services on an occasional peer-to-peer basis. A 
case-by-case  assessment  would  be  required  to  understand  if  in  any  given  case  such  providers  would 
qualify as traders for due diligence provisions to apply. 
113 See, for more details on the DSA, Annex 6, section 6.2.1. 
114 As  announced  in  the  European  strategy  for  data,  COM(2020)  66  final.  To  be  possibly  launched  in 
2023. The project is still in its inception phase. 
115 See  the  2016  Communication  (COM/2016/0356  final);  ‘Collaborative  Short-Term  Accommodation 
Services: Policy Principles & Good Practices’. 

21 

 
 
                                                           
Policy option 1 – Soft measures to promote data generation and data sharing  

Under this option, the EU would issue a Recommendation  

  Encouraging  public  authorities  to  put  in  place  registration  schemes  for  hosts. 
Under such schemes, hosts would have to register with public authorities to offer 
STR services. As part of the registration process, they would be asked to provide 
certain data to the relevant public authorities about themselves and the property 
they  put  out  for  rent.  The  EU  could  encourage  Member  States  to  ensure  that 
registration schemes are user-friendly and online, and lead to the automatic grant 
of a unique registration number per accommodation. It could also recommend to 
put in place a digital single entry point, to facilitate registration and data sharing 
(see further below, under Option 2). 

  Requiring  online  platforms  to  design  and  organise  their  online  interface  in  a 
way  that  enables  all  hosts  to  display  the  registration  numbers  on  their 
websites for each listing.116Online platforms would have to require a registration 
number for each accommodation from hosts who offer their accommodation on 
the online platform. This measure would ensure that hosts register their activities 
with public authorities (as without registration, they would not be able to offer 
STR  services  on  online  platforms),  which  would  enable  public  authorities  to 
better control compliance of STRs with local rules.  

  Requiring online platforms to share pre-agreed activity data on each listing 
with  public  authorities.  Information  on  such  data  sharing  would  be  clearly 
communicated to the hosts at the time of the registration. This will enable public 
authorities  to  have  a  detailed  knowledge  of  the  activity  of  each  STR 
accommodation. Activity data is relevant for areas where a limit on the number 
of  nightly  stays  is  in  place,  but  also  in  order  to  design  and  implement 
proportionate rules and ensure compliance with them.  

116  The DSA foresees this obligation only with listings uploaded by traders, not all hosts. 

22 

 
 
 
                                                           
Such  Recommendation  would  be  based  on  good  practice  examples,  whilst  taking 
into account applicable Union law. 

The Recommendation could be complemented by an EU Code of Conduct between 
public authorities and online platforms, and national legislation aiming to facilitate 
data sharing in practice in accordance with the GDPR.117 The specific STR Code of 
Conduct could build on and complement other voluntary agreements to data sharing 
on  STRs,  such  as  the  Eurostat  agreement  or  the  future  Code  of  Conduct  for  data 
sharing in tourism.118It would in particular seek to: 

  Specify which type of data online platforms could share with public authorities 

 

 

and with what frequency; 
Include  agreements  to  use  certain  technical  solutions  to  facilitate  data  sharing 
(e.g. the use of APIs119 or simpler alternatives such as ‘drag and drop’ for SMEs 
which might not have a sufficiently developed technological infrastructure); 
Include  IT  specifications  to  ensure,  to  a  limited  extent,  interoperability  of  the 
data  shared  between  public  authorities  and  online  platforms  and  security 
safeguards.  

The  Code  of  Conduct  could  be  initially  developed  between  a  limited  group  of  online 
platforms and public authorities, giving other online platforms and public authorities the 
possibility to enter similar commitments voluntarily once it is adopted.  

The  data  collected  voluntarily  through  the  STR  initiative  could,  in  an  aggregated 
format, feed into the Tourism Data Space. 

Policy  option  2  –  Legislative  initiative  containing  a  common  approach  to  data 
generation and data sharing 

Under this option, a legislative initiative would be adopted, covering the following key 
measures:  

1.  Obligation for public authorities to maintain a registration system for hosts 
and  their  accommodations  if  they  want  to  obtain  STR  data  from  online 
STR platforms (opt-in)  

Public authorities  (national,  regional or local) who would like to  obtain  data  on STRs 
for  policy  making  and  enforcement  purposes  (e.g.  to  ensure  a  sufficient  supply  of 
affordable long-term rental housing) from online STR platforms would be required, as a 
first  step,  to  establish  or  maintain  a  mandatory  registration  scheme  for  hosts  that 
announce their offers via online platforms.120 

117 Note that a CoC cannot be a legal basis for government asking for data, nor for the company to sharing 
this data. In order to be in line with GDPR, legislation would be required for sharing personal data. 
118 This Code of conduct foresees the sharing of data on tourism in general (not specifically on STR) and 
for commercial purposes mainly (rather than for policy design and enforcement). 
119  Application  Programming  Interface  (‘API’):  It  is  a  set  of  programming  code  that  enables  data 
transmission between one software product and another. 
120 The registration system could be established or maintained at local, regional or national level. Public 
authorities could decide to create one single registration scheme applicable to several localities or regions.  

23 

 
 
                                                           
Hosts  would  be  required  to  provide  information  relating  to  the  host/owner  (name, 
address,  contact  details)  and  the  accommodation  (type  of  accommodation,  capacity, 
address,  cadastral  number).  Public  authorities  would  also  be  allowed  to  ask  for 
additional  information  or  evidence,  such  as  health  and  safety  certificates,  fire  safety 
certificates,  insurance,  landowner  permission,  etc…),  on  the  condition  that  these 
additional  requirements  are  necessary  and  proportionate  to  achieve  a  public  interest 
objective (as required by the Services Directive and TFEU).   

The registration procedure would lead to the automatic grant of a unique registration 
number  per  accommodation.  This  would  ensure  full  traceability  of  who  offers  what 
STRs  on  their  territories.  Verification  of  the  information  and  supporting  documents 
provided by the host, as well as any inspections, if necessary, would be carried out  by 
public authorities ex post. 

The  requirement  to  maintain  a  registration  scheme  would  apply  only  to  public 
authorities (at national, regional or local level) interested in obtaining data on STRs for 
policy  making  and  enforcement  purposes  (e.g.,  to  ensure  a  sufficient  supply  of 
affordable  long-term  housing)  from  online  platforms.  This  may  result  in  a  situation 
wherein  some local  authorities maintain registration  systems,  and others  not.  Only the 
authorities that have put in place registration systems would be able to benefit from the 
data  reporting  obligations  on  platforms  under  this  initiative  (see  below).  This  ‘opt  in 
system’  aims to  keep  administrative burdens  for  authorities limited and to  ensure that 
data is only exchanged where it effectively serves a public purpose.  

To  reduce  administrative  burdens  for  online  platforms  and  hosts,  and  in  line  with  the 
Single Digital Gateway Regulation,121 Member States would be required to ensure that 
the information regarding the existence  of (and links to) registration schemes at local, 
regional  or  national  level  is  accessible  via  a  national  single  digital  entry  point(the 
single digital entry point would also facilitate data sharing, see below). Member States 
should  also  ensure  that  hosts  with  multiple  listings  can  re-use  data  they  have  already 
submitted  during  the  first  registration  (notably  data  relating  to  the  hosts  itself),  in 
accordance with the once-only principle.122  

An  EU  Member  State  in  the  territory  of  which  public  authorities  are  not,  at  any  level 
(national,  regional  or  local),  interested  in  obtaining  data  from  online  platforms  would 
not be required to establish or maintain a registration system, nor a related single digital 
entry point (opt-in system, as explained above). Where registration schemes are already 
in  place  at  national,  regional  or  local  level,  Member  States  could  maintain  them,  but 
would  need  to  ensure  that  their  existing  registration  schemes  are  in  line  with  EU 
requirements. The obligation on a Member State to set up the single digital entry point 
is  triggered  by  the  wish  of  a  local,  regional  or  national  authority  to  participate  in  the 
registration and data sharing systems as described under this policy option. 

121  Regulation  (EU)  2018/1724  of  the  European  Parliament  and  of  the  Council  of  2  October  2018 
establishing a single digital gateway to provide access to information, to procedures and to assistance and 
problem-solving services and amending Regulation (EU) No 1024/2012, OJ L 295, 21.11.2018, p. 1–38. 
122 Hosts with multiple listings in several EU countries will benefit from the once only technical system 
created under the Single Digital Gateway. 

24 

 
 
                                                           
2.  Obligation  on  online  platforms  to  enable  the  hosts  to  display  their 

registration numbers  

Online platforms would be obliged to  create a field for registration numbers, which is 
already  envisaged,  in  case  of  listings  published  by  traders,  under  the  “compliance  by 
design”  obligation  under  the  DSA,  where  registration  systems  are  in  place.  This 
obligation would therefore complement the DSA, covering all hosts, and not only hosts 
that would act as traders.  

In  line  with  what  the  DSA  currently  foresees  with  respect  to  listings  published  by 
traders, online platforms would be required  to make best efforts to  assess, prior to the 
allowing  of  the  offering  of  the  service,  that  such  registration  information  is  provided. 
Similarly,  online  platforms  would  be  required  to  make  reasonable  efforts  to  randomly 
check that the information provided by the host is reliable through the use of any freely 
accessible official online database or online interface made available by Member States 
(assuming such database would exist at national, regional or local level).123 

Where an online platform would obtain sufficient indications or would have reasons to 
believe that the information provided by the host is inaccurate, incomplete or not up to 
date,  this  would,  pursuant  to  the  DSA,  trigger  an  obligation  for  online  platforms  to 
suspend the provision of their services to those hosts until they provided all the required 
information. 

The  obligation  for  platforms  to  enable  all  hosts  to  display  their  registration  numbers 
would ensure that hosts effectively register their activities, which facilitates compliance 
by local authorities.   

3.  Obligation on online platforms to share activity data 

Online  platforms  would  be  required  to  report  a  closed  list  of  specific  data  on  the 
activity  of  hosts  to  public  authorities,  notably  data  on  the  number  of  nights  an 
accommodation  is  rented  out,  and  the  number  of  guests  to  which  it  rented  out.  They 
would  be  required  to  share  data  only  with  public  authorities  that  have  put  in  place  a 
registration scheme, and the reporting would be linked to the unique registration number 
issued for each rental unit for each host.  

This  will  allow  public  authorities  to  combine  the  activity  data  shared  by  the  online 
platforms  (i.e.,  registration  number,  number  of  night  and  number  of  guests)  with  the 
data  provided  by  hosts  through  the  registration  scheme  (i.e.,  identification  of  the  host 
and the property), to obtain the complete information on STR services provided by each 
host.  Complete  information  should  enable  authorities  to  order  (based  on  applicable 
national or EU law) the online platforms to remove, under the rules of the DSA and in 
full compliance thereof, any specific illegal listing that these authorities have identified 
(e.g.  listing  with  invalid  registration  number,  or  breach  of  any  other  requirement  in 
place). The DSA rules will apply with respect to orders for removal of specific illegal 
listings,  orders  for  obtaining  specific  information  about  individual  users,  insofar  as 

123 In line with what the DSA currently foresees for the information provided by traders to the platforms. 

25 

 
 
                                                           
those  orders  fulfil  the  conditions  of  the  DSA.  The  limitations  of  liability  of  online 
platforms  for  the  illegal  content  they  store  at  the  request  of  their  recipients  will  be 
governed by the DSA. 

Platforms would have to share data via an API (or similar tool) linked to a single digital 
interface made available at the national level, and linked to the single digital entry point 
referred  to  above.  This  interface  would  in  practice  serve  as  a  data  hub,  collecting  all 
relevant  data  from  all relevant  online  platforms, and sending on these data to  relevant 
public authorities within the national territory (with each public authority receiving data 
concerning its respective jurisdiction only). National authorities would therefore need to 
develop an IT infrastructure (or adapt any existing one already in place) to allow online 
platforms to share data through it. 

Online platforms would be requested to report activity data at least on a weekly basis. 
They are expected to share data through automated means – e.g. with API – through the 
single digital  entry point.  More  lenient  reporting  obligations  would  apply  to  small 
and  micro  online  platforms 
the  meaning  of  Recommendation 
2003/361/EC),124 unless these online platforms reach a certain threshold of active users 
(hosts) in the EU. Small and micro online platforms that do not reach such threshold are 
not  expected  to  share  data  through  automated  means  and  can  report  data  to  public 
authorities  every  three  months.  This  solution  should  ensure  that  authorities  get  data 
from all platforms, whilst minimising burdens on the smallest platforms with a limited 
impact on the market.  

(within 

Member States  would be responsible for the implementation  of the measures foreseen 
under  this  option,  and  would  also  have  to  ensure  that  the  necessary  safeguards  are  in 
place  to  comply  with  the  GDPR.  The  responsibility  for  the  enforcement  of  these 
measures would lie in principle with the Member States and consistently with the DSA 
framework. 

The  data  collected  by  public  authorities  through  the  STR  initiative  could  also,  in  an 
aggregated format, feed into the Tourism Data Space. 

Policy  option  3  –  Legislative  initiative  containing  a  common  approach  to  data 
generation and data sharing, with mandatory national registration schemes for all 
hosts 

A legislative initiative would be adopted, covering the three key measures set out above, 
including  more  lenient  obligations  for  small  and  micro  online  platforms,  but  with  the 
following difference: all Member States would maintain a single registration system at 
national level for all hosts offering STR listings via online platforms. 

This option would require all Member States to adapt their current practices in terms of 
registration schemes. Member States where registration schemes currently do not exist, 
would have to introduce one, and where registration schemes have been created at local 
or regional level, they would need to be centralised at the national level. 

124 Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-
sized enterprises, OJ L 124, 20.5.2003, p. 36–41. 

26 

 
 
                                                           
Whilst  this  system  can  be  more  burdensome  for  Member  States  on  the  short-term,  it 
would increase efficiency for online platforms, hosts and public authorities on the long-
term, and is likely to be more future proof (as, with the rise of STRs all across the EU, it 
is  likely  that  overtime  all  Member  States  would  want  to  have  data  on  STRs).  Online 
platforms,  in  particular,  will  benefit  in  terms  of  efficiency  by  setting  up  a  single  IT 
system applicable across all EU at the same time. 

As under option 2, Member States would be responsible for the implementation  of the 
measures foreseen under this option, and would also have to ensure that the necessary 
safeguards  are  in  place  to  comply  with  the  GDPR.  The  responsibility  for  the 
enforcement  of  these  measures  would  lie  in  principle  with  the  Member  States  and 
consistently with the DSA framework. 

The  data  collected  by  public  authorities  through  the  STR  initiative  could  also,  in  an 
aggregated format, feed into the Tourism Data Space. 

5.3  Options discarded at an early stage 

Five measures have been discarded upfront, for the reasons set out below. 

1.  Mandatory EU registration scheme 

The EU would set up a unique registration system for all hosts across the EU. All hosts 
would  receive  a  unique  registration  number.  The  EU  would  collect  data  from  online 
platforms, linked to the registration number, through a single digital entry point set up at 
EU level.  Local  and national  public authorities would be able to  extract  the necessary 
data from this database (manually or with automated tools such as APIs) as well as EU 
institutions  and  bodies 125 (aggregated  data).  While  bringing  some  simplification  and 
clarity  to  hosts  and  online  platforms  in  the  EU  with  regards  to  their  obligations  to 
register and share data, this option does not sufficiently take into account the principle 
of subsidiarity. 

2.  A  legislative  approach  providing  for  a  legal  basis  for  national  tax  authorities 
sharing data they obtain under DAC7 with local authorities (G2G dimension) 

The  DAC7126 will  apply  as  from  1  January  2023.  It  creates  an  obligation  for  online 
platforms to report annually some data on STR activity (including the income earned) 
and  for  the  Member  State  where  reporting  takes  place,  to  exchange  this  information 
automatically with the competent tax authorities of the other relevant Member State(s).  
Online  platforms  must  report,  inter  alia,  the  following  data  to  the  relevant  Member 
State: details of the platform; identification data on the host and the accommodation127; 

125  Any  technical  tool  developed  and  managed  by  the  EU  institutions  would  have  to  comply  with 
Regulation (EU) 2018/1725 with regard to the processing of personal data. 
126 See Council Directive (EU) 2021/514, op cit. 
127 More specifically: the first and last name of the host who is an individual, or its legal name if the host 
is an entity; the primary address; the tax identification number (TIN) of the host; the business registration 
number of the host that is an entity; the VAT identification number of the host, where available; the date 
of birth of the host who is an individual; the address of each property listing and, where issued, respective 
land registration number or its equivalent under the national law of the Member State where it is located, 
where available 

27 

 
 
                                                           
the revenue received during each quarter and the number of relevant activities provided 
with  respect  to  each  property  listing;  any  fees,  commissions  or  taxes  withheld  or 
charged by the platform during each quarter; where available, the number of days each 
property listing was rented and the type of each property listing. 

Under this measure, a legal basis would be introduced at the European level to allow the 
transfer of this data from the competent tax authorities of Member States to their public 
authorities enforcing STR rules (regional or local authorities). However, this option was 
discarded  as  the  frequency  of  data  sharing  (annually)  and  timing  (year+1)  would 
prevent  public  authorities  from  obtaining  up-to-date  information  on  hosts  that  would 
allow them to undertake effective and timely law-enforcement action. The type of data 
collected is also incomplete, as it does not cover for instance the number of guests. 

3.  A  legislative  approach  imposing  obligations  on  online  platforms  only;  no 

obligations on Member States 

This option would foresee the obligations on online platforms to share data as presented 
under  options  2  and  3,  without  however  considering  the  obligation  to  set  up  a 
registration  scheme  or  to  issue  a  registration  number.  While  with  this  option,  public 
authorities  could  get  some  data  on  STRs  from  online  platforms  directly,  it  would  not 
allow public authorities to cross-check the data received from online platforms with data 
received directly from hosts. This could lead to poor data quality and traceability. The 
burden on the online platforms would also be increased, as in the absence of registration 
schemes  and  registration  numbers,  online  platforms  might  have  to  share  also 
identification data. As this option would put all the burdens on online platforms, without 
creating any efficiency gains for them (i.e. harmonised data set to be shared with public 
authorities,  automated  data  sharing  mechanisms,  information  available  on  a  single 
digital entry point), it has been discarded upfront. 

4.  Exemption for certain online platforms from data-sharing obligations 

The  option  of  a  full  exemption  for  certain  small  and  micro  online  platforms  from 
reporting  obligations,  based  on  the  volume  of  STR  activity  intermediated  (number  of 
active hosts) was assessed but also discarded at an early stage. For the purpose of this 
assessment,  it  has  been  identified  that  680  companies128 could  fall  into  the  reporting 
exemption. There would be a direct positive effect for online platforms which would be 
able to  save “costs” deriving from  the data sharing obligations: the implementation of 
this  variant  will  translate  into  around  EUR  1.6  million  savings  per  year  for  all  EU 
companies falling into this reporting derogation. However, other considerations (below) 
need to be taken into account.  

Whilst such exemption might entail benefits for smaller online platforms (because they 
would be able to save costs related to data sharing), excluding certain online platforms 
from  the  scope  of  the  initiative  could  create  a  loophole  in  the  stream  of  information 
public  authorities  will  be  able  to  receive.  This  will  lower  the  completeness  and 

128 In the calculations, it is assumed that 30 companies cover more than 60% of the biggest platforms in 
terms of traffic and 680 would qualify for the more lenient reporting obligations. See Annex 4 and Annex 
5 for further details. 

28 

 
 
                                                           
reliability  of  information  at  the  disposal  of  public  authorities  to  tackle  positive  and 
negative externalities linked with STR activity. Consequently, the enforceability of STR 
rules  in  place  will  be  jeopardised.  In  addition,  an  exemption  from  reporting 
requirements  could  incentivise  circumvention  of the rules, by directing traffic towards 
online platforms that would be exempted from the reporting obligations. Hosts who do 
not  want  to  see  their  activities  reported  partially  or  fully  could  easily  resort  to  these 
platforms.  This  would  clearly  defeat  the  objective  of  the  reporting  requirements  by 
hampering the ability of public authorities to monitor compliance and enforce the rules. 
At the same time any initial benefit for these smaller online platforms will not represent 
a  consistent  incentive  prolonged  in  time  (because  as  soon  as  these  smaller  online 
platforms  will  reach  the  minimum  volume  of  transactions  they  would  need  to  report 
data).  It  should  be  noted  that  also  the  DAC  7  does  not  entail  an  exemption  from  data 
sharing for smaller platforms. 

5.  Proportionality assessment of market access conditions for hosts  

Under this option, the EU would have developed a dedicated proportionality assessment 
to ensure that any additional market access requirements, going beyond registration and 
reporting  requirements  (for  instance  quantitative  restrictions  such  as  night  caps,  or 
zoning restrictions), do not go beyond what is strictly justified and proportionate. This 
assessment  would  include  both  procedural  and  substantive  requirements  that  public 
authorities  must  respect  when  introducing  market  access  restrictions  on  hosts.  Public 
authorities  would  be  required  to  evaluate  market  access  requirements  to  demonstrate 
they are necessary and proportionate to meet a specific public interest objective.  They 
would also have to  differentiate between types of hosts  and types  of STR  offers  (e.g., 
differentiate between ‘peers’ and professional hosts). A list of un-recommended market 
access  requirements,  that  are  not  considered  justified  and  proportionate,  such  as  the 
imposition of undifferentiated bans on STRs, would be imposed. However, this option 
was  discarded  for  a  number  of  reasons.  Stakeholders,  and  in  particular  public 
authorities, did not express support for such intervention. The Cali apartments judgment 
already  clarified  the  requirements  under  the  Services  Directive,  and  notably  the 
requirement to conduct a proportionality test based on objective facts, already apply.  

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?  

Whenever  possible,  economic,  social  and  environmental  impacts  were  assessed 
quantitatively. Data needed for the analysis has been obtained from multiple sources129 
and triangulation between sources was used to confirm the cost estimation. For indirect 
impacts on STR players, a more qualitative analysis has been conducted in order not to 
rely on weak estimations, which could be misleading. 

Direct impacts of the initiative are assessed on three categories of stakeholders. Online 
platforms and  public  authorities  are directly targeted by the initiative (as  a  result of 
new recommendations/obligations for them). Hosts are directly affected but in different 
degrees depending on the policy option analysed. We refer to ‘other players’ as the set 

129  Open  Public  Consultation,  bilateral  meetings  with  stakeholders,  dedicated  survey  to  Public 
Administrations  and  dedicated  survey  to  Platforms,  literature  review,  JRC  market  analysis,  etc.  See 
Annex 4 for a complete assessment of data sources and methodology in the modelling of the analysis.  

29 

 
 
                                                           
of economic agents operating in the tourism ecosystem impacted by the STR segment; 
these are impacted mildly and indirectly.  

For  public  authorities,  the  maximum  cost  in  the  estimated  range  was  considered.  It  is 
assumed that Member States shall assess what existing IT infrastructure they can adapt 
to  comply  with  recommendations  or  provisions  set  up  by  the  initiative,  being  able  to 
lower costs by re-using existing solutions.  

With  regards  to  social  and  environmental  impacts,  quantification  of  impacts  were 
requested  to  public  authorities,  but  the  feedback  provided  did  not  allow  to  quantify 
substantially these possible impacts of the measures. These are therefore described in a 
more qualitative manner. 

An implementation (transition) period of two years will provide public authorities and 
online platforms sufficient time to adapt and implement the new requirements.  

6.1 POLICY  OPTION  1  -  SOFT  MEASURES  TO  PROMOTE  DATA  GENERATION  & 

DATA SHARING 

Economic impacts: 

In light of the voluntary nature of this option and the absence of information on whether 
Member  States  shall  implement  all  or  only  some  of  the  recommendations,  the 
estimation  of the economic impacts  at  EU level  in  quantitative terms  depends on  how 
many  Member  States  are  likely  to  implement  them,  the  exact  nature  of  commitments 
made under a Code of Conduct and the amount of participants, as well as the diversity 
of existing registration schemes. Some elements to assess qualitatively the impact on the 
different players are also presented below, in order to allow for a comparison between 
the options both quantitatively and quantitatively. 

Impacts on online platforms: 

1.  Benefits 

The  cost  for  an  online  platform  to  process  a  single  request  for  data  submitted  by  a 
public  authority  amounts  to  EUR  13  549130.  As  explained  in  chapter  2,  the  dedicated 
survey for online platforms has shown an exponential growth in data requests in the past 
years.  Online  platforms  reported  to  have  received  more  than  1700  requests  for  data 
sharing in 2020 and 800 in 2021 (the number lowered due to the impact that the COVID 
pandemic had on tourism flows and therefore on the need of local public authorities to 
check  STR  activity).  Taking  these  numbers  of  data  requests  as  a  baseline,  we  can 
estimate  a  cumulative  administrative  cost  for  online  platforms  in  the  next  5  years 
between EUR 54 million (based on 800 requests per year) and EUR 115 million (based 
on 1700 requests per year) at least. This estimate is based on a conservative assumption 

130 The cost estimation takes into consideration many factors: assessment of the request, data processing 
and preparation, follow up to ensure proper communication to public authorities and internally. It is based 
on  the  calculation  of  an  average  cost  for  one  data  request  per  platform,  following  a  model  of  the  cost 
function detailed in Annex 4.2. The model is based on the information provided by a limited number of 
platforms  during  the  consultation  process,  and  does  therefore  not  reflect  the  different  costs  possibly 
incurred by platforms of different sizes. See Annex 4.2 for further details. 

30 

 
 
                                                           
of  only  60%  of  the  biggest  platforms  (18)  are  confronted  with  data  requests  so  any 
requests  directed  to  smaller  platforms  are  not  included  in  these  estimates  (see  table  7 
annex 4). At the same time is assumed that each online platform will receive requests 
only  from  40%  of  the  total  150  local  public  authorities  identified  A  leaner  and  more 
predictable  way  to  share  data  will  reduce  the  time  and  full  time  equivalents  (FTEs) 
needed to deal with each data request. This option foresees soft tools to streamline the 
way data is generated and shared by online platforms. If the recommendations are put in 
place consistently by public authorities and online platforms, uncoordinated  requests 
for  data would be  replaced  by  a  more  streamlined  approach  based on pre-defined 
data sets and data sharing mechanisms. This will benefit all platforms, especially SMEs. 

The  benefits  for  online  platforms  will  however  strongly  vary  depending  on  the  exact 
principles  agreed  in  the  Code  of  Conduct  and  the  number  of  public  authorities 
voluntarily  joining  the  Code  of  Conduct  and  implement  the  recommendations.  It  is 
therefore not possible to quantify the benefits resulting from a reduction in the number 
of  uncoordinated  requests.  In  addition,  it  should be  noted  that  some  public  authorities 
will continue to request data via means other than those set forth in the recommendation 
and/or Code of Conduct. This means that online platforms could continue to be exposed 
to uncoordinated requests by public authorities.  

2.  Costs 

Online  platforms  would  bear  costs  to  adapt  their  IT  infrastructure  to  ensure 
automated  sharing  of  data  with  public  authorities.  The  one-off  costs  per  platform 
that  would  decide  to  share  data  via  an  API  could  be  estimated  at  EUR  30  000  with 
yearly  maintenance  costs  of  around  EUR  36  000131.  However,  as  these  costs  would 
depend  on  the  characteristics  of  the  available  technical  solutions  (automated  and  less-
automated ones) to facilitate data sharing and would only apply to online platforms who 
decide to voluntary comply with the framework, it is not possible to properly model the 
costs estimations.  

In Member States where registration schemes are put in place and registration numbers 
are issued, online platforms may also be required to display such registration numbers. 
For  online  platforms  to  enable  the  display  of  registration  numbers,  minor  technical 
adjustments would be needed, the cost of which is expected to negligible.  

Impact on public authorities: 

1.  Benefits 

Positive impacts would be only ensured where and to the extent public authorities and 
online platforms implement the soft tool set forth under this option. Benefits for public 
authorities would in that case include a reduction of costs in obtaining the data they 
need.  Authorities would receive better quality and more complete data sets, in a much 
more streamlined and cost-effective manner, with less litigation.  

The  benefits  are  difficult  to  quantify  under  this  option,  as  they  would  depend  on  the 
willingness  of  online  platforms  to  comply  with  the  soft  tools.  Better  quality  data  will 

131 See Annex 4, 4.4 - Table 5 Costs estimations (ROM) for APIs (data push and pull). 

31 

 
 
                                                           
also  reduce  public  authorities’  costs  in  monitoring  and  securing  compliance  with 
local  rules, as authorities would be able to identify and act against illegal listings in a 
more effective manner.   

2.  Costs 

Authorities  deciding  to  implement  the  soft  tools  would  face  a  set  of  administrative 
costs, related to the creation or adjustment of registration schemes, and the creation of 
an IT infrastructure facilitating data sharing with online platforms.  

The  one-off  cost  per  national  authority  for  setting  up  a  new  IT  infrastructure  is 
estimated to be around EUR 137 000132 but assuming that every national authority will 
exploit (at least partially) existing IT infrastructure, 30% of cost savings could be made. 
Yearly  costs  for  hosting  and  maintenance  have  been  identified  respectively  to  around 
EUR  60  000  and  EUR  36  000,  for  a  total  of  roughly  EUR  96  000.  Assuming  that  16 
Member  States133 will  implement  the  recommendations  under  option  1,  total  costs  for 
national  authorities  under  this  option  will  amount  to  around  EUR  1.55  million  for 
setting up the system and EUR 1.55 million  for  each subsequent  year for hosting  and 
maintenance. 

In addition, regional or local authorities may also bear costs related to the connection of 
their  systems  with  the  IT  infrastructure  created  by  national  authorities,  which  are 
estimated  at  EUR  30  000 134 with  yearly  maintenance  costs  at  EUR  36  000.  In  the 
conservative  assumption  that  around  100  cities/areas 135  in  the  16  Member  States 
mentioned  above  will  want  to  implement  the  provisions  and  will  adapt  their  existing 
systems  gaining  additional  80%  savings  in  the  above  mentioned  cost  to  connect  their 
systems, this could entail a cumulated adjustment cost of EUR 600 000 and a recursive 
yearly maintenance cost of about EUR 720 000. 

There may also be indirect costs associated with upskilling public authorities in relation 
to data analysis and business intelligence, depending on the existing level of expertise. 
It  is,  however,  difficult  to  quantify  such  costs  as  it  is  impossible  to  know  in  advance 
which public authorities will need to develop from ex-novo or are already in possession 
of such skills.  

Finally, it should be noted that under option 1, Member States would still have to adopt 
national legislation facilitating data sharing, to be compliant with the GDPR, since there 

132 See Annex 4, Section 4.4  - Table 4 Cost estimations for registration scheme and Single digital entry 
point.  Since  the  Code  of  Conduct  might  not  systematically  include  data-sharing  through  APIs,  the  API 
connection is not factored in under option 1, but it is under option 2 and 3. 
133  For  the  purpose  of  this  exercise,  we  assume  that  around  16  Member  States  might  adopt  the 
recommendations  under  option  1.  This  is  based  on  the  fact  that  currently,  22  Member  States  have 
registration  schemes  in  place.  Based  on  the  assumption  that  9  Member  States  will  not  follow  the 
recommendation, either because they already have best practice schemes in place, or because of lack of 
interest,  and  that  3  Member  States  who  do  not  have  any  scheme  in  place  will  decide  to  implement  the 
framework,  we  consider  that  16  Member  States  might  adopt  the  recommendations  for  the  purpose  of 
calculations under this option. 
134 See Annex 4, 4.3 - Table 5 Costs estimations (ROM) for APIs (data push and pull). 
135 The  working  hypothesis  is  that  local  authorities  that  have  already  in  place  a  system  in  place  for 
monitoring STR activity – a registration scheme – will voluntarily implement the recommendations. 

32 

 
 
                                                           
would  be  no  formal  legal  basis  created  under  EU  law.  This  would  reduce  the  (cost) 
effectiveness of this option.  

Impacts on hosts: 

1.  Benefits 

According  to  the  study  made  by  Oxford  Research136,  hosts  suffer  from  burdensome 
registration requirement and have, on average, to wait 15 days before their registration 
is complete (e.g., because of ex ante checks carried out by public authorities). Where the 
soft tools are implemented, new hosts entering the market in the assumed 16 Member 
States implementing the recommendations under  this option, would benefit from more 
streamlined  registration  procedures  and  from  a  significantly  reduced  waiting  time, 
translating  into  a  total  saving  of  about  EUR  438  million  in  the  first  5  years  after 
implementation  (based  on  baseline  number  of  2019  and  growth  rate  estimations137). 
This estimation represents the monetisation of the time hosts are expected to dedicate to 
this  activity  and  it  is  based  on  the  average  hourly  wage  and  the  assumption  that  the 
waiting time for registration will be reduced from 15 days to between 1.4 and 1.7 day, 
which  is  in  line  with  time  currently  needed  to  complete  a  registration  procedure  in 
Portugal and Greece. These two have been identified as benchmark because they are in 
line  with  the  proposed  soft  tools.  Based  on  the  assumption  that  87%  of  the  hosts  are 
peers138 and 13% professional hosts, the cumulative  cost savings for citizens over five 
years  are  estimated  at  around  EUR  381  million  and  for  professional  hosts  at  around 
EUR 57 million. 

2.  Costs 

Hosts in the 100 cities/areas139 in the 16 Member States mentioned above will possibly 
be  requested  by  competent  local  authorities  to  adapt  their  registration  information. 
Using the assumption that data already used in the active systems will be re-used, it is 
possible  to  assume  that  any  adaptation  will  not  cost  more  than  ~30%  of  a  new 
registration  for  each  host  (the  cost  associated  with  a  new  registration  under  the 
characteristics  required in this initiative is  at  around EUR 320140). A  rough estimation 
brings a total one-off administrative cost for hosts of around EUR 15.8 million.141 Based 
on the assumption that 87% of the hosts are peers and 13% professional hosts, the one 
off administrative  costs for citizens are estimated at  around EUR  13.7 million and for 
professional hosts at around EUR 2.1 million.  

136 Oxford Research. “Study on national regulatory approaches to short-term accommodation”, op.cit . 
137 It is assumed that 165.385 hosts  will be  impacted in the first  year after implementation and 158.618 
over the next 5 years. For details see Annex 4, Section 4.5.1 – Table 11 Savings for Hosts under option 1 
and Section 4.2- Table 2 Costs for hosts’ registration in the baseline scenario.  
138 Peers are considered hosts having maximum 2 listings. See Annex 5 – Table 10 Number of listings per 
Airbnb hosts. 
139 The  working  hypothesis  is  that  local  authorities  that  have  already  in  place  a  system  in  place  for 
monitoring  STR  activity  –  a  registration  scheme  –  will  voluntarily  implement  the  provisions  in  the 
recommendations. 
140 For detailed calculation see Annex 4, Section 4.4 – Table 7 Cost estimation for registration for hosts. 
141 For  detailed  calculations  see  Annex  4,  Section  4.5.1  –  Table  10  Costs  for  hosts  for  new/adjusted 
registration under option 1. 

33 

 
 
                                                           
Impacts on Tourism Ecosystem and other accommodation service providers: 

If  the  soft  tools  referred  to  above  are  implemented,  the  tourism  sector  as  a  whole  is 
likely  to  benefit,  in  an  indirect  manner.  Better  data  about  STR  would  give  authorities 
the tools to assess and address any problems related to unfair competition between STR 
providers and providers of other accommodation services, such as hotels. This is likely 
to have a positive economic impact on the latter.  

Further, public authorities might decide to make data collected on STRs available on an 
aggregate basis to the various stakeholders active in the tourism sector. This is the aim 
of the envisaged tourism data space. Better quality data on STRs would allow a variety 
of  actors  in  the  tourism  sector  (e.g.,  restaurants,  tourist  guides,  cleaning  services, 
management  companies  –  often  operating  cross-border)  to  monitor  and  anticipate 
trends, and to adjust their service offers to these trends. 

Social impacts: 

The potential impacts are presented below in a qualitative manner, as the social impact 
of the measures under this option will depend on the implementation of the measures by 
public  authorities  and  online  platforms,  and  also  on  what  public  authorities  will  do 
exactly with the better quality data they will receive. Expected impacts include: 

 

Increased trust of consumers/guests 

In  the  areas  where  the  recommendations  foreseen  in  option  1  will  be  implemented, 
guests’  trust  is  expected  to  increase  thanks to  the use of the registration number.  In 
addition,  public  authorities  would  be  able  to  better  monitor  and  enforce  health  and 
safety requirements, thanks to the data received from hosts and online platforms. 

  Less illegal listings 

Since traceability of hosts and their activity, including with the obligation to enable all 
hosts to display the registration numbers, will increase substantially the ability of public 
authorities to enforce local rules on STR activity, it is expected that fewer unlawful STR 
accommodations  will  be  offered.  This  would  benefit  the  final  consumers  –  i.e.  the 
guests – and/or the local communities, as authorities would be better able to ensure the 
quality of offer to tourists and the quality of life of residents. 

The  case  of  French  cities:  In  December  2021,  Airbnb  delisted  non-registered  offers  in  10 
touristic French cities. It is estimated that this led to a decrease of the offer ranging from 10 to 
40%  depending  on  the  city142.  This  delisting  followed  the  decision  of  the  Paris  Tribunal  to 
impose a 8.4 million fine to Airbnb for publishing non-registered listings. In Paris, it is claimed 
that around 10 000 ads were suspended for non-registration related reasons143. 

The case of Barcelona: Using data provided by a cooperation agreement with one important 
STR  online  platform,  as  well  as  other  complementary  sources,  Barcelona  has  been  able  to 
reduce significantly the number of illegal listings since it started to fight it in 2018. 

142 Le Monde, ‘La grande offensive des villes contre Airbnb’, 17 December 2021. 
143 Based on a position paper submitted by the City of Paris in June 2022. 

34 

 
 
                                                           
  Better management of tourism flows and increased ability of public authorities 

to assess and mitigate negative externalities of STRs 

Thanks to better data-sharing between online platforms and public authorities, the latter 
would  have  better  information  and  tools  to  predict  and  manage  touristic  flows.  
Completeness,  reliability  and  extensiveness  of  information  on  the  STR  segment,  if 
properly used, will help  public authorities in  their public policies duties. They  will be 
able  to  design  evidence  based  policies,  producing  better  targeted  policies  to  address 
specific externalities of the STR activity – positive or negative – to the benefit of local 
communities.  This  could,  for  instance,  have  a  positive  impact  on  the  availability  of 
affordable  housing  in  high  pressure  areas.  In  these  areas,  public  authorities  would  be 
able  to  better  regulate  STRs  to  ensure  a  balance  between  the  STR  offer  and  the 
availability of affordable housing. Better data could also positively affect the capacity of 
public  authorities  to  deal  with  health  and  safety,  as  well  as  possible  security  issues 
related to STRs.  

Benefits of a better data sharing framework for tourism hot spots detection and management 
of the coexistence between tourists and residents - The case of Barcelona 

Barcelona144 has  indicated  that  more  efficient  data  sharing  with  online  platforms  leads  to  a 
better  detection  of  areas  with  great  tourist  demand,  the  so-called  “Great  Affluence  Areas” 
(GAA) of Barcelona city. According to the city of Barcelona, identifying GAAs is necessary to 
better  define  specific  tourism  policies,  to  mitigate  the  potential  negative  effects  of  tourism  on 
public spaces and neighbourhoods. 

In  particular,  the  City  of  Barcelona  has  created  a  team  of  Civic  officers  to  improve  the 
coexistence  between  visitors  and  residents.  They  provide  advice  about  civic  rules  and 
behaviours and help visitors enjoy responsibly of the sites. Knowing the flows of tourists allows 
the City to better manage its Civic officers team. Data show a clear decreasing trend of reports 
by  citizens  of  incidents  due  to  touristic  activity,  in  particular  related  to  STR  (specific  entry), 
since the creation of the Civic officers team. 

144 Based on a position paper submitted by the Ajuntament de Barcelona in June 2022. 

35 

 
 
 
 
                                                           
Better management of STRs to ensure availability of affordable housing -The case of 
Amsterdam 

Several  studies  have  looked  into  the  impact  of  the  growth  of  STRs  on  the  availability  of 
affordable  housing.  A  study145 has  specifically  looked  into  statistical  correlations  between  the 
rise  of  STR  listings  in  Amsterdam  and  the  housing  prices  in  the  city.  While  the  research 
highlights the complexity in finding any correlation in this regard, the results however suggest 
that in particular in the high-density city centre, the growth of STRs can lead to higher housing 
market  prices.  Better  data  on  STRs  would  allow  public  authorities  to  better  manage  STRs  in 
given  areas,  which  could  have  a  positive  impact  on  the  availability  of  affordable  long-term 
housing. 

 

Impacts on fundamental rights 

The  recommended  provisions  under  policy  option  1  are  expected  to  affect  the 
fundamental  right  of  the  protection  of  personal  data 146,  since  it  would  increase  data 
collection and sharing. However, such processing would be necessary and proportionate 
to  achieve  the  objectives  as  described  above.  With  respect  to  the  impact  on  the 
fundamental right of protection of personal data, the Code of Conduct on data–sharing 
between  online  platforms  and  public  authorities  could  specify  the  application  of  the 
GDPR  to  the  processing  of  STR  data  and  provide  for  data  protection  safeguards  to 
mitigate  the  effects  of  data  sharing  by  setting  standards  on  data,  their  format  and  the 
tools needed to perform such operation which are in line with the principles of GDPR 
(data  minimisation  and  purpose  limitation,  integrity  and  confidentiality,  etc.).  If 
implemented  by  players,  the  agreement  will  streamline  the  operations,  reducing  the 
heterogeneity  of  formats  data  are  shared  at  the  moment.  The  expected  result  is  the 
development  of  a  data-sharing  process  that  better  guarantees  the  privacy  and  data 
protection  of  individuals,  i.e.  the  hosts.  If  widely  (voluntarily)  adopted,  the  Code  of 
Conduct  should  assist  with  the  compliance  with  GDPR  rules.  In  order  to  ensure  the 
lawfulness of the processing of those data, a national legislative act to establish the legal 
basis for the processing would still be required. 

Environmental impacts: 

The  potential  impacts  are  presented  below  in  a  qualitative  manner  as  the  actual 
quantitative  impacts  of  the  measures  under  this  option  will  (i)  depend  on  the  level  of 
implementation of the measures by public authorities and online platforms,  and (ii) on 
what public authorities would decide to do with the data they receive. Nevertheless, it is 
possible  to  forecast  certain  types  of  indirect  positive  impacts  as  presented  below,  if 
public authorities get more data, and if the data collected is used by public authorities to 
develop green policies: 

 

Increased  ability  of  public  authorities  to  assess  and  mitigate  the  ecological 
footprint of STR activity 

145 Van Haaren, Jeroen, and  Susan Vermeulen, Jeroen Klijs, Ko Koens, and Jorrit Bijl. “Short-term 
accommodation rental in Amsterdam. An empirical investigation of statistical correlations between short-
term rental, housing prices and quality of life index.” European Commission, Luxembourg (2021). 
146 Charter of Fundamental Rights of the European Union, OJ C 326, 26.10.2012, p. 391–407, Article 8. 

36 

 
 
 
                                                           
More  data  on  tourism  flows  via  STRs  could  give  public  authorities  the  possibility  to 
size  energy  consumption  of  such  accommodation  and  their  contribution  to  the 
ecological footprint. Public authorities would also possibly be able to better assess the 
needs  for  waste  management  and  coordinate  resources  at  local  level  accordingly, 
reducing the urban impact of STR activity.  

The impact of better STR data on green policies and mobility – The case of Barcelona 

The  city  of  Barcelona  has  been  able  to  assess  the  environmental  externalities  of  tourism, 
including STR147.  

- 

STR is the fourth most water-consuming per person, and it is 1.9 times the normal water 
consumption of Barcelona residents 

-  Energy consumption of a STR guest is 1.3 times the average energy consumption of a 

- 

Barcelona residents (although less than other touristic options) 
STR is the second main waste generator from tourist accommodation and responsible 
for 9.2% of the total waste generated in the city. 

The  city  also  assessed  that  better  data  on  STRs  could  allow  to  better  forecast  the  number  of 
overnight stays, the volume of daily travel within the city and hence allow to better design urban 
policies to plan and manage tourist mobility. 

 

Impact on rural areas 

Better  data  should  allow  public  authorities  to  attract  STRs  in  rural  areas  where  STRs 
have  a  positive  overall  impact,  for  example  where  STRs  can  allow  to  invest  in  the 
renovation of houses, including for the greening of buildings. It should be noted that all 
positive impacts  mentioned before would materialise only if and to  the extent the soft 
tools under this option are complied with.  

Stakeholders’  views  on  the  policy  option  1148:  All  stakeholders  groups  supported  in 
some manner the measures presented under this option during the stakeholder and the 
public consultations. However, public authorities and online platforms – as well as local 
associations  -  notably  have  stressed  the  limits  of  soft  approaches  in  this  regard.  In 
particular,  they  stress  that  soft  approaches  have  already  been  put  in  place  since  the 
Communication of 2016 and the policy principles of 2018, but that these have not led to 
major improvements in terms of transparency in the STR sector.149 Barcelona explained 
that,  while  the  collaboration  they  have  put  in  place  with  online  platforms  to  obtain 
periodic  data  on  STRs  and  flag  illegal  listings  brought  some  improvements  in  policy 
making and enforcement, they still observe major quality problems with regards to the 
data received, which has forced the authorities to continue to collect data through web 
scraping.150 This example therefore shows the limits of voluntary cooperation. 

Stakeholders,  including  local  associations,  therefore,  express  a  preference  for  a  more 
structured framework for data sharing, taking the view that only a binding common EU 
framework, by preference of a legislative nature, could achieve it. This is confirmed in 

147 br_externalitats_ambientals_turisme.pdf (barcelona.cat) 
148 Based  on  the  feedback  received  during  the  public  consultation,  the  workshops,  the  targeted  surveys, 
bilateral meetings with and ad hoc submissions from the stakeholders. See Annex 2 for more information. 
149 See in particular the analysis in Chapter 2. 
150 Based on a position paper submitted by the Ajuntament de Barcelona in May 2022. 

37 

 
 
 
                                                           
the Memorandum of the Urban Agenda Culture and Cultural Heritage 2021151 (which 
concludes  that  without  mandatory  collaboration  of  online  platforms,  the  regulatory 
powers of public authorities remains ineffective).  

6.2 POLICY  OPTION  2  -  LEGISLATIVE  INITIATIVE  CONTAINING  A  COMMON 

APPROACH TO DATA GENERATION AND DATA SHARING 

Economic impacts: 

The  main  difference  with  respect  to  option  1  is  that  option  2  makes  the  system 
compulsory  through  legislation  where  there  is  a  need  for  STR  data.  Impacts  are 
similar  in  nature,  but  different  in  probability  of  realisation  and  magnitude.  While  in 
option  1,  the  implementation  of  the  framework  (and  therefore  the  costs)  is  voluntary, 
and solely rely on the good will of public authorities and online platforms, in option 2, 
the  implementation  of  the  framework  is  mandatory  for  all  public  authorities  (local  or 
national)  who  would  like  to  collect  data  on  STRs,  and  for  all  online  platforms. 
Repetitions of the descriptive parts of the analysis are omitted and  analysis below will 
rather focus on the differences. 

Impacts on online platforms: 

Under  option  2,  all  online  platforms  in  the  EU  would  have  to  put  in  place  the  data 
sharing framework. This will result in much bigger (and much more certain) benefits for 
online platforms, whilst also increasing compliance costs. 

1.  Benefits 

The main benefit for online platforms results from the replacement of uncoordinated 
data  requests  by  more  streamlined  and  proportionate  requests  (in  particular  with 
regards to the type of data to be shared, the frequency and the technical means), which 
can be translated into cost savings on the long term. 

Contrary to option 1, online platforms will have the same data sharing obligations and 
obligations  to  allow  the  display  of  registration  numbers  (when  data  are  requested) 
within  the  entire  single  market.  Under  this  option,  the  data  set  that  online  platforms 
have  to  share  with  selected  public  authorities  (those  that  have  put  in  place  the  data 
framework) will be pre-defined and closed. This will therefore create economic benefits 
for online platforms, and in particular for smaller platforms, as they will always have to 
share the same data set with the same frequency with selected public authorities. 

A  streamlined  data-sharing  framework,  which  will  be  automated,  will  help  concretely 
online platforms  to better plan and allocate resources due to the predictability of 
the data requests as well as the predictability of the data to be shared, the tools to be 
used  and  the  data  standards  to  be  respected.  This  will  imply  certainty  for  online 
platforms on the type and timing of data-requests coming from public authorities since 

151  Martinez,  Yolanda  (Marimón  Avocados),  Memorandum  for  UA  EU  C&CH  2021  “Regulatory 
Enforcement  Difficulties  In  The  Short-Term  Rental  Accommodation  Sector  Stemming  From  The 
European Legal Framework For Digital Services” to be published at URBACT https://right2housing.eu 

38 

 
 
 
                                                           
they  will  only  receive  data  requests  under  the  framework  set  up  by  the  initiative, 
reducing the burdensomeness of requests. 

Savings for online platforms are expected to be substantial. A streamlined data-sharing 
framework will enable online platforms to eliminate the costs for legal assessment and 
put  in  place  an  automated  way  to  process  incoming  data  requests  from  public 
authorities, thus making the cost to process a single request very limited and negligible 
(therefore reducing the cost to process single requests from EUR 13 549 to EUR 0). On 
this basis, it is estimated that savings for online platforms over a period of 5 years will 
amount  to  between  EUR  54  million  (based  on  800  requests  per  year)  and  EUR  115 
million (based on 1700 requests per year) and net savings to around EUR 35.8 million 
and  EUR  96.8  million  (baseline  costs  related  to  data  requests  from  public  authorities 
minus  one-off  costs  for  online  platforms152 of  around  EUR  8.2  million  as  presented 
below and cumulative maintenance costs of EUR 10 million153. 

Small  and  micro-enterprise  online  platforms  with  average  monthly  active  hosts 
equal  or  lower  to  1  000  will  benefit  greatly  from  the  possibility  to  use  adapted 
reporting  obligations  (every  three  months,  and  manually,  rather  than  weekly  and 
automated  for  bigger  online  platforms).  Moreover,  the  targeted  survey  for  online 
platforms has shown that online platforms that would qualify for more lenient reporting 
obligations  are  already  recipients  of  requests  for  data  submitted  by  public  authorities 
and  this  is  likely  to  continue  considering  that  there  are  national  frameworks  (e.g. 
France)  that  do  not  foresee  any  exemption  to  the  collection  of  STR  data  from  online 
platforms,  including  small  and  micro-enterprises.  The  data  available  doesn’t  enable  to 
quantify the exact number of data requests received by small and micro-platforms and 
the related cost savings for small and micro-platforms. However, a single data request 
might  currently  cost  EUR  13  549  to  process,  which  is  significantly  higher  than  the 
estimated cost of the adapted reporting obligations (around EUR 600 for each reporting 
activity per small or micro-platform or EUR 2400 per year)154. 

Additional  legal  certainty  will  be  given  to  online  platforms  by  the  legal  basis  that 
provisions  in  this  policy  option  will  provide  –  differently  from  option  1.  Due  to  the 
diversity  of  requests,  online  platforms  often  fear  that  data  requests  from  public 
authorities  could  breach  privacy  laws  and  other  legal  instruments  at  the  level  of  the 
Member  States’  domestic  law  or  at  the  level  of  Union  law  (e.g.  GDPR).  Without  a 
specific  basis  in  Union  law,  online  platforms  are  therefore  obliged  to  analyse  every 
single data request in order to make sure that these requests do not breach any existing 
legal  instrument,  incurring  in  extra  costs  and  delaying  the  provision  of  data  to  public 
authorities.  The  new  ad  hoc  legal  basis  set  by  this  policy  option  will  increase  legal 
certainty  for  all  online  platforms  and  therefore  reduce  costs  for  legal  assessment  and 
processing  time  linked  to  data  requests,  while  still  complying  with  applicable  Union 
legislation in the field of data protection, such as the GDPR.  

152 In the cost calculations, it is  assumed that 30 companies (the top 60% of the biggest platforms)  will 
need to connect to single digital entry points through APIs as some of the online platforms might qualify 
for the option with more lenient reporting obligations. See Annex 4, Section 4.1 & 4.2. 
153 See Annex 4, 4.5.2 - Table 15 Costs for platforms for data sharing under option 2. 
154 See Annex 4, 4.3 - Table 6 Costs estimations – Option with more lenient reporting obligations. 

39 

 
 
                                                           
2.  Costs 

Under this option, online platform will mainly incur administrative costs linked with the 
adaptation of their IT infrastructure and the connection to the single digital entry point.  

Larger companies will face the one-off cost of adapting their IT infrastructure to share 
data  by  automated  means  (APIs)  through  each  single  digital  entry  point  of  Member 
States in which they operate and in which local, regional or national authorities request 
data.  Small  and  micro-enterprise  online  platforms  with  1  000  average  monthly 
active  hosts  will  benefit  greatly  from  the  possibility  to  use  adapted  reporting 
obligations  (every  three  months, and manually,  rather than weekly  and  automated for 
bigger online platforms).  

The cost  of creating  one connection  between an  online platform and the  single digital 
entry  point  is  estimated  at  around  EUR  30  000.  In  the  computation  of  the  costs  per 
online platform, the complexity linked with the number of connections to establish has 
been taken into consideration. An intermediary that operates in more than one country 
will  need  to  connect  to  each  national  single  digital  entry  point  but  once  the  first 
connection  has  been  developed,  a  20%  extra  cost  should  be  considered  for  each 
additional  connection.  Additionally,  in  the  breakdown  of  the  costs,  costs  for 
maintenance have been identified with one third of FTE for each year. Considering an 
hourly  IT  specialised  salary  of  75  EUR,  the  computation  for  yearly  maintenance  is 
estimated at EUR around 36 000 per year155. 

Under  these  hypotheses,  the  one-off  administrative  costs  for  online  platforms 156 are 
estimated  at  around  EUR  8.2  million,  while  yearly  maintenance  (administrative)  costs 
are expected to be around EUR 2 million that over a period of five years it amounts to a 
total  of  around  EUR  10  million  (EUR  18.2  million  including  one-off  administrative 
costs).  

As  stated  before,  small  and  micro-enterprise  online  platforms  with  average  monthly 
active  hosts  equal  or  lower  to  1  000  will  benefit  greatly  from  the  possibility  to  use 
adapted  reporting  obligations.  Therefore,  they  will  not  face  costs  to  adapt  their  IT 
infrastructure but they will be able to share data by uploading them every three months 
with  an estimated cost  to  be around EUR  600 for each  reporting activity  per platform 
(or  EUR  2  400  per  online  platform  per  year)157 which  is  significantly  lower  than  the 
estimated cost for processing one data request (EUR 13 549). Based on the estimation 
that 680 online platforms would qualify for the more lenient reporting requirements158, 
there is  only  a  yearly  total  reporting  (administrative)  cost  of  around EUR  1.6  million. 
Adjusted  reporting  obligation  will  ensure  the  completeness  of  data  collection  –  not 
creating loopholes in the system – and a very limited cost impact for small and micro-
enterprises,  while  making  sure  that  collection  and  data  sharing  are  embedded  in  the 
business  process  since  early  stages  of  company  life.  This  will  also  help  to  avoid  the 

155 See Annex 4, 4.3 - Table 5 Costs estimations (ROM) for APIs (data push and pull). 
156 In the cost calculations, it is  assumed that 30 companies (the top 60% of the biggest platforms)  will 
need to connect to single digital entry points through APIs as some of the online platforms might qualify 
for the  with the more lenient reporting obligations. See Annex 4, Section 4.1 & 4.2. 
157 See Annex 4, 4.4 - Table 10 Costs estimations – Option with more lenient reporting obligations. 
158 See Annex 4, 4.1 - Table 1 Number of hosts and platforms. 

40 

 
 
                                                           
creation  of  artificial  obstacles  for  this  type  of  online  platforms  to  their  business 
development and growth.159 

Online platforms would also incur the (expected negligible) cost related to the creation 
of the field  to  request  the registration number to  hosts and to  enable its  display in  the 
relevant listing. 

Impacts on public authorities: 

Under option 2, all public authorities (whether local, regional or national) who want to 
collect data on STRs would have to implement the framework, whereas under option 1, 
the  implementation  of  the  data  framework  is  purely  voluntary.  The  number  of  public 
authorities affected is therefore expected to be higher than in option 1 (for the purpose 
of calculating costs and benefits, it is assumed that 25 Member States compared to  16 
Member  States  under  option  1  will  implement  the  framework).  However,  the  net 
benefits at EU level will also be higher. 

1.  Benefits 

  Reduction of costs to obtain data 

All public authorities interested in data will be able to have the full picture on the online 
STR  activity  intermediated  by  online  platforms.  This  is  due  to  the  fact  that  all  online 
platforms, SMEs  companies included, will be required to  share activity  data, avoiding 
the creation of loopholes in the data sharing flow. Additionally, the provisions foreseen 
by  policy  option  2  will  ensure  certainty  on  data  traceability  and  optimisation  of 
data-sharing  processes  through  the  implementation  of  the  framework  in  areas 
interested  in  data.  The  ability  to  link  data  on  STR  activity  to  the  registration  number 
will  ensure  the  traceability,  giving  the  ability  of  public  authorities  to  consolidate 
properly  data  coming  from  different  online  platforms  on  the  same  host.  On  the  other 
hand, the defined data set to be shared by online platforms as well as the standards and 
the  tools  to  be  used  for  sharing  it  will  ensure  consistency  in  the  data  shared  and 
optimizing the process, hence reducing overall costs. 

The  full  transparency  on  STR  activity  that  will  be  achieved  will  additionally  ensure 
“transparency  level-playing  field”  between  STR  activity  and  activity  of  other 
accommodation  services  (hotels,  hostels,  etc.)  that  are  already  monitored  by  local 
authorities. 49 out of 80 (61%) respondents declared to the dedicated survey for public 
authorities that they collect data from other tourism businesses, most of the time (46%) 
at  least  bi-monthly 160 .  Public  authorities  will  obtain  another  important  piece  of 
information on the accommodation services in their areas and will be able to properly 
address  public  interest  objectives  as  management  of  tourism  flows  or  affordability  of 
housing.  Acquiring  the  comprehensive  and  reliable  knowledge  on  activity  of  STR 

159 Full  exemptions  for  SMEs  are  not  favoured  by  SMEs  companies.  Once  example  could  be  the  clear 
statements of Fairbnb during a bilateral meeting. Full exemptions for SMEs will indeed create an artificial 
additional barrier to the company scaling up process since it will be obliged to comply with obligations 
(many, if we take into consideration also other exemptions on other issues) one day to the other, and not 
in a gradual way. 
160 See Annex 2a. 

41 

 
 
                                                           
accommodations  will  give  a  complete  overview  of  the  dynamics  of  the  whole 
accommodation sector. 

While  it  is  not  possible  to  quantify  the  exact  cost  reduction  resulting  from  the 
implementation  of the framework under option 2161, it is  possible to  assume that such 
benefits  would  materialize  for  public  authorities  implementing  the  data  sharing 
framework.  Indeed,  while  some  costs  (see  below)  are  associated  with 
the 
implementation  of  the  data  sharing  framework,  these  are  one-off  costs  (adjustment 
costs).  The  current  costs  for  gathering  data  based  on  fragmented  and  non-efficient 
means are expected to be higher than the costs to gather data in a more automated way. 
Therefore, while on the short-term, absolute costs for public authorities may be higher 
due to adjustment costs, the benefits would be higher and outweighing the costs on the 
long term. 

  Reduction of enforcement costs of STR rules 

Areas  that  implement  the  data-sharing  framework162 would  obtain  the  full  benefits  of 
transparency and have detailed, traceable, interoperable and timely data. Therefore, this 
would enable better policy-making, more targeted and proportionate rules, and greater 
enforceability of their STR rules, helping public authorities better achieve public policy 
objectives. Additionally, costs will likely be offset by a consistent reduction of the delay 
in  enforcement  that  public  authorities  need  to  bear  due  to  their  inability  to  (a)  collect 
data  on  a  timely  manner  and  (b)  communicate  to  online  platforms  which  listings  are 
unlawful and ask them to be delisted. For example, as obligations will be clearly set by 
the  provisions,  savings  are  foreseen  coming  from  the  decrease  of  legal  challenges 
between public authorities and online platforms to get the data. Similarly, as the single 
digital  entry  point  shall  enable  public  authorities  to  match  the  activity  data  shared 
directly  by  hosts  (e.g.  in  relation  to  direct  bookings),  this  shall  also  facilitate  better 
enforcement and a complete understanding of the STR segment. 

Costs of web scraping to obtain STR data - The case of one big EU city163 

In order to obtain STR data, certain local authorities sign contracts with private companies who 
scrape the web (in particular big online booking platforms) to obtain data such as occupancy 
rates, active listings, price for one night, maps with location of listings or even excel sheets with 
all  the  data  for  one  listing.  Depending  on  the  company  and  the  type  of  data  scrapped,  these 
contracts can vary in terms of costs (a major EU local authority paid EUR 1.500 in 2021 and it 
is expected to pay EUR 7.500 in 2022). 

2.  Costs 

  One-off costs to adapt to the new registration system and the single digital entry 

point 

161 Data about costs related to the gathering of STR data by different means has been requested to public 
authorities, who have not been able to quantify these costs. 
162 It can be assumed that at least 25 Member States would need to adjust to comply with the single digital 
entry point requirements. 
163 This information has been provided by a major EU city (local authority), and was anonymised as the 
data provided is confidential. 

42 

 
 
                                                           
The number of public authorities that will implement the provisions will vary based on 
their  present  or  future  appetite  for  data  on  STR  activity.  We  can  estimate  that,  at  the 
moment,  there  is  interest  for  data  in  at  least  one  locality  (big  city)  in  25  of  the  27 
Member  States  of  the  European  Union.  This  number  is  calculated  taking  into  account 
that in 22 Member States some kind of registration scheme is present – at least in one 
locality  in  their  territory  and  other  3  Member  States  have  introduced  market  access 
restrictions and they are planning to move towards taking additional measures including 
the creation of registration schemes. 

  Costs  per  national  authority  for  setting  up  an  IT  infrastructure  including  API 
connection,  as  well  as  yearly  costs  for  hosting  and  maintenance  are  similar  to 
those  described  in  option  1.  National  authorities  are  expected  to  have  one-off 
administrative  costs  estimated  at  around  EUR  3  million  to  setup  the 
infrastructure for the registration schemes and develop the national single digital 
entry point. Additionally, a yearly cost for hosting and maintenance is calculated 
to be around EUR 96 000 for each Member State, for a cumulative cost of EUR 
2.4 million per year164.  

  Costs for local/regional authorities to connect to the single digital entry point 

It  is  expected  that  local  authorities  will  connect  their  systems  to  the  national  one  in 
order  to  retrieve  data  from  online  platforms.  The  assumption  is  that  (at  least)  local 
authorities  with  already  a  system  for  a  registration  scheme  in  place  will  develop  such 
connections. In line with Option 1, we can assume that 100 local authorities within the 
25 Member States have already a system in place and at least 100 will develop a new 
one (in total at least 200165 local authorities within the 25 Member States). The 100 local 
authorities  that  have  already  a  system  in  place  will  therefore  save  ~80%  of  the  costs 
estimated for both the creation and  yearly maintenance of a new system and the other 
100 local  authorities  will face the whole cost  of  setting up the connection with  the  IT 
infrastructure created by national authorities, which are estimated at EUR 30 000166 and 
yearly maintenance costs at EUR 36 000. It is possible to foresee a cumulative one-off 
cost  for local  authorities of  around 3.6 million.  Additionally, a cumulative  yearly  cost 
for hosting and maintenance is estimated to be around EUR 4.3 million. 

Impacts on hosts:  

As the sharing of identification and activity data shall become consistent and reliable for 
all hosts and online platforms in all areas interested in data, the benefits under option 2 
will  materialise  in  a  more  systematic  manner  in  those  areas.  Considering  a  scenario 
based on the status quo, it is expected that all areas where there is already an interest in 
data will use the framework set by provisions in policy option 2. 

164 As in PO1, the cost per national authority for setting up an IT infrastructure including API connection 
is  estimated  to  be  in  a  range  between  EUR  150.000  and  EUR  190.000.  Yearly  costs  for  hosting  and 
maintenance have been identified respectively to around EUR 60.000 and EUR 35.000. These costs could 
be reduced by 30% if existing IT infrastructure is being re-used. See Annex 4, section 4.4.2, Table 12 – 
Costs for National Public Administrations for coordination under option 2 
165 Inference based on the Airbnb mapping mentioned in the previous note. 

166 See Annex 4, Section 4.4 - Table 5 Costs estimations (ROM) for APIs (data push and pull). 

43 

 
 
                                                           
1.  Benefits 

  Savings in the time spent to complete registration procedures 

There will be a marginal impact on hosts who are already subject to similar obligations, 
as it is expected public authorities will only request the data that is missing to have the 
minimum set of data required in the EU template and reuse the data already provided by 
hosts. Thanks to the provisions on a minimum, easy registration process, all future hosts 
in  all  areas  should  benefit  from  a  more  user-friendly  and  fast  registration  process  in 
order to obtain a registration number and start to offer accommodation STR services. 

In line with Option 1 and taking as a benchmark the most efficient and fast systems in 
place  in  the  EU,  it  can  be  estimated  that  the  waiting  time  for  the  hosts  to  complete  a 
registration process  will  be reduced  from  15 days to  between  1.4  and 1.7 days. When 
translated  into  the  monetisation  of  the  time,  hosts  are  expected  to  benefit  from  the 
reduction of around EUR 3000167 to around 320 EUR per new registration (based on the 
average  hourly  wage)  168.  Taking  into  consideration  that  25  Member  States  will  be 
adopting  the  data  sharing  framework  and  for  the  cost  considerations  made  above,  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  (based  on 
baseline number of 2019 and growth rate estimations)169. Based on the assumption that 
87% of the hosts  are peers170 and 13% professional  hosts, the cumulative cost  savings 
for  citizens  over  five  years  are  estimated  at  around  EUR  1287.6  million  and  for 
professional hosts at around EUR 192.4 million. 

  More proportionate other STR rules 

As  expressed  in  the  previous  section,  a  medium/long-term  positive  effect  for  hosts 
expected is the higher probability of more proportionate rules on STRs issued by public 
authorities, with a higher probability of realisation with respect option 1.  

2.  Costs 

As stated before, the estimated monetisation of the time hosts are expected to dedicate 
to a new registration is around EUR 320. We assume that 50% of the hosts will need to 
register ex novo and the other 50% will need to (eventually) adjust the info they already 
provided,  which  in  line  with  Option  1  will  not  cost  more  than  ~30%  of  a  new 
registration.  Considering  the  number  of  the  hosts  in  the  above-mentioned  25  Member 
States, it is expected one off administrative costs of around EUR 112.4 million for them 
and cumulative  yearly  administrative costs over a period of five  years of around EUR 
171.3  million.171 Based  on  the  assumption  that  87%  of  the  hosts  are  peers172 and 13% 

167 See Annex 4, Section 4.1 – Table 2 Costs for Hosts’ registration in the baseline scenario. 
168 See Annex 4, Section 4.4 - Table 7 Cost estimation for registration for hosts. 
169 It is assumed that 540.649 hosts  will be  impacted in the first  year after implementation and 535.476 
over the next 5 years. For details see Annex 4, Section 4.4.2 – Table 16 (Savings for Hosts under option 
2) and Section 4.1- Table 2 (Costs for hosts’ registration in the baseline scenario).  
170 Hosts having max 2 listings. 
171 See Annex 4, 4.5.2 - Table 14 Costs for hosts for new/adjusted registration. 

44 

 
 
 
                                                           
professional  hosts,  the  cumulative  administrative  costs  for  citizens  over  five  years  are 
estimated  at  around  EUR  149  million  and  for  professional  hosts  at  around  EUR  22.3 
million. 

Impacts on Tourism Ecosystem and other accommodation service providers: 

The  same  types  of  impacts  as  described  under  option  1  would  apply,  with  a  wider 
benefit  expected  overall  as  the  number  of  public  authorities  putting  in  place  the 
framework would be higher than under option 1. More data would be available for the 
tourism data space which could allow for e.g. for more innovative services.  

Social impacts: 

Social  impacts  are  expected  to  be  similar  to  those  described  in  option  1,  but  are 
expected  to  be  more  probable  and  more  important,  given  that  a  consistent  data 
framework would be in place in all areas in the EU where STR is currently an issue. It is 
however not possible to quantify the impacts, as social impacts would largely depend on 
what  authorities  would  do  with  the  data.  In  addition,  better  rules  on  data  sharing  are 
expected to have a positive impact on respect for privacy (see under option 1).  

Environmental impacts:  

Environmental impacts are expected to be similar to those described in option 1, but are 
expected  to  be  more  probable  and  more  important,  given  that  a  consistent  data 
framework  would  be  in  place  in  all  areas  in  the  EU  where  STR  is  currently  an  issue. 
However,  it  is  not  possible  to  quantify  those  impacts  as  explained  above,  as  impacts 
would only materialize where public authorities make use of the data collected to design 
green policies. 

Stakeholders’  views  on  policy  option  2173:  all  stakeholders  support  in  substance  the 
measures put forward under this option (similarly to option 1 and option 3). The public 
consultation  show  that  respondents,  in  particular  public  authorities,  local  associations 
and representatives of the tourism industry, are in favour of requiring online platforms 
to  share  data  on  STRs  with  public  authorities  to  increase  transparency  and  facilitate 
public policy and enforcement activities. The majority of respondents also consider that 
such measures should be put in place and/or facilitated at EU level.174Public authorities 
are strongly in  favour of this  option, compared to the other options, as  it leaves  some 
flexibility to Member States and local authorities to regulate, taking into account local 
preferences  and  needs,  both  in  terms  of  data  needs  and  data  sharing  requirements. 
Online platforms, in turn, are usually in favour of a more harmonised approach to data 
sharing, avoiding fragmentation  notably of registration obligations which they need to 
enforce by enabling the display of registration numbers. 

172 Peers are considered hosts having maximum 2 listings. See Annex 5 – Table 10 Number of listings per 
Airbnb hosts. 
173 Based on the feedback received during the consultation process, including the public consultation, the 
workshops, the targeted surveys, bilateral meetings with and ad hoc submissions from the stakeholders. 
See Annex 2 for more information. 
174 See Figure 11 in Annex 2 for a detailed assessment of replies from stakeholders on this point.  

45 

 
 
                                                                                                                                                                          
6.3 POLICY  OPTION  3  -  LEGISLATIVE  INITIATIVE  CONTAINING  A  COMMON 
APPROACH  TO  DATA  GENERATION  AND  DATA  SHARING,  WITH  MANDATORY 
NATIONAL REGISTRATION SCHEMES FOR ALL HOSTS 

Option  3  foresees  the  obligation  for  all  hosts  in  the  EU  to  register  in  national 
registration  schemes.  Public  authorities  and  hosts  are  the  stakeholders  that  will  be 
directly affected compared to option 2. Online platforms will also be further impacted, 
but only marginally. 

Economic impacts: 

Impacts on online platforms:  

1.  Benefits 

On  a  general  level,  the  types  of  impacts  on  online  platforms  are  similar  to  option  2. 
Online  platforms  would  slightly  gain  in  terms  of  efficiency,  as  diverging  local  and 
regional  registration  systems  for  hosts  would  be  replaced  by  national  ones,  making  it 
also easier for platform to track what systems exist and which requirements their hosts 
need  to  comply  with.  However,  while  online  platforms  would  have  to  share  the  same 
type of data with public authorities, they would have to share a higher volume of data, 
namely data regarding all hosts in the EU (compared to data on hosts for selected public 
authorities  under  option  2).  Similar  to  option  2,  small  and  micro-enterprise  online 
platforms with average monthly active hosts equal or lower to 1000 will benefit greatly 
from  the  possibility  to  use  adapted  reporting  obligations  (every  three  months,  and 
manually, rather than weekly and automated for bigger online platforms). 

On  this  basis  and  in  line  with  the  calculations  under  Option  2,  it  is  estimated  that  net 
savings for online platforms over a period of 5 years will amount between around EUR 
36.3 million and EUR 97.3 million (baseline costs related to data requests from public 
authorities  minus  one-off  costs  of  EUR  8.2  million  and  yearly  maintenance 
(administrative) costs of EUR 2 million175). Similarly to Option 2, for online platforms 
that would qualify for the more lenient reporting obligations, the data available doesn’t 
enable to  quantify the exact  number of data  requests they receive and the related  cost 
savings.  However,  a  single  data  request  might  currently  cost  EUR  13  549  to  process, 
which is significantly higher than the estimated cost of the adapted reporting obligations 
(around EUR 600 for each reporting activity per small and micro-platform or EUR 2400 
per year)176. 

2.  Costs 

Specifically on the cost structure, it will follow exactly what has been discussed in the 
previous section of Option 2177. One-off costs associated with data reporting for online 

175 In the cost calculations, it is  assumed that 30 companies (the top 60% of the biggest platforms)  will 
need to connect to single digital entry points through APIs as some of the online platforms might qualify 
for the option with the more lenient reporting obligations. See Annex 4, Section 4.1 & 4.2. 
176 See Annex 4, 4.4 - Table 6 Costs estimations – Option with more lenient reporting obligations. 
177  Cost  of  creating  one  connection  between  an  online  platform  and  a  single  digital  entry  point  is 
estimated at around EUR 30.000 with a yearly maintenance costs at EUR 36.000. For an intermediary that 
operates  in  more  than  one  country,  once  the  first  connection  to  a  national  single  digital  entry  point  is 

46 

 
 
                                                           
 
platforms 178 under  this  option  are  estimated  around  EUR  8.2  million,  while  annual 
administrative costs would be of around EUR 2 million. For small and micro-enterprises 
with average monthly active hosts equal or lower to 1000 and based on the estimation 
that 680 online platforms would qualify for the more lenient reporting requirements179, 
there  is  only  a  yearly  cumulative  reporting  (administrative)  cost  of  around  EUR  1.6 
million (EUR 2400 per year per online platform that would qualify for the more lenient 
reporting obligations). 

Impacts on public authorities: 

1.  Benefits 

Benefits are expected to be the same as under option 2.  

2.  Costs 

Costs  are  expected  to  be  of  the  same  nature  as  under  option  2.  However,  in  Member 
States  where  registration  schemes  already  exist  at  local  or  regional  level,  national 
authorities  will  have  to  centralise  these  registration  schemes  at  the  national  level. 
Important adjustment costs are therefore foreseen for Member States where registration 
schemes already exist at local or regional level.  

In  addition,  all  27  Member  States  will  have  to  create  a  single  digital  entry  point,  and 
adapt/create ex-novo a centralised national registration scheme as well as the needed IT 
infrastructure,  including  the  APIs  predisposition.  We  assume  that  20  Member  States 
will create a new system  (IT infrastructure costs  at  around EUR 170.000 per Member 
State) and cost savings (30%) will apply only to 7 Member States that already have in 
place some form of IT infrastructure at national level180. Therefore, for the setting up of 
the systems in the 27 Member States, a total one -off cost of around EUR 3.6 million is 
expected  to  set  up  the  IT  infrastructure  at  national  level.  Additionally,  a  yearly 
administrative  cost  for  hosting  and  maintenance  as  under  option  2  is  calculated  at 
around EUR 96.000 for each Member State181.  

It is expected that local authorities would develop automated connections to the single 
digital  entry  point  in  order  to  receive  activity  data,  linked  with  the  (newly  created) 
registration  scheme  at  national  level.  It  can  be  assumed  that  at  least  220 182  local 
authorities within the 27 Member States will develop a new system or adapt an old one. 
In  line  with  option  1  and  2,  it  is  possible  to  assume  that  100  of  the  urban/local  areas 
opting in in the system have already a system in place (45% of the 220) and therefore 
will save ~80% of the costs estimated for the creation of a new system. The other  120 

developed,  a  20%  extra  cost  should  be  considered  for  each  additional  connection  with  a  single  digital 
entry point of other Member States. 
178 In the cost calculations, it is  assumed that 30 companies (the top 60% of the biggest platforms)  will 
need to connect to single digital entry points through APIs as some of the online platforms might qualify 
for the option with more lenient reporting obligations. See Annex 4, Section 4.1 & 4.2. 
179 See Annex 4, 4.1 - Table 1 Number of hosts and platforms. 
180 See Annex 4, 4.5.3, Table 17 – Costs for National Public Administrations under Option 3 
181 Calculations  are  based  on  the  same  assumptions  with  option  2  with  the  main  difference  being  the 
number of impacted Member States (27 under option 3 instead of 25 under option 2). 
182 Inference based on the Airbnb mapping mentioned in the previous note. 

47 

 
 
                                                                                                                                                                          
(55%  of  the  220)  of  the  urban/local  areas  will  face  the  whole  cost  of  setting  up  (of 
around 30.000 EUR for APIs development). It is possible to foresee a cumulative one-
off  cost  for  local  public  authorities  at  around  EUR  4.3  million.  Additionally,  a  yearly 
cost for hosting and maintenance is calculated to be around EUR 5.2 million. 

Impacts on hosts: 

The  same  types  of  impacts  as  under  option  2  apply.  However,  the  impacts  will  affect 
(positively and negatively) all hosts in the EU, rather than only hosts in areas putting in 
place the framework. Hosts that had not been subject to any kind of registration before 
will pay the full cost of registration estimated. 

1.  Benefits 

In  line  with  options  1  and  2  and  taking  as  a  benchmark  the  most  efficient  and  fast 
systems  in  place  in  the  EU,  it  can  be  estimated  that  the  waiting  time  for  the  hosts  to 
complete a registration process will be between 1.4 and 1.7 days across all 27 Member 
States (around 320 EUR per new registration based on the monetisation of an average 
hourly wage) 183.The cost savings are expected to be similar as in Option 2184. Option 3 
introduces registration schemes in all 27 Member States, covering all local authorities, 
including the ones not having any intention to do so (e.g. small communities in Member 
States  that  have  no  intention  to  register  or  regulate  STRs)  so  creating  additional 
registration costs for hosts that would probably never need to register. 

2.  Costs 

Costs  associated  with  hosts  follows  the  same  reasoning  of  option  2.  Under  option  3, 
however, all hosts will be subject to the same obligation to register. Hosts in Europe that 
had not be subject to any kind of registration before will  incur full cost of registration 
estimated (i.e. 320 EUR). The total one-off costs for hosts will be at around EUR 376.6 
million. This estimation takes into account the total number of hosts in the EU and that 
the majority of the hosts will need to perform a new registration (i.e. all hosts in 2 MSs 
and 80% of all hosts in the remaining 25 MSs) as well as the hosts who would need to 
adapt  their  actual  registration  to  the  new  template  (20%  of  hosts  in  25  MSs  already 
subject  to  some  form  of  registration).  This  means  that  compared  to  Option  2,  as  the 
registration is obligatory across all 27 Member States, around 825 683 additional hosts 
would  need  to  register  under  Option  3,  with  an  estimated  one-off  cost  of  EUR  264.2 
million.  Additional  yearly  administrative  costs  for  the  next  5  years  after  the 
implementation of the provisions foreseen by option 3 are estimated to be around EUR 
438.4 million for new hosts that will be starting their activities (hence need to register in 
those  areas) 185.  Based  on  the  assumption  that  87%  of  the  hosts  are  peers186 and  13% 
professional hosts, the one off administrative costs for citizens (peers) are estimated at 

183 See Annex 4, Section 4.4 - Table 7 Cost estimation for registration for hosts. 
184The difference in number of local authorities interested in the data on STRs is assumed to be marginal 
compared to option 2 i.e. 20 additional local authorities from 2 MS. 
185 See Annex 4, 4.3 - Table 19 Costs for hosts for new/adjusted registration. 
186 We assume that hosts having max 2 listings are citizens. 

48 

 
 
                                                           
around EUR 327.14 million and cumulative yearly administrative costs over a period of 
five years at around EUR 381.4 million.187 

Impacts on Tourism Ecosystem and other accommodation service providers: 

The  same  types  of  impacts  as  under  option  2  apply.  However,  the  magnitude  of  the 
impacts  are  much  wider  as  data  will  be  available  on  all  hosts  in  the  EU.  If  public 
authorities make the data available at aggregate level, for e.g. through the future tourism 
data space, players in the tourism ecosystem will have more predictability of the market. 
Local communities could also potentially enjoy the complete data availability. 

Social impacts: 

The  indirect  impacts  on  society  will  be  more  consistent  and  structural  compared  to 
option 1. However, less positive impacts on the society are expected under option 3 as 
this option reduces the regulatory freedom of local and regional authorities to maintain 
their  own  registration  requirements  and  decide  on  the  type  of  data  they  would  like  to 
request  from  hosts and  online  platforms. As for fundamental  rights,  the same types of 
impacts as under option 2 apply, but such impacts will apply more widely to all hosts.  

Environmental impacts: 

With  a  global  picture  on  the  STR  activity  on  their  territory,  public  authorities  will  be 
able  to  better  address  the  negative  externalities  of  STRs  impacting  the  environment. 
However,  as  also  mentioned  above,  national  registration  schemes  might  reduce  the 
scope for specific local and/or regional actions to promote sustainability (e.g., the scope 
for requiring the submission of additional certificates etc.) 

Stakeholders’  views  on  policy  option  3188:  this  option  is  mainly  supported  by  online 
platforms,  for  whom  a  full  harmonisation  of  registration  requirements,  obligations  to 
enable the display of registration numbers and data sharing obligations will substantially 
decrease  compliance  costs.  While  hosts  stand  to  benefit  from  more  proportionate 
registration  schemes  and  STR  rules  in  general,  they  are  not  necessarily  in  favour  of 
more  administrative  burden  (registration  obligations)  from  the  outset.  Finally,  public 
authorities have stressed the need for any regulatory intervention to respect subsidiarity, 
and  are  therefore  not  in  favour  a  full  harmonisation  at  EU  level,  but  would  rather 
welcome more flexibility to implement the framework where it is really needed. 

7.  HOW DO THE OPTIONS COMPARE?  

Table 1 - Policy objectives and policy options 

Options 

Reduce the burden on 
online platforms of STR 
data collection and 
sharing, and avoid 
fragmentation of these 
transparency requirements 

Ensure that public 
authorities have the tools 
they need to gather data 
for policy making and 
enforcement of STR rules 

187 See Annex 5.2, - Table 12 - Number of listings per Airbnb hosts. 
188 Based on the feedback received during the consultation process. See Annex 2 for more information. 

49 

 
 
                                                           
across the EU 

Option 1 – soft approach 

+ (if implemented) 

+ (if implemented) 

Option 2 – Regulation voluntary opt-in 

Option 3 – Regulation All-hosts-in  

+++ 

+++ 

+++ 

+++ 

Legend: +- almost no impact; + reduced positive impact; ++ positive impact; +++ significant positive 
impact; - minor negative impact; -- negative impact; --- significant negative impact; +/- mixed impacts. 

The  options  that  allow  meeting  the  policy  objectives  best  are  those  relying  on  a 
legislative approach. In both Options 2 and 3, public authorities will have the possibility 
to retrieve data and online platforms will gain certainty on how to share data. With the 
flexibility to opt-in, Option 2 makes sure that public authorities with  immediate needs 
get  the  data  while  under  Option  3  public  authorities  will  have  data  on  all  hosts,  even 
where there is not an immediate need for data. 

Table 2 – Cost and benefits of policy options for key stakeholders 

Options 

MSs 

Local 
Public 
authorities 

Hosts 

Online 
Platforms 

Option 1 – Soft approach 

Option 2 – Regulation voluntary opt-in 

Option 3 – Regulation All-hosts- 

+ 

++ 

++ 

+ 

+++ 

++ 

+ 

++ 

+/- 

+ 

+++ 

++ 

Legend: +- almost no impact; + reduced positive impact; ++ positive impact; +++ significant positive 
impact; - minor negative impact; -- negative impact; --- significant negative impact; +/- mixed impacts. 

The  cost-benefits  ratio  as  a  whole  is  the  best  where  flexibility  is  provided  to  public 
authorities to opt in. Public authorities will incur costs only where there is a real need 
for  data  –  hence  a  potential  big  benefit  in  using  data  and  better  assess  STR  related 
issues.  Option  3  will  provide  data  to  all  public  authorities,  including  those  not  asking 
(yet) for data. Only in the medium/long term will the benefits for public administrations 
exceed the initial costs they will face to comply with Option 3. For hosts, Option 3 will 
have  mixed  effects  since  all  hosts  in  EU  will  have  to  register,  even  where  public 
authorities  do  not  need  data,  therefore  creating  additional  unnecessary  costs  for  such 
players.  However,  hosts  will  benefit  in  the  medium/long  term  from  preventive 
assessment of externalities linked with STR activity, avoiding undifferentiated policies 
for STR activity.  

Table 3 - Comparison of policy options 

Options 

Effectiveness 

Efficiency 

Proportionality  

50 

 
 
Option 1 – Soft approach 

Option 2 – Regulation voluntary opt-in 

Option 3 – Regulation all-hosts-in  

+ 

+++ 

+++ 

+ 

+++ 

+ 

++ 

+++ 

+ 

Legend: +- almost no impact; + reduced positive impact; ++ positive impact; +++ significant positive 
impact; - minor negative impact; -- negative impact; --- significant negative impact; +/- mixed impacts. 

The key difference in terms of effectiveness between the 3 options lies in a legislative 
approach  imposing  obligations  on  stakeholders,  as  foreseen  under  Options  2  and  3.  
Options  2  and  3  are  the  most  effective  as  they  reduce  the  burden  on  platforms  and 
ensure that public authorities have tools to get the STR data.  

When  it  comes  to  efficiency,  the  impacts  differ.  The  most  efficient  option  is  the  one 
where the flexibility of the opt-in system is provided to public authorities immediately 
interested  in  data.  Option  1  seems  less  efficient  due  to  the  voluntary  nature  of  the 
measures,  and  the  efficiency  of  Option  3  is  reduced  at  EU  level  as  it  imposes  an 
obligation even on public authorities not interested in data. 

Finally,  with  regards  to  proportionality  Option  2  scores  the  best,  as  it  takes  the 
preferences of local authorities into account, in full respect of the subsidiarity principle. 
Some  liberty  is  also  achieved  with  Option  1,  but  the  possible  lack  of  collaboration  of 
online platform reduces the overall proportionality of this option. Option 3 seems to be 
the least proportionate as it imposes obligations on all Member States even though they 
might not have any needs for STR data.  

Table 4 - Impact of policy options 

Options 

Economic 

Social 

Environmental 

Option 1 – Soft approach 

Option 2 – Regulation voluntary opt-in 

Option 3 – Regulation All-hosts-in  

+ 

+++ 

+ 

+ 

++ 

+ 

(+/-) 

(+/-) 

(+/-) 

Legend: +- almost no impact; + reduced positive impact;  ++ positive impact; +++ significant positive 
impact; - minor negative impact; -- negative impact; --- significant negative impact; +/- mixed impacts. 

Summarising  how  the  three  options  compare  under  the  economic,  social  and 
environmental impacts, Option 2 seems to maximise the general positive impacts on the 
three levels. The reasoning for each option is developed in chapter 6. 

 Table 5 - Support of stakeholders to policy options 

Options 

MSs 

Local 
Public 
authorities 

Hosts 

Online 
Platforms 

Option 1 – Soft approach 

+ 

+ 

+ 

+ 

51 

 
 
Option 2 – Regulation voluntary opt-in 

Option 3 – Regulation all-hosts-in  

++ 
- 

+++ 
-- 

++(+) 
++(-) 

+++ 
// 

Legend: --- completely adverse; -- not in favour; - not so in favour; +- neutral; + marginally in favour; 
++ in favour; +++ significantly in favour – for a more detailed explanation, see Section 6. 

The  interactions  with  stakeholders  involved  in  the  STR  segment  and  therefore 
potentially impacted by  this initiative  show that  all of them welcome an  EU initiative 
that could streamline data sharing between online platforms and public authorities. This 
is  also  the  case  of  local  association.  Stakeholders,  however,  stressed  their  need  for 
flexibility (for public authorities, obligations only where there is a need for data) and for 
certainty (for online platforms, clarity on data set to be shared and tools to be used; for 
public authorities: clarity of the legal basis for data requests and consistent enforcement 
of  their  rules).  Hosts  favour  simplified  registration  but  only  in  areas  where  this  is 
considered necessary.  

8.  PREFERRED OPTION 

8.1 PREFERRED POLICY OPTION  

Option 1 does not ensure that the burden on platforms and access to data will be 
adequately addressed. It will only lead to improvements in some areas and only between 
limited  online  platforms  and  public  authorities.  This  option,  as  voluntary,  is  heavily 
reliant on cooperation and the good will of those making commitments and abiding by 
them and lacks any means of enforcement to make the more effective. This option will 
provide  little  or  no  improvement  in  addressing  the  problems  faced  by  platforms  with 
burdensome requests and public authorities for data.  

Option  2  does  meet  the  objectives  in  a  flexible  and  proportionate  way.  It  would 
provide  a  clear  and  coherent  framework  for  data  access  and  sharing,  which  provides 
detailed, traceable, interoperable and timely data in  a simple and balanced way for all 
stakeholders.  This  would  enable  better  policy-making,  greater  enforceability  of  their 
STR  rules  and  help  public  authorities  better  achieve  public  policy  objectives.  The 
burden on platforms will be significantly reduced. 

Option  3  would  provide  an  effective  data  sharing  framework  across  the  EU,  but 
requires  high  adjustment  costs  for  authorities,  whilst  reducing  possibilities  to 
address  specific  concerns  at  local  and/or  regional  level.  This  option  ensures  full 
transparency on the STR segment in  the EU, including  in  areas  where data are not  of 
interest  for  public  authorities.  As  one  registration  system  will  be  created  at  national 
level  in  each  Member  State,  local  and  regional  authorities  would  not  incur  any  direct 
costs, but Member States who are not currently interested in STR data would incur costs 
regardless  of  their  preferences.  The  costs  on  hosts  across  the  EU  would  also  be 
increased, as all hosts in the EU would be required to register. Additional benefits will 
be  reached  in  the  medium/long-term,  since  public  authorities  will  be  given  the  right 
tools to have full transparency and assess in advance negative and positive externalities 
linked with STR activity. 

The preferred option is therefore,  Option 2. It addresses the specific objectives in a 
consistent, proportionate, effective and efficient way across the  areas in the EU where 

52 

 
 
main problems are de facto present. It ensures the use or adaptation of existing national 
and regional registration schemes and IT infrastructures (if any). It optimises costs and 
preserves  the  ability  for  public  authorities  to  set  the  data-sharing  framework  in 
compliance with the principles  of subsidiarity and proportionality. The principle of 
subsidiarity is respected. Member States are not able to address  alone the issues faced 
by  online  platforms  operating  cross-border.  It  is  also  respected  by  giving  local  and 
regional  authorities  flexibility  with  regards  to  the  implementation  of  registration 
schemes (whether to introduce them or not, and at which level), but also with regards to 
the information and evidence that each authority can request from hosts, to ensure that 
local  circumstances  and  needs  are  respected  and  taken  into  account.  The  measures 
proposed  also  strike  a  balance  between  the  interests  of  all  stakeholders  involved,  by 
requiring  action  from  public  authorities,  hosts  and  online  platforms,  and  offering 
benefits to these actors, ensuring the proportionality of the foreseen intervention.  

It also contributes to the fulfilment of the Sustainable Development Goals, in particular 
SDG 11 (sustainable cities and communities), by giving public authorities the tools and 
the data to regulate the STR sector in a proportionate and sustainable way. 

8.2 REFIT (SIMPLIFICATION AND IMPROVED EFFICIENCY) 

REFIT section is not applicable to this proposal.  

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will monitor the implementation, the application and the compliance 
to the new system a view to assessing its effectiveness. To do so, it will work together 
with the Member States. For instance, it intends to assess whether the rules effectively 
lead to better quality data for public authorities, based on registration schemes for hosts 
and data sharing rules for platforms that are effectively complied with. 

After  the  adoption,  a  transitional  period  of  2  years  will  be  given  to  Member  States  to 
map  the  interested  local  authorities,  create  or  adapt  local/national  existing  registration 
systems (connecting local registration schemes, if any) and set up the IT infrastructure 
at  national  level  to  streamline  data-sharing  with  online  platforms  (through  the  single 
digital  entry  point).  The  first  evaluation  should  take  place  not  earlier  than  five  years 
after the full implementation of the Regulation (i.e., five years after the initial first two 
years which will be the transition period). The general effectiveness will be monitored 
based (but not solely) on the set of KPIs identified in Table 6 below. 

Table 6 – Key Performance Indicators for the evaluation of the implemented measure 

Indicator  

Definition / Objective 

Baseline 

Data Source 

Reported  mapping  of 
Public 
authorities 
adopting provisions in y1 
and y3. 

Data 
generated 
national authorities 

by 

∆ of local authorities 
opting in y5 vs y3 (vs 
y1)  

of 

Number 
local 
authorities  deciding  to 
use  the  provisions  for 
data-sharing / Objective: 
(growing) 
monitor 
the 
local 
interest 
authorities 
data. 
Expected  result:  higher 

of 
for 

53 

 
 
# of registered hosts  

(Absolute number) 

%  of  total  data  volume 
through  APIs 
shared 
(Percentage 
total 
of 
Data volumes) 

illegal 

#  of 
identified  

listings 

(Absolute number) 

Use  of  data  by  other 
STR  players  (Absolute 
number) 

Previously 
volumes 
year of adoption) 

(by 

estimated 
country, 

number  of  local  public 
authorities 
in  y5  with 
respect y3, ∆+. 

of 

hosts 
Number 
registered  by  country  / 
Objective: verify the ease 
and  friendliness  of  the 
registration  scheme  with 
the 
Template. 
Expected  result:  higher 
hosts 
number 
respect 
registered  with 
the forecasted numbers 

EU 

of 

N/A 

N/A 

N/A 

Use of APIs as % of the 
total  data  shared  by 
online 
/ 
platforms 
Objective:  monitor 
the 
good  implementation  of 
the  alternative  reporting 
for  small  and 
system 
micro 
enterprises. 
Expected  result:  volumes 
of  data  shared  through 
reporting 
alternative 
system 
be 
marginal 

should 

Number  of  listings  not 
compliant 
with 
local/national STR rules 
(per  year,  per  MS)  / 
verify 
Objective: 
effectiveness 
data 
sharing.  Expected  result: 
higher  number  than  the 
public  authorities  (easy 
sharing and accessibility) 

of 

Number of download by 
non-PAs  requesters 
/ 
Objective:  monitor 
the 
use  and  exploit  of  new 
data  on  STR  segment. 
Expected value: n/a. 

Legend: # number, % percentage, ∆% percentage difference 

54 

generated 
Data 
national authorities 

by 

Statistical 
reporting 
authorities 

operational  
national 

by 

Proxy:  Notification  sent 
by  Public 
authorities 
(possibly  through  single 
digital entry point) 

Statistical 
reporting 
SDEP 

operational  
national 

by 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, DEcide Planning/CWP references 

Lead DG: DG Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) 

Directorate: G - Ecosystems II: Tourism & proximity 

Decide  number  of  the  underlying  initiative:  PLAN/2021/11047  (Short-term  rental 
initiative) 

2.  Organisation and timing 

The inception impact assessment was published on 16 September 2021. It was followed 
by  a  feedback  period  that  lasted  from  16  September  2021  to  14  October  2021.  71 
stakeholder feedbacks were received. 

The  Commission  held  a  public  consultation  from  27  September  until  13  December 
2021. This consultation  was available on the  Have  your  say portal and open to anyone 
who wished to reply. The public consultation received 5696 stakeholder feedbacks. The 
Commission launched two additional targeted EU surveys in April 2022: the first one to 
public  authorities,  for  which  it  received  80  replies,  and  the  second  one  to  online 
platforms,  for  which  it  received  15  replies.  The  results  of  the  targeted  surveys  are 
presented in Annex 2a and Annex 2b. 

The following DGs (Directorates General) have been invited to contribute to this impact 
assessment: SG (Secretariat-General), CLIMA (Climate Action), COMP (Competition), 
CNECT  (Communications  Networks,  Content  and  Technology),  DIGIT  (Informatics), 
ECFIN  (Economic  and  Financial  Affairs),  EMPL  (Employment,  Social  Affairs  & 
Inclusion), ENV (Environment), ESTAT (Eurostat), JRC (Joint Research Centre), JUST 
(Justice  and  Consumers),  REGIO  (Regional  and  Urban  Policy),  MOVE  (Mobility  and 
Transport),  SJ  (Legal  Service),  TAXUD  (Taxation  and  Customs  Union)  and  TRADE 
(Trade).  

The  ISSG  met  three  times  in  2021  (15  July,  25  October,  15  December)  to  give  an 
update on the ongoing work and discuss preliminary versions of the Impact Assessment 
report, together with all the supporting documents. The final ISSG meeting took place 
on  14  January  2022.  Following  the  negative  opinion  of  the  RSB,  an  additional  ISSG 
meeting took place on 14 June 2022 to discuss the revised impact assessment. 

3.  Consultation of the RSB 

The  RSB  was  consulted  in  an  upfront  meeting  on  15  November  2021.  The  impact 
assessment  report  was  submitted  to  the  RSB  on  19  January  2022.  The  impact 
assessment  was  discussed  with  the  RSB  on  16  February  2022,  and  the  RSB  issued  a 
negative opinion on 18 February 2022. Based on the RSB recommendations, the impact 
assessment has been significantly revised in accordance with the following points: 

55 

 
 
 
 
RSB Recommendations 

Revisions introduced 

(B) Summary of findings 

(1)  The  problem  definition  and  its  scope  are  not 
precisely  defined.  The  report  does  not  provide 
sufficient evidence to substantiate the problems. It 
does not demonstrate the scale of the problems. It 
does  not  clearly  delimit  the  internal  market 
dimension of the problems. 

The problem definition and scope of the initiative 
have  been  thoroughly  revised  and  are  now  more 
targeted.  The  IA  now  focuses  on  the  main 
problem,  which  relates  to  data  sharing.  This 
problem  has  a  clear  single  market  dimension,  as 
platforms  are 
increasingly  confronted  with 
diverging and burdensome data  sharing requests, 
which  hampers  their  development  in  the  single 
market.  More  evidence  and  a  better  analysis  of 
the  problems  and  the  scale  thereof  has  been 
provided,  based  on  additional 
information 
gathered through additional surveys and research. 
Chapter 2 has been entirely revised on this basis. 

to  reconcile 

(2) The report is unclear about the objectives and 
the  intervention  logic.  It  does  not  adequately 
the  objectives  of 
explain  how 
developing 
internal  STR  market  and 
promoting a sustainable tourism sector at the local 
level. It does not demonstrate the need to act at the 
EU level. 

the 

logic,  showing 

the  objectives  and 
the  direct 

The  objectives  and  intervention  logic  have  been 
thoroughly revised and are now more targeted. A 
the 
new  description  of 
intervention 
link 
between the problems and proposed measures, is 
presented  in  Chapters  4  and  5  in  particular. 
the 
Chapter  4  now  also  makes  clear 
initiatives  aims  to  promote  sustainable  tourism, 
by  improving  data  generation  and  data  sharing.  
Chapters 2, 3 and 5 clarify that only action at the 
EU  level  will  achieve  effective  and  efficient 
results in terms of data sharing. 

that 

(3)  The  report  does  not  sufficiently  explore  less 
ambitious  and  more  flexible  alternatives  focusing 
on  key  issues.  It  does  not  demonstrate  the 
proportionality of the preferred policy option. 

The  three  policy  options  have  been  revised  and 
clarified  and  vary  from  a  less  ambitious  and 
flexible policy option to a more ambitious policy 
option  with  more  harmonisation.  This  is  now 
better reflected in Chapter 5. The preferred option 
is  now  option  2,  and  the  proportionality  of  the 
preferred  option  is  explained  in  section  6.2.,  7 
and 8. The proportionality framework for market 
access restrictions for hosts, which was promoted 
in the previous IA, has now been discarded, with 
an  indication  of  the  reasons  why,  in  Chapter  5, 
section 5.3. 

(4)  The  report  does  not  assess  the  potential 
impacts  of  the  initiative  on  local  communities, 
society and the environment. 

Potential  social  and  environmental  impacts  of 
each  policy  options  are 
identified  and  an 
assessment is provided in Chapter 6. 

(C) What to improve 

56 

 
 
 
 
 
(1)  The  report  should  describe  clearly 
problems and provide supporting evidence: 

the 

(e.g. 

  The  description  of  the  market  should 
include estimates of the market shares of 
including 
different  market  players, 
specific 
vs. 
peer 
segments 
professional hosts; hosts in rural areas or 
small  cities  vs.  tourist  centres;  operators 
and  platforms  offering  cross-border 
services  vs.  local  ones,  etc.),  as  well  as 
market  boundaries,  i.e.  whether  the  STR 
is  a  distinct  (relevant)  market  or  a  broad 
one 
including  all  other  alternatives 
(hotels etc.). 

  The  problem description should be  more 
precise on streamlining the core problem 
(data  gathering,  data  standardisation  and 
data 
specific 
from 
problems.  It  should  distinguish  the  main 
problems  from  the  consequences  (i.e. 
poor policy design). 

access) 

other 

  When specific problems are outlined, the 
report  should  clearly  explain  the  reasons 
behind them and which market players or 
authorities cause specific problems or are 
affected by them.  

The report clarifies that STRs are a segment and 
not  a  distinct  market.  STRs  offers  are  largely 
interchangeable  with  for  e.g.  hotels  offers  from 
the  point  of  view  of  consumers,  in  particular  for 
price reasons (demand-side substitution) (Chapter 
1).  The 
includes  additional 
information  on  the  shares  of  the  different  STRs 
players (see Chapter 1 and Annex 5).  

revised  draft 

The  problem  definition  (Chapter  2)  has  been 
streamlined.  The  initiative  addresses  only  the 
transparency issue, which was the first identified 
in the IIA and which is considered the core issue. 
The main problems are (i) the numerous requests 
for data received by online platforms and (ii) the 
insufficient  and  inefficient  data  gathering  by 
public  authorities  (see  section  2.1).  Burdensome 
market access requirements, which was identified 
in  the  IIA,  is  considered  a  consequence  of  the 
problem  of  the  lack  of  data,  although  other 
political factors can lead to disproportionate rules 
(see section 2.3). With an enhanced transparency, 
the initiative will therefore contribute to a greater 
proportionality  of  rules.  However,  the  initiative 
will  not  deal  with  proportionality  as  such,  as  it 
has to address the drivers of the core issues. 

The  report  now  describes  and  substantiates  the 
two  problems,  explaining  for  whom  this  is  a 
problem  and  what  the  problem  is  about  (section 
2.1). The drivers of these problems are explained 
in section 2.2. An assessment of the  scale of the 
problems  is  included,  building  mainly  on  the 
feedback  received  from  public  authorities  and 
from online platforms, in surveys and during the 
workshops  organised  by  the  Commission  (see 
Annex 2).  

It  should  be  clear  on  the  scale  of  the 
specific  problems 
(e.g.  number  of 
disproportionate or challenged STR rules, 
number  of  public  authorities  facing 
specific  data  needs),  differentiating  by 
region  or 
Member  States, 
significant 
agglomerate 

type  of 
in  case  of 

This  feedback  shows  that  the  vast  majority  of 
Member  States  and  different  types  of  entities 
(national, regional or local) are currently affected 
by  the  lack  of  data/need  data.  The  feedback 
shows also that an increasing number of requests 
for data, coming from a vast majority of Member 
States, affects online platforms (the big ones and 

57 

 
 
 
 
 
 
 
 
 
some  smaller  ones).  Figures  are  provided  in  the 
revised  draft  and  can  give  indications  of  the 
scale/size  of  the  problems.  The  IA  now  also 
shows  variations  between  Member  States  and 
regions  in  terms  of  data  needs.  (Section  2.1  and 
also Annex 2a and 2b). 

The IA refers in section 1.1. to these problems, to 
explain the context of the proposal. However, the 
initiative does not aim to directly tackle problems 
related  to  the  rapid  growth  of  STRs.  It  rather 
tackles problems related to transparency and data 
sharing. Problems related to STRs in certain areas 
are  an  indirect  consequence  of  the  difficulties 
cities face in designing STR rules, and enforcing 
them, both as regards platforms and hosts.  

variations. 

  The 

report  should  provide  specific 
information  on  the  problems  created  by 
the rapid growth of STRs in certain areas, 
such  as  the  increase  in  housing  prices, 
noise, congestion or waste.  

It  should,  objectively,  describe 
the 
specific  instances  where  these  problems 
occur  and  link  them  to  the  problems 
identified  (transparency,  burdensome  or 
disproportionate requirements for STRs). 

  The  report  should  be  more  precise  on 
where  cross-border  problems  exist.  It 
the 
should 
problems 
and 
disproportionality  of  requirements  on 
STRs have a single-market dimension.  

justify  why  and  where 

transparency 

of 

between 
clients 

The  discussion  on  the  occurrence  of 
cross-border  problems  should  clearly 
distinguish 
offering  STR 
from  different 
services 
countries  and  offering  STRs  located  in 
different  countries.  The  report  should 
also  provide  reliable  estimates  of  the 
incidence of these types of services. 

to 

  The  report  should  consider  other  factors 
hampering the cross-border expansion of 
the 
STRs 
proliferation  of  rules  and  assess  their 
relative importance. 

companies, 

beyond 

The  report  has  been  revised  and  underlines  the 
cross-border dimension of the transparency issue 
(offering  STR  services  is  not  addressed).  In 
particular,  online  platforms  that  are  key  players 
of the STR segment, hold comprehensive data on 
STRs.  Nearly  all  platforms  operate  cross-border 
and  interact  with  public  authorities  from  many 
Member  States.  The  overwhelming  majority  of 
platforms  –  both  big  platforms  as  well  as  SME 
platforms  –  are  also  confronted  with  a  rising 
number  of  diverging  data  requests  (Chapters  1 
and 2).  

In addition, it is also indicated that a small share 
of  hosts,  who  are  asked  to  provide  data  via 
registration  schemes,  offer  listings  in  more  than 
one Member State (Chapter 1). 

The  core  problem  addressed  by  the  report  is  the 
transparency  issue  and  not  the  cross-border 
expansion of STRs companies (see section 2.1). 

  The  report  should  explain  why  public 
authorities  are  not  able  to  get  the  data 

An additional targeted consultation was run  with 
public authorities to better explain the difficulties 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
that  they  need,  even  though  the  problem 
description  considers  that  the  frequent 
and  diverse  data  requests  by  public 
authorities  are  a  problem.  It  should 
estimate the frequency of this problem. It 
should  clarify  which  types  of  data  are 
needed  by  which  authorities  for  policy 
development and policy enforcement. 
  The report should explain why there is a 
need  for  a  specific  STR  initiative,  given 
that  STR  services  are  subject  to  the 
Services Directive. 

(2)  The  report  should  specify  the  scope  of  the 
initiative. It should explain whether it 3 focuses on 
specific  segments  such  as  cross-border  STRs, 
platforms,  professional  hosts  or  SMEs  or  on 
mitigating the social and societal impacts on local 
communities.  If  the  initiative  addresses  the  STR 
sector  in  general,  the  report  would  have  to  show 
that the problems described affect the whole STR 
sector,  and  explain  how  the  different  actors  will 
benefit from the initiative. 

reconciled  within 

(3)  The  report  should  explain  how  the  different 
objectives  would  be 
the 
initiative.  It  should  acknowledge  potential  trade-
offs between facilitating the expansion of the STR 
sector  and  the  aim  to  help  remove  the  negative 
effects  of  STR  growth  on 
local 
communities. 

some 

they  face  to  get  the  data  they  need  (and/or 
sufficiently  complete  and  accurate),  on 
the 
frequency of this problem, on their needs for data 
and  the  purposes  for  which  they  need  this  data. 
The  results  are  presented  in  Annex  2a  and 
integrated into the report (chapter 1 – section 2.2) 

the 

the  existing  EU 

that 
tools  do  not  address 

The need for an initiative on data on STR results 
legal 
the  fact 
from 
framework  or 
in  an 
appropriate  and  efficient  way  the  identified 
transparency  issues.  The  Services  Directive  does 
not  cover  transparency  issues  (see  Annex  6, 
section  6.1.1).  The  Services  Directive  mainly 
concerns 
relationship  between  public 
authorities and hosts, by requiring the former not 
to  impose  market  access  restrictions  until  such 
restrictions  are  necessary  and  proportionate.  The 
proposal  does  not  deal  with  market  access 
restrictions (the option to put in place a dedicated 
proportionality  framework  in  now  discarded  in 
Chapter  5).  It  will 
indirectly  secure  better 
compliance with the Services Directive however, 
by  ensuring  that  authorities  have  data  to  design 
appropriate  policies,  and  by  proposing  a 
streamlined  approach  to  registration  schemes 
(which provide identification data).   

The  report  clarifies  the  scope  of  the  initiative.  It 
is  a  very  targeted  scope.  It  is  about  improving 
transparency  (i.e.  data  generation  and  data 
sharing)  in  the  STR  segment.  It  addresses  well-
identified  types  of  actors  of  the  STR  segment: 
and 
public 
the 
indirectly  hosts.  The 
measures that would improve transparency in the 
STR  sector  (section  5.2)  as  well  as  the  actors 
directly  affected  by  those  measures  (see  Chapter 
6) 

platforms, 
identifies 

authorities, 

online 

report 

The  objectives  of 
initiative  have  been 
the 
streamlined  (chapter  4).  The  aim  is  to  provide 
transparency  and  give  better  data  to  public 
authorities to allow them to better manage STRs 
in  their  jurisdictions.  The  objective  is  therefore 
not  to  facilitate  the  expansion  of  the  STR  sector 
or to remove the negative effects of STR growth; 
these  objectives  are  left  to  public  authorities  (in 
full  respect  of  the  subsidiarity  principle).  As 
such, the initiative has therefore a neutral impact 

59 

 
 
on tourism (chapter 6 – sections 6.1;6.2; 6.3)  

A revised intervention logic is proposed (chapter 
5). 

this  end, 

the  problem  definition, 

(4) The intervention logic should be strengthened. 
To 
the 
description  of  the  policy  options  and  the  analysis 
of potential impacts should be more coherent. The 
report  should  clarify  how  it  addresses  all  the 
objectives of the initiative. 

(5)  The  report  should  demonstrate  with  evidence 
where  the  EU  needs  to  act  because  of  internal 
market  problems.  The  report  should  explore  less 
ambitious  and  more  proportionate  alternatives 
focusing  on  the  key  issues  identified  and  clearly 
substantiated with robust evidence.  

the 

The  report  demonstrates  the  internal  market 
dimension  of 
issue  of  transparency,  in 
particular  for  online  platforms,  which  provide 
intermediating  services  cross-border  (chapters  2 
and  3).  As  indicated,  reporting  obligations  on 
platforms  can  be  seen  as  a  restriction  to  the 
provision  of  intermediating  services,  if  they  are 
not well justified.  

It  should  consider  the  possibility  of  combining 
targeted 
legal  obligations  on  certain  market 
players (e.g. big platforms) with softer instruments 
such  as  a  Recommendation  based  on  existing 
experience and case law.  

Given the potential differences in the relevance of 
the problems in Member States, the report should 
pay  more attention  to voluntary,  gradual and opt-
in  approaches  while  avoiding  disproportionate 
conditions. 

report 

indicates  a  clear  differentiated 
The 
approach: transparency issues could be addressed 
in  a  piece  of  legislation;  while  market  access 
issues  (proportionality…)  could  be  addressed 
separately  (i.e.  not  by  the  initiative  but  by  a 
guidance…) (see chapter 5 - section 5.1). 

to 

The policy options take into account the specific 
situations in Member States. An opt-in system for 
public authorities is proposed. As a result of this 
initiative,  a  framework  for  data  on  STR  will  be 
put in place: if public authorities want data from 
online  platforms,  they  will  have  to  join  this 
framework: 
issue  a 
they  would  have 
registration  number  for  each  listing  and  connect 
to a single digital entry point at national level. If 
they  do  not  want  or  need  data,  they  will  able  to 
stay  out  of  the  system.  Depending  on  the 
administrative organisation of Member States, the 
decision  to  opt-in  could  be  made  at  national, 
regional  or  local  level  (chapter  5  -  section  5.2). 
The  requirement  to  put  in  place  registration 
schemes as a pre-condition to get data is designed 
in  a  way  that  makes  it  as  user-friendly  for  hosts 
as possible, including by allowing the latter to re-
use  part  of  their  data  in  case  of  more  than  one 
listing.  

(6) The report should elaborate the content of the 
policy  options.  In  particular,  it  should  explain 
which  criteria  will  be  used 
the 
proportionality  of  the  requirements  on  STRs  and 

to  assess 

The  content  of  the  policy  options  has  been 
streamlined to take into account the new targeted 
approach  of  the 
initiative  (chapter  5).  The 
proportionality  of  the  requirements  on  STRs  is 

60 

 
 
 
 
 
 
where they will be defined.  

The  report  should  present  additional  sub-options, 
since  there  may  be  alternative  policy  choices  as 
regards  certain  elements  of  the  policy  options, 
such as the criteria to assess proportionality or the 
type of market players affected.  

The  options  should  describe  how  compliance 
would be monitored and enforced. 

(7)  The  options  should  consider  appropriate 
mitigation  measures  for  all  types  of  SMEs  active 
in the market, not only for small platforms. 

not  part  of  the  initiative,  which  should  not  list 
criteria and where they will be defined. This issue 
requirements)  could  be 
(proportionality  of 
addressed 
the 
relating 
in  documents 
implementation of the Services Directive.  

to 

The report includes three options, with a possible 
variant  for  options  2  and  3  (chapter  5  -  section 
5.2).  The  monitoring  and  enforcement  of 
compliance  was  raised  with  regards  to  the 
proportionality  assessment,  which  is  no  longer 
considered as part of the policy options (chapter 5 
- section 5.3). 

References  to  enforcement  are  included  under 
each legislative options (chapter 5  – sections 5.2 
and 5.3). Member States shall in principle ensure 
adequate  and  effective  enforcement  of 
the 
obligations.  The  Commission  will,  as  part  of  its 
monitoring  of  the  proposal,  work  together  with 
the Member States to see whether the Regulation 
is complied with, by hosts and platforms. 

Given  the  targeted  new  approach  focussing  on 
transparency,  the  measures  do  no  longer  impact 
all types of SMEs active in the STR segment, but 
only  online  platforms  and  hosts.  Specific 
measures  for  small  and  micro  online  platforms 
are  therefore  presented  (chapter  5  -  section  5.2). 
Administrative costs and benefits for professional 
hosts are presented in chapters 6.1 – 6.3.  

(8)  The  report  should  further  develop  the  impact 
analysis.  It  should  assess  the  potential  impacts  of 
the  initiative  on  local  communities,  society  and 
the environment. Even if the final impact on local 
communities  cannot  be  quantified  –  because  it 
depends on action at local level, the report should 
elaborate  on  the  expected  effects  of  actions  at 
local  level,  which  will  be  triggered  by  the 
initiative. The impact analysis should also present 
a more complete overview of the expected effects 
on  the  different  types  of  market  participants, 
including the more traditional local ones. 

The  report  has  been  revised  and  for  each  of  the 
policy  options,  an  assessment  of  the  potential 
social  and  environmental 
impacts  has  been 
included (chapter 6). Illustration of these impacts 
has  been  included  when  feedback  from  public 
authorities  has  been  received.  Environmental 
impacts  of  this  initiative  are  limited.  Impacts  of 
policy options on “market” participants have also 
been  included.  Some  examples  of  the  potential 
impacts  on 
local  communities  have  been 
included.  For  these  inclusions,  see  chapter  6  – 
section 6.1; 6.2; 6.3.   

(9)  The  report  should  clearly  demonstrate  the 
respect  of  the  subsidiarity  principle  and  the 
proportionality  of  the  preferred  policy  option, 
including  the  choice  of  a  regulation  as  the 
preferred  policy  delivery  instrument.  It  should 
justify  why  the  most  stringent  options,  which 

The  Impact  Assessment  has  been  revised  and 
policy  options  have  been 
in 
particular  to  better  take  into  account  subsidiarity 
considerations.  The  report  has  been  amended  to 
explain  how 
is 
respected  (chapter  3  -  section  3.2;  chapter  5 

subsidiarity  principle 

reconsidered, 

the 

61 

 
 
 
 
 
 
impose obligations for all actors across  the whole 
EU,  score  better  than  more  targeted  options  that 
only  impose  costs  where  these  are  needed.  The 
comparison  of  options  should  be  improved  and 
clearly linked to the findings of the analysis. 

regards 

(10)  The  report  should  present  the  views  of 
different  stakeholder  groups  as 
the 
problems  and  possible  policy  solutions,  including 
consumers,  (associations  of)  citizens  affected  by 
STRs or NGOs. Given the low number of citizens 
responding  to  the  public  consultation  and  the 
sensitivity of this issue in certain areas, the report 
should  complement  the  information  from  the 
public consultation with other sources. 

(11)  The  report  should  explain  how  the  initiative 
would  affect  the  existing  reporting  by  the  STR 
sector  under 
the  Directive  on  administrative 
cooperation in the field of taxation (DAC7). 

section  5.2  and  chapters  7  and  8  -  section  8.1). 
The  proportionality  of  the  proportionality  of  the 
preferred  policy  option  is  also  better  explained 
(chapters 7 and 8 – section 8.1) 

The views of NGOs and associations on STRs in 
general  have  been  included  in  the  report:  in 
chapter 1 section 1.1 (context, first and under the 
assessment  of  each  policy  option  in  chapter  6 
(sections 6.1, 6.2 and 6.3). More than 4 000 hosts 
(mainly  citizens)  participated  in  the  open  public 
consultation. 

the 
report  demonstrates,  building  on 
The 
feedback  of  public  authorities,  that  the  reporting 
under  DAC7,  which  benefits  national 
tax 
authorities, is not  sufficient to meet  the  needs of 
public  authorities  managing  STRs  (content, 
timing,  difficulties  to  access  data  from  taxation 
authorities…)  (see  sections  1.2,  2.2,  5.1  and 
Annex 6). A specific policy option consisting in a 
legislative  approach  providing  for  a  legal  basis 
for  national  tax  authorities  sharing  data  they 
obtain  under  DAC7  with  local  authorities  (G2G 
dimension)  has  also  been  discarded  for  the 
reasons explained in section 5.3. 

(12)  The  standard  tables  on  costs  and  benefits  in 
annex  should  present  a  more  comprehensive 
overview,  in  particular  on  compliance  costs  for 
citizens and businesses. 

The  Tables  in  Annex  3  have  been  revised.  With 
reference to the preferred option, the figures have 
been  updated.  Table  2  includes  3  categories 
(citizens, businesses, public administrations). 

The revised impact assessment was submitted to the RSB on 23 June 2022. The Board 
issued a positive opinion with  reservations on 22 July 2022.  The recommendations of 
the Board were addressed in the impact assessment as follows: 

RSB Recommendations 

Revisions introduced 

(B) Summary of findings 

(1)  The  report  does  not  clearly  demonstrate  the 
internal market dimension of the problems. 

See improvements made in more details below. 

(2)  The  report  does  not  sufficiently  demonstrate 
the necessity and value added of EU action. 

See improvements made in more details below. 

(C) What to improve 

62 

 
 
 
(1)  The 
report  still  does  not  sufficiently 
demonstrate where the EU needs to act because of 
internal market problems.  

It  should  provide  clear  concrete  evidence  that 
information requests from public authorities result 
(or  are  likely  to  result)  in  market  fragmentation 
and present an appreciable obstacle to the  market 
entry  and  expansion  of  small  and  medium  sized 
platforms.  This  assessment  should 
into 
account the results from the SME test.  

take 

It should also recognise that information and data 
requests  from  public  authorities  for  public  policy 
purposes  often  have  a  regional  or  local  focus, 
concern  specific  information  and  frequencies  and 
thus are different by their very nature.  

Regarding the costs to platforms when replying to 
data  requests  of  public  authorities,  the  report 
should provide further ranges of such estimates to 
better  reflect  the  differences  in  scope  of  such 
requests (e.g. requests to big platforms covering a 
whole  country  vs  request  to  a  small  platform 
regarding a specific location or region). 

(2)  The  report  still  needs  to  better  explain  why 
(local)  public  authorities  are  not  able  to  get  the 
data that they need for public policy design.  

The  report  now  clarifies  in  section  2.1  why  and 
how  fragmented  data  requests  affect  online 
platforms,  based  on  the  results  of  the  targeted 
survey  to  platforms.  The  report  also  clarifies 
which  type  of  platforms  are  affected,  namely 
small,  medium  and  large  platforms  who  operate 
or  wish  to  operate  in  several  cities  and  Member 
States.  Further  analysis  has  been  conducted  to 
estimate the number of large and small platforms 
operating  in  this  sector  and  the  percentage  of 
platforms  operating  cross-border. 
  Evidence 
indicates  that  a  significant  proportion  of  smaller 
platforms  active  in  the  short-term  rental  sector 
also  operate  cross-border,  and  therefore  the 
likelihood  of  receiving  multiple  and  fragmented 
data  requests  is  high  for  smaller  operators  too. 
Annex  5  contains  more  detailed  estimations  of 
cross-border 
rental 
platforms.  

activity  of 

short-term 

Section 2.1 also clarifies that there is a core set of 
data  that  public  authorities  always  ask  from 
online  platforms  (and  this  is  also  the  set  of  data 
which is harmonised on this basis), while certain 
public 
additional 
can 
information or evidence based on the local needs.  

authorities 

require 

Annex  4.2  provides  a  detailed  calculation  of  the 
average  cost  of  one  data  request  per  platform. 
This  calculation  is  based  on  the  information 
provided by a limited number of platforms during 
the consultation process, while most platforms to 
which  this  information  was  requested  did  not 
provide this information, either for confidentiality 
reasons or because they declared not to have this 
information. It is therefore not possible to provide 
more  detailed  calculations  of  the  costs  as  online 
STR  platforms  themselves  do  not  have  this 
information are not willing to share it. Moreover, 
the baseline cost burden calculation is based on a 
conservative  assumption  that  only  60%  of  big 
platforms  (18)  are  confronted  with  data  requests 
(150  requests  annually  with  an  average  cost 
related to request of €13.549. See table 7 Annex 
4).  The  report  adds  a  clarification  and  caveat  to 
this calculation in sections 2.3 and 6.1.  

Section 2.1 of the report now explicitly states the 
reasons  put  forward  by  public  authorities  in  the 
consultation process for not being able to get the 
data  they  need  for  policy  design.  Section  2.2 

63 

 
 
 
 
 
 
 
It should explain why (present and future) rules at 
local, regional or national level are not sufficiently 
effective  and  efficient  in  this  regard.  It  should 
explain  why  EU  level  rules  would  lead  to  better 
compliance  of  hosts  and  platforms  and  better 
enforcement and sanctioning by public authorities.  

It  should  better  justify  the  use  of  Article  114  to 
motivate  more  effective  and  efficient  information 
request  possibilities  for  public  authorities  in 
absence  of  a  clear  link  to  an  established  internal 
market problem.  

It  should  better  demonstrate  the  respect  of  the 
subsidiarity  principle  and  the  proportionality  of 
the preferred legislative policy option. 

(3) The report should better explain why the tools 
available  to  public  authorities  under  the  Digital 
Services  Act  are  not  sufficient  to  deal  with  hosts 
acting  in  a  fraudulent  manner.  It  should  also 
clarify  to  what  extent  platforms  require  in  their 
general contract conditions that their hosts comply 
with the applicable laws. 

clarifies the three main reasons why rules in place 
at  local,  regional  or  national  level  are  not 
sufficiently effective and efficient to get this data 
(lack  of  enforceability  of  registration  schemes 
without  the  collaboration  of  online  platforms, 
limited  data  sharing  by  online  platforms  for 
several reasons). 

schemes, 

registration 

Section  3.2  now  clearly  explains  why  EU  rules 
regarding 
registration 
numbers and data sharing obligations are  needed 
to  ensure  that  such  requirements  are  easily 
enforceable  and  complied  with  at  EU  level  by 
hosts  and  online  STR  platforms,  while  reducing 
significantly  the  burden  on  those  actors  to  do  so 
compared 
(fragmented 
to 
requirements). 

status  quo 

the 

Sections  3.1  and  3.2  clarify  that  this  proposal 
primarily  aims  at  streamlining  data  requests 
across the EU to  facilitate compliance  with  such 
data  requests  for  online  STR  platforms,  hence 
reducing  costs  and  removing  barriers  to  operate 
in  the  single  market  for  these  platforms.  Public 
authorities  also  benefit  from  this  streamlining, 
but  the  internal  market  problem  for  online  STR 
platforms is clearly identified and solved by  this 
proposal.  

Sections  3.2  and  8  clarify  how  the  subsidiarity 
principle  is  respected  by  the  preferred  policy 
option,  in  particular  with  regards  to  registration 
schemes,  and  how  the  preferred  option  strikes  a 
balance  between  the  different  interests  involved 
in order to ensure proportionality of the proposed 
measures. 

Section  5.1  states  clearly  the  limitations  of  the 
DSA with regards to STR, related notably to the 
limited  enforcement  of  registration  numbers  on 
‘traders’  only,  and  the  absence  of  data  sharing 
mechanism  (with  only  the  possibility,  under  the 
DSA, to request information and order takedown 
on  individual  listings).  Section  5.1  provides 
information  on  the  general  contract  conditions 
imposed by platforms on hosts with respect to the 
compliance with the applicable laws.  

(4) The report should clarify under the legislative 
the 
policy  option  2  who  would 

trigger 

The  report  clarifies  in  section  5.2,  policy  option 
2,  that  if  a  local,  regional  or  national  authority 

64 

 
 
 
 
 
 
 
 
 
 
 
 
participation  of  a  Member  State  in  the  common 
registration system (and the obligation to ensure a 
single  digital  entry  point),  in  particular  whether 
this  would  be  an  autonomous  decision  of  that 
Member State or whether it would be triggered, if 
any  public  authority  of  that  Member  State  would 
wish to do so. 

(5)  Given  that  platforms  did  not  answer  to  the 
question  whether they offer their services in their 
country  of  residence  or  cross-border,  the  report 
should  justify  the  assumption  that  many  or  the 
majority of platforms intermediating STR services 
operate  cross-border.  In  particular, 
it  should 
explore  whether  this  assumption  applies  to  small 
platforms or only to the bigger ones as if only the 
latter are concerned, the initiative risks benefitting 
the established players disproportionately. 

wants  to  obtain  data  from  online  STR  platforms 
as  per  the  system  described  under  this  policy 
option,  they  have  to  put  in  place  a  registration 
system  at  their  level  and  that  would  trigger  the 
obligation  for  national  authorities  to  set  up  the 
single digital entry point.  

The report clarifies in section 2.1 which types of 
platforms  are  affected  by  fragmented  data 
requirements  (i.e.  small,  medium  and  larger 
platforms  who  operate  or  wish  to  operate  in 
several cities and Member States).  

Annex  5  contains  estimations  of  cross-border 
activity  of  short-term  rental  platforms.  Evidence 
indicates  that  a  significant  proportion  of  smaller 
platforms  active  in  the  short-term  rental  sector 
also  operate  cross-border  and  are,  therefore, 
affected by fragmented data requests.  

The  Board  notes  the  estimated  costs  and  benefits 
of  the  preferred  option(s)  in  this  initiative,  as 
summarised in the attached quantification tables. 

The  costs  and  benefits  analysis  is  not  altered  by 
the clarifications brought to the text following the 
above recommendations. 

4.  Evidence, sources and quality 

DG  GROW  conducted  and  contracted  several  studies  in  support  of  the  impact 
assessment: 

  Oxford  Research.  “Study  on  national  regulatory  approaches  to  short-term 
accommodation  services”  -  European  Commission,  Luxembourg  (2021) 
(upcoming). 

  Van Haaren, Jeroen, Susan Vermeulen, Jeroen Klijs,  Ko Koens and Jorrit Bijl. 
“Short-term accommodation rental in Amsterdam. An empirical investigation of 
statistical  correlations  between  short-term  rental,  housing  prices  and  quality  of 
life index.” European Commission, Luxembourg (2021). 

 

Ipsos European Public Affairs. “Flash Eurobarometer 495. Short-term rentals in 
the EU.” European Commission, Luxembourg (2021). 

  Spark  Legal  Network  and  Valdani  Vicari  &  Associati.  “Study  on  the 
Assessment of the Regulatory Aspects Affecting the Collaborative Economy in 
the  Tourism  Accommodation  Sector  in  the  28  Member  States.”  European 
Commission, Luxembourg (2018). 

65 

 
 
 
 
A series of external analytical papers contracted by the Commission shed light on issues 
related to market access requirements in the short-term accommodation rental segment: 

  Duch-Brown,  N.  (Coord.),  The  Short-Term  Accommodation  Rentals  market  in 

the EU, JRC Digital Economy Working Paper 2021-09 

  Ratin  Legis.  “Impulse  Paper  on 

the  Business  Authorisation/Licensing 
Requirements Imposed Both on Peer-Providers and Platforms. Barcelona, Berlin 
and Amsterdam.” (2016) 

  Guido  Smorto.  “Impulse  Paper  2  on  the  Business  Authorisation/Licensing 
Requirements  Imposed  Both  on  Peer-Providers  and  Platforms  in  Paris,  Rome, 
Milan and London” (2016) 

  Sofia  Ranchordás  et  al.  “Impulse  Paper  on  Home-Sharing  in  the  Digital 

Economy: The Cases of Brussels, Stockholm and Budapest.” (2016)  

The  Commission  (DG  GROW)  signed  a  landmark  agreement  with  Airbnb,  Booking, 
Expedia  Group  and  Tripadvisor,  which  began  collaboration  between  these  platforms 
and  Eurostat,  to  publish  data  on  short-term  accommodation  rentals  offered  via  these 
platforms across the EU. 

DG GROW conducted dedicated workshops with all stakeholders: 

  Developing  a  fair  single  market  for  short-term  rental  services,  10  December 

2021. 

  Enhancing transparency on short-term rentals in the EU, 22 October 2021. 

  SIMFO  Workshop  2021  –  The  holiday  and  other  short-term  accommodation 

sector in Dublin, 10-11 February 2021189 

 

 SIMFO  Workshop  2021  -  The  holiday  and  other  short-term  accommodation 
sector in Lisbon, 28-29 January 2021 

  SIMFO  Workshop  2021  -  The  holiday  and  other  short-term  accommodation 

sector in Valencia, 3-4 December 2020 

DG GROW carried out a literature review, based on the references listed in Annex 10.  

189 Report saved under Ares(2021)7518319. 

66 

 
 
 
 
                                                           
ANNEX 2: STAKEHOLDER CONSULTATION  

Consultation strategy 

The objectives were to collect feedback and data on the identified problems and drivers, 
as well as on the possible solutions. The activities included a public consultation of all 
stakeholders, a roadmap, workshops and bilateral meetings with relevant  stakeholders. 
The  main  communication  channel  has  been  the  Commission’s  Have  Your  Say  portal,  a 
dedicated  webpage,  and  twitter.  Consulted  stakeholders  include  hosts  and  online 
platforms  (and  their  organisations),  public  authorities  (national,  regional  and  local 
level),  service  providers  such  as  management  companies,  hotels,  citizens  and  local 
associations. 

71 feedbacks  were received on the inception impact  assessment, during  a consultation 
from  16  September  to  14  October  2021.  Hosts  stressed  the  need  to  increase  the 
responsibility of online platforms in ensuring that only legal listings are displayed. They 
warned  against  the  multiplication  of  restrictive  rules  for  hosts  at  local  level.  Property 
managers  (mainly  SMEs)  suggested  that  simple  registration  procedures  should  be  in 
place for STRs and that a national database should be available to map STR operators. 
For online platforms, data sharing requests should  be proportionate and in compliance 
with  EU  law,  notably  GDPR.  Smaller  platforms  called  for  data  minimisation  and  the 
‘once  only’  principle  for  data  sharing.  They  stressed  that  new  data  sharing  obligation 
should build on existing obligations (e.g. under DAC7 and the DSA) and fill remaining 
gaps. The hospitality sector (mainly hotels) supports registration schemes for hosts and 
increasing  data  sharing  by  online  platforms.  It  calls  for  a  level  playing  field  between 
STRs and traditional accommodation providers. The majority of stakeholders supports 
STR rules that differentiates between different types of hosts (no one-size fits all). 

Bilateral  meetings  with  the  stakeholders  and  five  workshops  took  place.190 A  public 
consultation  was  open  from  27  September  to  13  December  2021,  available  in  23  EU 
languages. In addition, two targeted surveys were launched to public authorities on the 
one hand, and to platforms on the other hand, in April 2022. The results are presented in 
Annex 2a and Annex 2b respectively. 

Public consultation 

Stakeholders group. Respondents were asked to self-identify themselves under one of 
the  7  categories  of  respondents  that  match  the  composition  of  the  STR  ecosystem: 
hotels  and  similar,  online  platforms  and  their  associations  (traditional  STR  platforms, 
booking  platforms,  online  travel  agencies,  and  their  associations),  other  service 
providers  (e.g.  property  management  companies,  maintenance  and  cleaning  services), 
individual  and  professional  hosts,  public  authorities  (local,  regional  and  national)  and 
other  (e.g.  academia,  host  associations,  housing  and  tenant  associations,  trade 
associations).  The  results  are  presented  based  on  these  specific  categories  of  STR 
stakeholders, rather than on the standard categories of respondents of EU survey.191 The 
affiliation  with  a  certain  respondent  category  is  based  on  the  self-declaration  of  the 

190 Minutes saved in ARES. Operative conclusions for the workshops available here. 
191 For a preview of results based on the standard categories of respondents, see here. 

67 

 
 
                                                           
respondent. Thus, is should be bared in mind that there may be errors with regard to the 
affiliation  chosen  by  the  respondent.  The  following  graph  shows  the  responses  per 
respondent category: 

Figure 1. Responses by stakeholder group 

Figure 2. Responses by country of respondent 

Total respondents: 5,479. 

The  graphs  above  shows  the  number  of  responses  per  stakeholder  category.  The 
majority  of  responses  were  submitted  by  individual  (78.1%  -  4,278)  and  professional 
(11.1% - 606) hosts. Most of the replies were submitted  from France (24.8% - 1,414), 
Italy (16.8% - 957), Spain (10.6% - 601) and Germany (9.8% - 558).  

Total respondents: 5,695. 

68 

78.1% (4,278)11.1% (606)2.6% (145)0.5% (25)0.5% (26)3.0% (167)4.2% (232)Individual HostProfessional HostService ProvidersBooking PlatformsPublic AuthorityHotelsOtherI24.8% (1,414)16.8% (957)10.6% (601)9.8% (558)6.5% (373)5.1% (292)3.8% (214)2.2% (123)2.1% (118)1.8% (101)12.0% (685)4.5% (259)FranceItalySpainGermanyPortugalGreeceNetherlandsBelgiumCroatiaSwedenRemaining Member StatesNon-EU countriesII 
 
 
 
Methodology  and  tools  to  process  the  data. For all seven groups, we received 5696 
responses.  One  reply  was  disregarded  at  the  request  of  the  respondent.  We  identified 
216  respondents  who  wrongly  self-identified  as  online  booking  platforms.  We  do  not 
include those respondents in the disaggregate analysis, but we include their answers at 
aggregate  level.  Therefore,  at  disaggregate  level  we  only  consider  5.479  respondents. 
As  the  survey  aims  to  measure  the  perception  and  possible  issues  related  to  STR, 
frequency analysis was carried out. Data was categorised into one of seven stakeholder 
groups, defined above.  

The survey is composed of closed and open questions. Closed questions were assessed 
based  on  a  proportion  analysis,  measuring  the  responses  across  different  stakeholder 
groups.  Proportions  are  displayed  individually  in  each  of  the  questions.  For  open 
questions,  a  qualitative  analysis  was  performed  to  measure  the  responses  proportions. 
Filters  by  stakeholders  and  responses  were  applied  in  both  cases  if  necessary  for  the 
study purposes. 

Campaigns. A possible campaign by online platforms to alter some of the answers was 
considered. The periods from 28 October to 3 November 2021 and 25 to 29 November 
2021  were  analysed.  The  analysis  consisted  of  the  identification  of  duplicate  answers 
across stakeholders. Duplicates were identified among responses from individual hosts 
but with a 1% frequency in the first period and a 0.3% in the second one. The analysis 
does not suggest any possible campaign and any possible alteration is discarded.  

Contributions  received  outside  the  formal  consultation  process.  11  contributions 
were  received  by  email,  for  either  confidentiality  or  technical  reasons,  and  have  been 
taken into account in the results below. 

Results 

1.  General market information 

Definition  of  STR.  For  respondents,  STR  include  the  provision  of  accommodation, 
typically on a daily or weekly basis principally for short stays by visitors (95.9% - 5,462 
out of 5695) of the respondents strongly or somewhat agree); 67.4% (3,838 out of 5695) 
also  strongly  or  somewhat  believe  it  includes  stays  on  a  monthly  basis.  94.8%  (5,399 
out of 5695) of the respondents believe it includes furnished rooms or entire apartments 
or  houses,  and  50.1%  (2,853  out  of  5695)  agree  that  it  excludes  furnished  short-stay 
accommodation with daily cleaning, bed-making, food and beverage services. 

Benefits generated by STRs. For all respondents, STRs generate economic and tourist 
benefits.  Most  of  the  hosts  (97.5%  -  4,762  out  of  4884)  agree  with  that  statement. 
Online  platforms,  public  authorities  and  hotels  usually  give  greater  importance  to  the 
economic  impacts  rather  than  tourist  benefits.  Nevertheless,  both  benefits  are 
significant.   

69 

 
 
Figure 3. Benefits generated by STRs by Stakeholders group 

Total respondents: 5, 479. 

Economic benefits group the options: It is an additional source of income for citizens; It creates 
employment; It attracts visitors; It encourages investment in local services (e.g. housing, tourism, 
transport). 
Benefits for tourists group the options: It caters to unfulfilled tourism needs (e.g. low-income tourists, 
(large) families); It is an alternative to more traditional accommodation offers.   

Negative impact of STRs. 48.2% (2,355 out of 4884) of the hosts report no drawbacks. 
However,  47.6%  (2326  out  of  4884)  of  them  is  aware  of  housing  affordability  and 
availability  issues  that  STRs  could  create.  Public  authorities  reported  security  issues 
(73.1% - 19 out of 26). 32% (8 out of 24) of online platforms consider the rental pricing 
issue relevant and 32% (8 out of 25) report no drawbacks. 

Figure 4. Negative impacts generated by STRs by Stakeholders group 

Total respondents: 5, 479. 

70 

10.611.573.34.612.13.677.07.312.076.012.016.084.09.02.188.30.74.62.592.97.32.290.20.2OtherHotelsPublic AuthorityBooking PlatformsService ProvidersProfessional HostIndividual HostEconomic benefitsBenefits for touristsBoth benefitsNo benefits3.324.233.633.25.73.824.532.137.12.511.53.873.111.532.020.032.08.333.820.139.66.50.327.118.649.05.00.130.317.648.13.8OtherHotelsPublic AuthorityBooking PlatformsService ProvidersProfessional HostIndividual HostEconomicRent PricesSecurityNo DrawbacksOther 
 
 
 
 
Economic: It has a negative economic impact on traditional accommodation providers. 
Rent Price: It increases the price of renting or buying housing in cities; it decreases the availability of 
housing for rent or sale in cities. 
Security: It raises security issues; it increases nuisance for local residents. 
No Drawbacks: There are no drawbacks. 

Hosts activity 

The  next  graphs  show  the  type  of  accommodation  rented  out  by  both  individual  and 
professional hosts and their location (urban, rural area or both).  

Figure 5. Type of accommodation offered by hosts 

Total respondents: 4884. 

Room: Room(s) in my main residence (apartment or house) 
Main Residence: The entirety of my main residence (apartment or house) 
Own & Other Apartment: An apartment or house other than my main residence 
Several Apartments: Several apartments or houses other than my main residence 
Other Apartment: Among the “other” type of accommodation, the following were mostly listed: (a) 
mostly apartments built next to the main residence; (b) other atypical rental spaces (e.g., boat, bungalow, 
yurt, tent). 

Figure 6. Locations where accommodations are offered by hosts 

Total respondents: 4884. 

71 

14.8%12.5%35.7%20.3%16.6%RoomMain ResidenceOther ApartmentSeveral ApartmentsOwn & Other ApartmentAccomodation by place32.5%63.1%4.4%Rural AreaUrban AreaRural & Urban AreaAccomodation by place 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Means used to offer STR services. Hosts mainly use online platforms to advertise their 
STR services. In addition, 19% (928 out of 4884) of hosts consider word mouth as an 
important means to offer their services.  

Online  platforms  used  to  offer  STR  services.  Hosts  use  mainly  large  platforms  to 
offer their STR services, while only 8.6% (420 out of 4884) of hosts use small platforms 
only.  The  most  popular  large  platforms  cited  were  Airbnb,  Booking,  Vrbo  (Expedia) 
and  TripAdvisor.  Airbnb  consolidates  as  the  most  used  one  (~85%  for  individual 
hosts192 and ~72% for professional hosts193). Some examples of small platforms used by 
individual  hosts  included  Leboncoin,  Rentalia,  Homeaway  (8.4%  -  359  out  of  4278), 
and  those  used  by  professional  hosts included  Gîtes  de  France,  PAP  vacances,  Agoda 
and other local platforms (32.67% - 198).  

Figure 7. Main online platforms used by hosts 

Total respondents: 4884. 

Cross-border activity 

Hosts  and  online  platforms  were  asked  whether  they  offer  their  services  only  in  their 
country of residence (and in how many cities), or whether they also offer their services 
cross-border.  While  platforms  did  not  provide  an  answer  to  these  questions,  it  can  be 
assumed that almost all online platforms operate cross-border. At the same time, while 
most  hosts  provide  their  services  in  their  country  of  residence  (89.4%  -  4,366  out  of 
4884) some hosts declared to offer their services in more than 1 city (13.6% - 664 out of 
4884) and some even cross-border (16.3% - 796 out of 4884).  

192 Airbnb  is  used  by:  People  using  only  Airbnb  (63.6%);  People  using  A.  &  booking  (20.1%);  People 
using A. & others (2.6%). ~85% of people use Airbnb, as using one platform does not imply not using 
others and multiple listings are possible. 
193 Airbnb is used by: Hosts using only Airbnb (35%); Host using A. & booking (33.8%); Hosts using A. 
& others (3.8%). ~72% of hosts use Airbnb, as using one  platform does not imply not using others and 
multiple listings are possible. 

72 

5.22.721.81.660.08.6Small PlatformAirbnbBookingAirbnb & BookingAirbnb & OthersCombination of all 
 
 
                                                           
The  main  reasons  put  forward  by  hosts  for  not  operating  cross-border  were:  not 
interested  in  operating  cross-border  (55.2%  -  2,696  out  of  4884)  too  costly  to  do  so 
(21.8% -1,065 out of 4884), don’t know what rules apply (27.6% - 1,348 out of 4884), 
too many rules apply (11.7% - 571 out of 4884).  

Hosts indicated that significant194 expenses arise to comply with obligations in different 
Member  States.  Respondents  report  cleaning  and  maintenance  costs  and  taxes.  Hosts 
point out commission fees from platforms. 

Ancillary service providers  

39.2% (1913 out of 4884) of hosts declared that they collaborate with providers of other 
services (ancillary services, e.g. property management, cleaning, maintenance…) or are 
considering doing so. 60% (15 out of 25) of online platforms declared they help arrange 
such services. 83.4% (121 out of 145) of ancillary services providers declared that they 
gain  a  significant  part  of  their  customers/revenue  from  services  requested  by  hosts 
and/or by referrals from online platforms. 

Impact of COVID 

When asked about the impact of COVID on the STR sector, public authorities indicated 
that  the  STR  sector  suffered  similar  setbacks  as  other  industries  related  to  tourism. 
However,  the  STR  sector  shows  greater  resilience  and  recovered  volumes  faster  than 
other types of accommodation. The lockdown period has – reportedly – heavily affected 
STRs. However, most respondents point out a current recovery to pre-pandemic levels. 
Hosts, in turn, described the impact of COVID to be significant. On the first year of the 
pandemic loses range from 20% to 100%. The lockdown implied a drop in international 
tourists  arrivals,  sharply  reducing  STRs  revenues.  No  respondent  who  identified  as  a 
platform replied to specific questions on this issue.    

2.  Transparency 

Data needed to design STR rules 

Public  authorities  indicated  that  they  need  non-personal  (73.1%  -  19  out  of  26)  and 
personal  data  (26.9%  -  7  out  of  26)  to  design  STR  rules.  The  following  data  was 
mentioned most: number of available STRs, property information (location), number of 
nights rented, information on the hosts. 

Data needed to enforce STR rules  

For enforcement purposes, 53.8% (14 out of 26) public authorities indicated they need 
non-personal  data,  and  61.5%  (16  out  26)  public  authorities  indicated  they  need 
personal data. The following data were mentioned most: Number of nights the property 
is rented, host identification and property information (location).  

194 Different respondents from different Member States reported examples of possible expenses they were 
referring to. Ranges and specific items described vary depending on the Member State and locality. 

73 

 
 
                                                           
Access to data by public authorities  

26.9%  (7  out  of  26)  of  public  authorities  indicated  that  they  have  access  to  non-
personal, aggregated data on the number of STR and of nights rented out and 11.5% (3 
out of 26) personal data on who rents what and how often. Public authorities get access 
to  both  personal  and  non-personal  data  mostly  by  using  publicly  available  data  or 
private/commercial data. Among those who declared a lack or limited access to personal 
(88.46%  -  23  out  of  26)  and  non-personal  data  (73.07%  -  19  out  of  26),  the  main 
reasons  behind  were  a  lack  of  appropriate  legal  framework  for  data-sharing  (for 
personal  78.26%  (18  out  of  23)  and  non-personal  63.15%  (12  out  of  19))  and  lack  of 
response  from  online  platforms  to  requests  by  public  authorities  (56.5%  (13)  and 
52,63%  (10)  respectively).  Ten  public  authorities  declare  to  receive  data  either  from 
online platforms (5 out of 26) or using publicly available and commercial data (5 out of 
26).  Some  of  those  public  authorities  declare  to  receive  the  data  on  a  yearly  basis  or 
even on a timely (daily) basis. Among all public authorities, a low percentage (23.07% - 
6 out of 26) require a particular delivery format.  

Public  authorities  also  receive  data  directly  from  hosts  (57.7%  -  15  out  of  26).  Those 
who  receive  data  from  hosts  do  so  via  online  platforms,  register  procedures  and  tax 
payments.  Those  who  do  not  receive  data  from  hosts  declared  the  following  reasons: 
lack of legislation, lack of cooperation from hosts, and privacy concerns. 

Finally, fifteen public authorities declared to receive data from hotels. They particularly 
have access to licenses, tourist tax information and official statistics data. 

Data sharing by hosts 

82.9%  (4,049  out  of  4884)  of  hosts  declared  to  share  information  on  STRs  with  local 
public authorities. In particular, 79.4% (3,878 out of 4884) of hosts declared that they 
have  to  register  with  local  authorities  and  provide  information  in  that  context.  83.2% 
(4,063 out of 4884) of hosts declared that they share information when complying with 
tax  obligations.  Some  hosts  declared  to  share  other  type  of  information,  such  as  the 
identity  of  hosts  (Spain,  Greece,  Portugal,  Italy).  Other:  information  on  income, 
duration  of  stay  (Greece),  monthly  statistics  to  city  council  on  occupation  rate 
(Germany). 

Data sharing by platforms  

76%  (19  out  of  25)  of  platforms  respondents  declared  to  share  data  with  public 
authorities  from  at  least  one  Member  State.  20%  (5)  declared  to  share  data  only  in 
certain Member States (but not all in which they operate). Platforms that do not share 
data with public authorities (24% - 6 out of 25) declared the following reasons for not 
doing  so:  four  have  not  received  requests;  one  has  received  requests,  but  they  believe 
they are not subject to the jurisdiction of the relevant Member State; one cannot legally 
share the data. 

With regards to  public  authorities that request  data, platforms identified:  National  and 
local  tax  authorities,  tourism  authorities  and  tourism  information  offices,  policy 
authorities  and  statistical  institutes.  When  they  share  data  with  public  authorities,  it is 
often on a mandatory basis (44% - 11 out of 25), less so on a voluntary basis (12% - 3 
out  of  25),  and  sometimes  on  both/it  depends  on  the  data  (12%  -  3  out  of  25).  One 

74 

 
 
platform explained that they usually create reports on voluntary basis since they want to 
be open and transparent.  

Platforms that share data with public authorities share non-personal data (60% - 15 out 
of  25),  personal  data  (32%  -  8  out  of  25)  or  sometimes  other  types  of  data  such  as 
income details or tourist information. They share the data mostly on a yearly basis (28% 
- 7 out of 25), but sometimes also every six months (20% - 5 out of 25) upon requests of 
public authorities (44% - 11 out of 25) or on a timely basis through e.g. APIs (12% - 3 
out  of  25).  With  regards  to  the  level  of  diversity  of  the  data  requests  from  public 
authorities, 12% (3 out  of 25) declared that the difference is high, while 8% (2 out of 
25) declared that there is low or no difference at all. 

Platforms declare that data requests continue to pose legal challenges and costs, as they 
are often fragmented, inconsistent (often duplicate). Platforms identify costs according 
to (i) legal costs due to challenges with local public authorities and (ii) operational costs 
linked  to  the  internal  product  development  required  to  support  local  data-sharing 
compliance schemes (and lack of solutions at scale). Platforms report that data-sharing 
requirements  can  be  unclear,  complex  and  much  more  costly  to  build  compliance 
schemes around. 

Cooperation of platforms in enforcing STR rules  

72%  (18  out  of  25)  of  platforms  declared  that  they  are  subject  to  obligations  to 
cooperate  with  public  authorities  to  enforce  existing  STR  rules  (e.g.  obligation  to 
display registration numbers, delist listings without a registration number).  

Platforms  specified that  the following obligations could  apply (non-exhaustive listing) 
depending on the market:  

  Delisting  non-compliant  listings  when  ad  hoc  notices  are  received  from 

public authorities,  

Identifying whether a listing needs a registration number or not, 

  Displaying registration numbers,  
 
  Enforce nightly stay caps restrictions, 
  City tax collection and remittance on behalf of home owners. 

In terms of costs to comply with such obligations, platforms indicated that: enforcement 
actions  are staff intensive and very  costly, there are high  administrative costs, and the 
lack of transparency favours the non-compliance with  the rules. Platforms  reports that 
the  time  needed  vary  depending  on  the  underlying  regulation,  information  requested, 
reporting cadence, and adherence to EU law – it can take one week to several months. 

How  should  public  authorities  get  access  to  data.  The  graph  below  shows  the 
perception by respondents as to whether and how public authorities should get access to 
data on STR to design and enforce policies:  

Figure 8. How should public authorities get access to data? 

The tables below show the perception of the respondents  with  regards to the different 
means public authorities should use to get access to data (and as to whether they should 
get access to data at all). 

75 

 
 
a.  They should not get access to such data 

b.  They  should  carry  out  checks  and  enforcement  actions  directly  on  the 

ground 

Total respondents: 5695. 

c. They should obtain it directly from the (registered) hosts 

Total respondents: 5695. 

76 

17.23.18.411.018.541.918.00.610.815.022.832.93.73.77.43.77.474.116.73.320.026.73.330.020.72.813.814.519.329.017.23.013.716.818.331.020.83.616.115.620.223.8OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions14.54.414.19.337.919.820.42.422.810.229.315.07.43.733.311.133.311.113.36.740.013.316.710.021.45.522.19.022.120.019.63.123.612.918.322.420.94.919.812.316.026.2OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
 
d.  They should get it from the online booking platforms, upon request  

Total respondents: 5695. 

e.  They should get it from the online booking platforms, periodically  

Total respondents: 5695. 

77 

15.42.620.76.239.615.416.83.018.66.642.512.67.43.729.67.444.47.410.03.316.713.356.713.82.821.49.040.013.115.32.825.79.128.718.317.63.622.610.327.018.9OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions12.83.123.34.439.217.214.41.819.29.041.314.47.43.725.97.440.714.823.33.313.320.026.713.315.96.226.95.531.713.814.22.824.98.433.815.814.43.527.57.629.917.0OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
 
Total respondents: 5695. 

Registration obligation for hosts  

56.6% (3,224 out of 5695) of total respondents see merit in a registration obligation for 
hosts as a tool to increase transparency on STRs. Figure 9 explains at which level the 
registration scheme should be introduced according to the respondents. The majority of 
the respondents believe that the registrations scheme should be managed at national or 
at national/regional/local level. 

Figure 9. At which level a host registration scheme for STRs should be organised? 

Total respondents: 3225. 

78 

11.52.220.75.739.620.315.03.016.29.640.715.63.73.718.566.77.416.73.323.310.026.720.017.96.222.87.629.016.616.83.621.97.334.515.816.74.322.57.430.418.6OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions18.419.741.420.431.318.335.714.817.434.839.18.748.012.036.04.027.414.747.410.528.522.134.415.029.218.536.515.8OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostDo you believe that host registration systems should be organised atEu levelNational levelNational/Regional/LocalRegional/LocalOptions 
 
 
 
As shown by the figures below, there is undoubtedly big support for a more harmonised 
approach  to  host  registration  schemes  within  the  EU.  Most  respondents  see  merit  in 
having national/local registration schemes aligned with an EU template. 

Figure 10. Do you see merit in a more harmonised approach to host registration 
schemes within the EU? 

 

I see merit in having one single registration scheme at EU level, but 
it should replace existing local/national registration schemes 

 

I see merit in having national/local registration schemes aligned to an 
EU standard  

79 

16.33.313.116.321.629.416.52.615.712.235.717.421.78.726.18.734.88.024.08.044.016.08.41.127.47.436.818.913.03.317.812.233.120.615.84.217.911.233.417.5OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions7.21.326.15.949.010.512.20.936.56.138.36.18.74.326.18.747.84.312.048.028.012.07.422.15.356.88.48.42.326.08.943.810.710.53.226.36.343.710.0OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
 
 
 

I  see  merit  in  having  an  optional  EU  standard  for  national/local 
registration schemes 

 

I see no merit in having a harmonised approach at EU level 

Total respondents: 5695. 

Figure 11 shows hosts’ experience with registration schemes.  

80 

15.05.217.019.015.028.824.35.215.717.410.427.030.417.48.721.721.724.012.08.012.044.022.13.217.915.814.726.317.05.120.912.518.326.220.26.718.512.519.023.1OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions13.17.27.213.711.147.714.85.27.818.39.644.317.48.78.717.44.343.54.08.012.08.068.013.73.23.28.415.855.815.06.66.615.813.242.714.79.57.113.511.543.8OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
 
 
 
Figure 11. Hosts’ experience with registration schemes 

Total respondents: 4884. 

Data sharing by platforms  

51.4% (2,927 out of 5695) of respondents are in favour of requiring online platforms to 
share data on STRs with public authorities to increase transparency and facilitate public 
policy  and  enforcement  activities.  Respondents  indicated:  they  expect  positive  impact 
on legal STRs operation (and fight against illegal STRs), less burden on hosts, a higher 
transparency and better  knowledge of the market,  better data quality with  a facilitated 
cross-checking  and  validation  of  data,  better  control  including  on  paying  taxes, 
improved  quality  standards  for  customers.  85.6%  (4,875  out  of  5695)  of  total 
respondents  also  believed  that  such  requirements  should  be  put  in  place/facilitated  at 
EU level. 

To facilitate the sharing of data by online platforms with public authorities, respondents 
are very much in favour of obliging hosts and booking platforms to display registration 

81 

11.49.99.223.530.016.0The procedure was clear and simple to understand14.35.28.214.039.718.7The procedure could be completed online12.910.213.220.625.218.0The procedure was quick to complete20.314.119.016.511.618.5I had to provide a large number of documentsStrongDisagSomDisagreeNeutralSomAgreeStrongAgNo opinion20.314.119.016.511.618.5I had to provide a large number of documents10.94.112.515.532.124.8Registration numbers were issued automatically37.69.217.27.55.522.9The procedure was expensive32.67.615.19.68.127.1The procedure needs to be repeated/updated frequentlyStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinion 
 
 
 
 
 
numbers  when  advertising  a  property,  but  also  to  develop  technical  tools  for  data 
sharing at EU level, or a more harmonised format and frequency for data sharing.  

Figure 12. What would be the better way to facilitate the sharing of data by online 
booking platforms with authorities? 

Obligation  for  hosts  and  booking  platforms  to  display  the  registration  number 
when advertising a property 

Development  of  technical  tools  at  EU  level  (such  as  application  programming 
interfaces, ‘APIs’)  

82 

9.62.910.30.772.83.710.01.18.93.375.61.14.34.391.35.929.464.78.31.46.91.480.61.47.62.018.72.365.24.19.14.117.63.958.17.2OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
Development of a standard format to share data  

Development of harmonised rules for sharing such data (type of data, frequency) 

83 

17.214.917.96.037.36.720.25.615.72.250.65.621.78.713.056.511.85.95.964.711.822.55.621.147.92.819.110.017.05.039.99.120.616.518.33.934.66.0OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions9.74.517.24.560.43.77.95.622.564.04.326.165.24.329.470.611.41.424.31.457.14.312.64.125.61.252.63.813.68.326.21.847.62.5OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
 
Total respondents: 5695. 

22.5% (1,281 out of 5695) of respondents also indicated that if data sharing rules were 
adopted,  they  consider  that  some  online  platforms  should  benefit  from  an  exemption 
(e.g.  start-ups,  platforms  with  low  revenues,  etc.)  More  specifically,  respondents 
identified  the  following  types  of  platforms:  emerging  or  small  platforms,  with  low 
revenues  or  turn-over,  local  platforms  with  little  scope,  platforms  that  facilitate 
individual hosting. 

3.  Market access requirements 

Requirements for STR  

The  graph  bellow  shows  the  perception  by  respondent  as  to  which  rules  and 
registration  schemes,  authorization 
requirements  could  be  acceptable  and 
requirements  or  limits  should  be  imposed.  The  results  show  a  great  divergence  of 
opinion  regarding  market  access  requirements,  which  could  be  explained  by  the  local 
dimension of market access requirements (subsidiarity). 

if 

84 

8.92.219.33.763.03.011.23.423.660.71.127.39.163.66.36.325.056.36.36.92.826.461.12.813.83.526.51.552.62.112.96.426.31.550.82.1OtherHotelsPublic AuthorityBooking PlatformService providerProfessional HostIndividual HostStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinionOptions 
 
 
Figure 13. What type of rules and requirements for STR could be acceptable? 

Total respondents: 5695. 

Standardization of rules and requirements  

The graph bellow shows the perception of respondents as to whether “peers” (individual 
hosts) and professional hosts should be subject to the same rules. The results also show 
that  there  is  no  agreement  on  this  question  and  opinions  diverge  among  respondent 
groups, which indicates that there is no EU wide support for a standardization of STR 
rules and requirements, in particular the distinction between peers and professionals.   

85 

15.45.87.018.851.11.8Registration obligation for hosts35.312.110.813.625.42.7Authorisation requirements for all hosts33.19.012.616.123.95.3Authorisation requirements for professional hosts63.59.47.07.88.04.4Limit on the number of rented nightsStrongDisagSomDisagreeNeutralSomAgreeStrongAgNo opinion63.59.47.07.88.04.4Limit on the number of rented nights69.57.76.46.25.34.8Limit on the amount of generated income49.17.88.015.016.24.0Limit on the number of rented houses/rooms85.02.53.1117.3Total ban on STRStrongly DisagreeSome DisagreeNeutralSome AgreeStrongly AgreeNo opinion 
 
 
 
Figure 14. Should 'peers' be subject to the same rules as professionals? 

Total respondents: 5.479. 

Requirements  on  hotels.  To  start  their  activity,  hotels  must  get  authorisations  (e.g. 
planning  permission/building  permits).  They  must  meet  requirements  related  to 
company  registration,  fiscal  registration,  compliance  with  necessary  health  and  safety 
requirements  (e.g.  fire  protection  and  food  safety),  public  liability  insurance  etc.  In 
order to  exercise their activity, hotels must elaborate a number of procedures and risk 
assessments  and  deal  with  customer  complaints,  luggage  handling,  processing  of 
payments,  dealing  with  emergencies.  They  must  also  comply  with  public  order 
requirements (e.g. registration of guests), privacy regulations, consumer protection law, 
copyright  law,  contract  law,  social  and  employment  law  and  many  other  legal 
requirements. 

86 

52.633.613.832.956.310.834.653.811.536.052.012.038.652.49.032.854.312.974.514.211.3OtherHotelsPublic AuthorityBooking PlatformsService ProvidersProfessional HostIndividual HostNoYesDon´t know 
 
 
 
 
 
 
ANNEX 2A: RESULTS  OF  THE  ADDITIONAL  TARGETED  SURVEY  TO PUBLIC 

AUTHORITIES  

The  targeted  survey  to  public  authorities  complemented  the  results  of  the  public 
consultation  and  gathered  additional  information  on  their  data  needs,  the  purpose  for 
which such data is needed, how and how often public authorities currently collect data 
and  the  level  of  cooperation  they  have  achieved  with  online  platforms.  The  targeted 
survey  to  public  authorities  was  open  from  8  April  to  2  May  2022  and  it  was 
communicated  via  a  targeted  email  campaign.  80  responses  were  received  from  all 
levels  of  public  authorities  (national,  regional,  province/municipal).  The  results  of  the 
survey are presented below, following the order of the questions. 

1.  Identification of respondents 

Public  authorities  were  asked  to  identify  themselves  according  to  the  territorial  level 
they represent. The majority of the public authorities responding to the targeted survey 
(61.25% - 49) carry out their activity at a province/municipal level. 18.75% (15) of the 
public authorities have competences at national level and 16.25% (13) at regional level. 
3.75% (3) of the respondents declared to be tourism offices.  

Figure 1. Number of respondents: 80 

2.  Data needs for public authorities 

Type of data needed on to short-term accommodation rental activities 

Public authorities indicated that they need identification data of the host/owner, of the 
real estate unit and activity data. 

Identification data of the host/owner 

87 

18.75%16.25%61.25%3.75%National authorityRegional authorityProvince/Municipal authorityOtherType of Public Authority 
 
 
The  table  1  shows  the  type  of  identification  data  of  the  host/owner  that  is  needed  by 
public  authorities  at  all  level.  Most  public  authorities  need  identification  data  of  the 
host, and some need the hosts’ tax identification number. 

Identification  data  of  the  host/owner  (multiple 
replies possible): 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

% by category of repliers 

Name, address and contact details (telephone and/or 
email) of the host 
Name, address and contact details (telephone and/or 
email)  of  the  owner  (if  different  from  the  host); 
Social Security number of host) 

Tax identification number of host 
Other 

I do not need this data 

Over a total of respondents 

60% 

33% 

7% 

15 

Identification data of the real estate unit 

80% 

85% 

86% 

20% 

0% 

14% 

37% 

10% 

4% 

69% 

8% 

8% 

13 

3 
Table 1. Number of respondents: 80 

49 

33% 

0% 

33% 

0% 

33% 

The table 2 shows the data needs of public authorities with regards to the real estate unit 
(i.e. the accommodation). The address, the type of accommodation and the capacity are 
among the most selected data types. 

Identification data of the real estate unit (multiple 
replies possible): 

%  by  category  of 
repliers 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

80% 

92% 

60% 

62% 

92% 

92% 

38% 

93% 

93% 

47% 

67% 
0% 
15 

96% 

35% 

88% 

82% 

55% 

33% 

33% 

33% 

33% 

0% 

54% 
0% 
8% 
67% 
13 
3 
Table 2. Number of respondents: 80 

55% 
0% 
49 

Address of the real estate unit rented 
Cadastral  information  or  its  equivalent  under  the 
national law of the Member State where the property 
is located 
Type of real estate unit rented (e.g. room, apartment, 
house…) 
Capacity  of  real  estate  unit  rented  (e.g.  number  of 
beds) 
Whether  the  real  estate  unit  is  a  primary  residence, 
secondary residence, or other 
Other 
I do not need this data 

Over a total of respondents 

Activity data 

88 

 
 
  
  
  
Table 3 shows the type of activity data needed by public authorities. Public authorities 
need mostly the number of nights rented out and the number of guests hosted. 

Activity data (multiple replies possible) 

by 

% 
category 
of repliers 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

the  booking 

Number  of  nights  the  real  estate  unit  has  been 
rented 
Number of guests hosted 
Reason  of 
business/other purposes of stay) 
Revenues  generated  by  the  short-term  rental 
activity 
Other 
I do not need this data 
Over a total of respondents 

leisure/for 

(for 

87% 

80% 

53% 

67% 

67% 
0% 
15 

92% 

77% 

46% 

46% 

88% 

71% 

47% 

41% 

67% 

67% 

67% 

33% 

54% 
8% 
13 
Table 3. Number of respondents: 80 

55% 
6% 
49 

67% 
33% 
3 

Frequency of identification data needs 

The  frequency  at  which  public  authorities  need  identification  data  on  the  host/owner 
varies  greatly,  depending  on  the  level  of  public  authorities,  as  shown  by  the  figure  2 
below.  

With regards to identification data of the real estate unit, the frequency at which the data 
is needed also varied depending on the level of public authority, as shown by figure 3 
below. 

Figure 2. Number of respondents: 76 

89 

 
 
 
  
  
  
  
Finally,  with  regards to  activity data, public  authorities declare to  need it mainly on a 
daily basis, but with important differences depending on the level of public authority.  

Figure 3. Number of respondents: 79 

Figure 4. Number of respondents: 76 

For which purposes is data needed 

Most of the public authorities require the information about hosts, owners and activity 
to  enforce  rules.  On  the  other  hand,  less  than  a  half  of  the  respondents  indicate  they 
need the data to design and justify rules.  

 Identification 
data 
hosts/owner 

– 

Identification 
data – real estate 
unit 

Activity 
data 

90 

 
 
 
 
  
Enforcing rules 

Designing and justifying rules 

Other 

Over a total of respondents 

75% 

42% 

10% 

73 

74% 

49% 

15% 

76 

62% 

40% 

22% 

69 

Table 4. 

Could  you  specify  for  the  design  and  justifying  of  which  rules  you  would  like  to 
collect identification data on the hosts/owner? 

26%  (9)  need  identification  data  on  hosts/owner  to  manage  tourism  flows  and  design 
housing  market  regulation  policies.  For  the  same  policies,  33%  (12)  and  30%  (11)  of 
authorities  indicate  they  need  identification  data  of  real  estate  units.  Finally,  25%  (8) 
would collect activity data for the same purpose. Real estate unit information would be 
required  by  27%  (10)  of  the  authorities  in  order  to  design  better  health  and  safety 
policies. 

Could  you  specify  for  the  design  and  justifying  of  which  rules  you  would  like  to  collect 
identification data on: 

Taxation 
Security 
Health and safety requirements 
Tourism flows management 
Local housing market regulation 
Other 
Over a total of respondents 

hosts/owner 
22% 
19% 
19% 
26% 
26% 
10% 
34 

real estate unit 
25% 
22% 
27% 
33% 
30% 
7% 
37 

 activity data 
20% 
17% 
16% 
25% 
26% 
7% 
32 

Table 5. 

Could  you  specify  for  the  enforcement  of  which  rules  you  would  like  to  collect 
identification data on the hosts/owner? 

Authorities need data mainly to enforce rules on local housing market. 44% (27) need 
data  on  host/owner  and  real  estate  unit  information  for  this  purpose.  40%  (24)  of  the 
authorities  consider  that  host/owner  information  is  also  important  for  taxation 
enforcement rules. Around 40% (23) of authorities also consider important information 
of real estate units for security and health rules.  

Could you specify for the enforcement of which rules you would like to 
collect: 

Taxation 

Security 

hosts/owner 

real estate unit 

40% 

37% 

36% 

39% 

activity 
data 

33% 

30% 

91 

 
 
 
 
 
  
  
  
  
Health and safety requirements 

Tourism flows management 

Local housing market regulation 

Other 

Over a total of respondents 

36% 

36% 

44% 

11% 

61 

41% 

36% 

48% 

9% 

59 

25% 

37% 

37% 

9% 

50 
Table 6. 

3.  Current collection of identification data by public authorities 

Current collection of data on hosts and real estate units  

A  considerable  percentage  of  authorities  operating  at  national  level  collect  data  from 
hosts via a  registration process  (40%  - 6), whereas  a lower number  of them  use other 
methods  as  contacting  platforms  or  using  alternative  tools.  85%  (11)  of  the  regional 
authorities collect the data through a mandatory registration process. They also consider 
the  other  methods.  23%  (3)  require  the  data  directly  to  the  platform,  use  an  ex-post 
framework  or  use  alternative  tools.  Province  and  municipal  authorities  mostly  collect 
the data through the registration process (39% - 19) or via alternative tools (47% - 23). 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

I require hosts to register, as a  
pre-condition  for  providing  STR 
services 
I get data directly from platforms 
I  require  hosts 
activity ex-post  
(at least once a year) 
I 
collect 
independent/ 
alternative tools  

to  report 

through 

their 

data 

this 

Other 

I do not use any tool to collect data 

Over a total of respondents 

40% 

20% 

13% 

27% 

40% 

7% 

15 

85% 

23% 

23% 

23% 

15% 

8% 

13 

39% 

27% 

22% 

47% 

20% 

14% 

49 

33% 

33% 

0% 

33% 

0% 

33% 

3 

Table 7. Number of respondents: 80 

Type of identification data currently collected 

92% (12) of the regional authorities currently collect identification data on hosts, while 
only 32% (4) are collected identification data on owners. Some province and municipal 
authorities collect identification data both on hosts and owners (53% - 26 and 58% - 28 
respectively).  The  address  of  the  real  estate  unit  is  also  considered  as  crucial 
information by regional authorities. The type and capacity of the unit rented would be 
also asked by all public authorities.  On the contrary, social security number would be 
rarely requested by the authorities at any territorial level. 

National 

Regional 

Province/Municipal  Other 

92 

 
 
 
 
  
  
authority 

authority 

authority 

60% 

92% 

59% 

Name, address and contact details  
(telephone and/or email) of the host 
Name, address and contact details 
 (telephone  and/or  email)  of  the 
owner  

Social Security number of host 

Tax identification number of host 
Address  of  the  real  estate  unit 
rented 
Cadastral 
its 
information 
equivalent under the national law of 
the 
the  Member  State  where 
property is located 
Type of real estate unit rented  
(e.g. room, apartment, house…) 

or 

Capacity of real estate unit rented 
Whether  the  real  estate  unit  is  a 
primary residence,  
secondary residence, or other 

Other 
I do not collect data about hosts and 
real estate  
units rented on a short-term 

Over a total of respondents 

27% 

7% 

33% 

53% 

20% 

53% 

53% 

13% 

47% 

20% 

15 

31% 

8% 

54% 

92% 

38% 

69% 

77% 

15% 

46% 

8% 

13 

53% 

10% 

22% 

78% 

16% 

55% 

49% 

33% 

37% 

20% 

67% 

67% 

0% 

67% 

67% 

33% 

67% 

67% 

33% 

33% 

33% 

49 
Table 2 Number of respondents: 80 

3 

Frequency of collection of identification data 

Most  of  the  authorities  collect  identification  data  of  the  host/owner  on  a  short-time 
basis.  53.8%  (7)  of  the  regional  authorities  collect  this  data  every  year.  On  the  other 
hand, 27.3 % (3) of national authorities collect it every week and 36.4% (4) every year. 
A  considerable  percentage  of  province/municipal  authorities  (25.6%  -  11)  collect  this 
information once.  

93 

 
 
 
  
 
Similar findings apply to the collection of identification data of the real estate unit. 

Figure 5 Number of respondents: 70 

4.  Current collection of activity data by public authorities 

Type of activity data collected and from whom 

Number of nights 

Figure 6.  Number of respondents: 70 

National  
authority 

Regional 
authority 

Province/Municipal 
authority 

I do not collect this data 

Hosts 

Platforms 

19% 

40% 

20% 

39% 

34% 

20% 

69% 

17% 

0% 

94 

Other 

33% 

33% 

33% 

 
 
 
 
 
  
 
 
 
 
Other 
Over 
respondents 

a 

total 

of 

25% 

15 

17% 

13 

7% 

49 

0% 

3 

Table 9 Number of respondents: 80 

Number of guests 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

I do not collect this data 

Hosts 
Platforms 

Other 
Over 
respondents 

a 

total 

of 

27% 

40% 
13% 

20% 

15 

Reason of the booking 

75% 

25% 
0% 

0% 

13 

45% 

38% 
9% 

8% 

49 

Other 

33% 

33% 
33% 

0% 

3 

Table 10. Number of respondents: 80 

National  
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

I  do  not  collect  this 
data 

80% 

Hosts 
Platforms 

Other 
Over 
respondents 

a 

total 

of 

7% 
7% 

7% 

15 

Revenues generated 

100% 

0% 
0% 

0% 

13 

80% 

8% 
4% 

8% 

49 

67% 

33% 
0% 

0% 

3 

Table 11. Number of respondents: 80 

National  
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

I  do  not  collect  this 
data 
Hosts 

Platforms 
Other 
Over 
respondents 

a 

total 

of 

44% 
13% 

26% 
19% 

15 

83% 
8% 

0% 
8% 

13 

80% 
12% 

4% 
4% 

49 

67% 
33% 

0% 
0% 

3 

Table 12. Number of respondents: 80 

Frequency of data collected from hosts 

The  frequency  of  activity  data  collection  varies  greatly  among  public  authorities. 
National  authorities  mostly  collect  data  every  day  (36.4  –  5)  or  on  a  weekly  basis 
(18.2%  -  3).  Similarly,  province/municipal  authorities  collect  their  data  on  a  daily 
(35.7%  -17)  or  weekly  (16.7  –  8)  basis.  Moreover,  19%  (9)  province/municipal 

95 

 
 
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
authorities  collect  this  data  only  once.  On  the  other  hand,  regional  authorities  usually 
access to this data on a daily basis (66.7% - 9). 

Figure 7. Number of respondents: 70 

Frequency of data collected from platforms 

Most of the authorities collect activity data from  platforms  on a daily basis. However, 
provincial/municipal authorities also collect this data only once (25% - 12), on a weekly 
basis (13.6 – 7), or every month (13.6 – 7). 

Figure 8. Number of respondents: 70 

96 

66.733.319.035.716.79.54.814.366.78.38.316.79.136.418.29.127.3OtherProvince/Municipal authorityRegional authorityNational authorityHow often do you collect activity data from hosts?Once onlyReal timeDailyWeeklyMonthlyAnnuallyNot neededOptions33.333.333.325.040.913.613.66.88.383.38.39.163.618.29.1OtherProvince/Municipal authorityRegional authorityNational authorityHow often do you collect activity data from platforms?Once onlyReal timeDailyWeeklyMonthlyAnnuallyOptions 
 
 
 
5.  Current level of co-operation with platforms 

Existence of a legal basis to request data from platforms 

A legal basis to request data from platforms seems to currently exist in half of the cases, 
as shown by figure 9 below. 

Existence of voluntary agreements with online platforms for data sharing 

The vast majority of public authorities do not currently have voluntary agreements with 
online platforms in place. 

Figure 9. Number of respondents: 77 

Among  the  small  number  of  voluntary  agreements,  public  authorities  declare  to  have 
agreements with Airbnb (38.1% - 8), Expedia (19.05% - 4) and Booking (14.29% - 3) in 
place.  

Figure 10. Number of respondents: 78 

97 

66.733.342.651.16.466.733.353.346.7OtherProvince/Municipal authorityRegional authorityNational authorityDoes your national law foresee the possibility for relevant public authorities to request data from platforms?YesNoOtherOptions100.010.489.6100.026.773.3OtherProvince/Municipal authorityRegional authorityNational authorityDo you have voluntary agreements in place with platforms that include a commitment from platforms to share data?YesNoOptions 
 
 
 
 
Figure 11. Number of respondents: 9. Number of total agreements: 21 

Experience with data requests to platforms 

Even though most public authorities declare not to have requests data to platforms ever, 
it  appear  that  public  authorities  at  all  level  have  already  requests  data  to  public 
authorities, and different  types of data (identification data, on hosts, on the real  estate 
unit, and activity data) showing the great diversity of data requests. 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

No,  I  have  never  requested  data 
to platforms 
Identification data on the host 
Identification  data  on  the  real 
estate unit 
Activity data 
Other 
Over a total of respondents 

73% 
7% 

7% 
20% 
13% 
15 

50% 
33% 

25% 
17% 
8% 
12 

Other 

100% 
0% 

53% 
30% 

30% 
26% 
7% 
43 
Table 14 Number of respondents: 73 

0% 
0% 
0% 
3 

If  you  have  already  requested  data  from  (at  least)  a  platform,  please  specify  from 
which one (multiple replies possible): 

Among those that have already requested data from booking platforms, a 31.94% (23) 
of the requests were done to  Airbnb, a 18.06% (13) to  Booking and a 16.67% (12) to 
Expedia.  

98 

38.1%19.05%14.29%4.762%4.762%19.05%AirbnbExpediaBookingFairbnbTripadvisorOtherSpecify which platforms 
 
 
 
  
 
 
 
 
 
 
 
 
Figure 12. Number of respondents: 27. Number of total requests: 72 

Public authorities declare that their data requests are not always answered by platforms, 
showing the difficulty of public authorities in accessing the data on STRs. In the next 
plot  we  can  observe  the  evolution  of  data  request  by  public  authorities  (17)  over  the 
years compared to the number of requests addressed by platforms. 

Format of data requests (e.g. based on registration numbers) 

Figure 133. Number of respondents: 17 

Authorities’ requests are mostly based on the name, address and  contact  details of the 
host.  However,  a  considerable  percentage  of  regional  authorities  also  base  their  data 

99 

31.94%18.06%16.67%9.722%1.389%22.22%AirbnbBookingExpediaTripadvisorFairbnbOtherSpecify which platforms050100150200250Number of requests20142016201820202022YearRequests for data you filed to platformsRequests that were addressed by platforms 
 
 
 
 
requests  on  the  local  or  national  registration  number  (80%  -  4).  This  shows  the  great 
diversity in the format of data requests overall. 

National  
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

Local  or  National  registration 
number 
Name,  address,  and  contact 
details of the host 

Social Security number 

Other 
Over a total of respondents 

40% 

80% 

0% 

40% 
5 

80% 

80% 

0% 

60% 
5 

29% 

59% 

0% 

- 

- 

- 

41% 
17 
Table 15 Number of respondents: 27 

- 
- 

Requests rejected by online platforms and reasons  

A  small  number  of  authorities  agree  in  that  platforms  always  collaborate  in  the  data 
sharing process. On the other hand, among the respondents, a 60% of the national and 
regional authorities (3) and a 89% (16) of the municipal authorities report that booking 
platforms  refused  to  share  data,  mainly  due  to  legal  reasons.  This  again  stresses  the 
difficulties faced by public authorities in accessing STR data. 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

platforms  were 

No, 
collaborative 

always 

They claim not to have the data 
Legal  reasons  (e.g.  no  legal  basis 
for providing  
the  data,  possible  violation  of 
GDPR) 
Technical  difficulties (e.g. resource 
or time 
intensive exercise for platforms) 
They  claim  they  have  already 
shared  the  same  or  similar  data 
with  another  Public  Authority  in 
the Member State 

Other 

Over a total of respondents 

-    

-    

-    

-    

-    

-    

6% 

17% 

18 
Table 16 Number of respondents: 28 

-    

20% 

20% 

20% 

20% 

6% 

22% 

60% 

60% 

89% 

0% 

0% 

28% 

0% 

60% 

5 

0% 

40% 

5 

100 

 
 
  
 
 
 
 
 
 
 
  
 
             
 
             
 
             
 
             
 
             
 
             
 
             
 
6.  Activity data on other tourism businesses 

Activity data on other tourism businesses (e.g. hotels)  

All  the  authorities  collect  information  from  other  businesses  in  the  tourism  sector,  in 
particular  hotels  and  hostels.  67%  (10)  of  national  authorities  collect  data  from  both 
type of business.  

No,  I  do  not  collect  data  from 
other tourism businesses 
Hotels 
Hostels 
Other 
short-stay 
daily 
accommodation 
cleaning,  bed-making,  food  and  
beverage services 
Other 
Over a total of respondents 

furnished 

with 

National 
authority 

Regional 
authority 

Province/Municipal 
authority 

Other 

27% 
67% 
67% 

33% 
73% 
15 

42% 
50% 
33% 

17% 
92% 
12 

45% 
59% 
43% 

67% 
33% 
33% 

32% 
84% 
44 
Table 16 Number of respondents: 74 

33% 
100% 
3 

Frequency on data requests to other tourism businesses 

Public authorities mainly collect this data on a monthly basis.  

Figure 15. Number of respondents: 50 

101 

100.028.115.621.934.442.914.342.950.010.040.0OtherProvince/Municipal authorityRegional authorityNational authorityHow often you collect data from other tourism businesses?MonthlyBi-annuallyAnnuallyOtherOptions 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX  2B:  RESULTS  OF  THE  ADDITIONAL  TARGETED  SURVEY  TO 

PLATFORMS 

The  targeted  survey  to  platforms  complemented  the  results  of  the  public  consultation 
and  gathered  additional  information  on  the  data  sharing  requests  received  by  online 
booking  platforms  from  public  authorities.  The  survey  investigated  the  modalities  of 
such requests (timing and frequency), the tools used to share data and the purposes for 
which such data is requested. The targeted survey to platforms was open from 13 April 
to 13 May 2022 and it was communicated via a targeted email campaign. 15 responses 
were  received  from  online  booking  platforms  of  all  sizes  (from  one  city  in  1  EU 
Member State to more than 4 EU Member States). The results are presented both in a 
aggregated manner (for the 15 platforms) and also based on the size of the respondent. 

1.  Identification of Respondents 

Online  booking  platforms  were  asked  to  identify  themselves  based  on  the  number  of 
Member  States  in  which  they  operate.  10  platforms  operate  in  more  than  4  Member 
States.  One  platform  operates  in  2  to  4  Member  States.  4  platforms  operate  in  one 
Member  State  only.  Among  those  platforms,  one  operates  in  more  than  one  region 
(6.7%) and three operate in one city of the Member State (20%). 

Respondents  were  also  asked  to  confirm  where  their  headquarter  is  located.  A  large 
number of the main platforms are located in Germany (26.7% - 4) and Ireland (26.7% - 
4). The rest of platforms locate their headquarters in different European member states 
(UK,  Finland,  Netherlands,  Switzerland,  Italy  and  Denmark).  Moreover,  one  of  them 
(6.7%) locate their headquarter in two locations, UK and Denmark. 

102 

66.7%6.7%6.7%20.0%In more than 4 EU MSIn 2 to 4 EU MSIn more than one regionIn one city of 1 EU MSwithin 1 MSSize of the booking platform 
 
 
2.  Data sharing requests filled by public authorities 

Most of the booking platforms indicate that they have ever received a data request from 
a public authority (80% - 12). 

The three platforms who have never received a data request from a public authority are 
one that operates in more than 4 EU Member States, and 2 who operate in one city only. 

Figure 4. Number of respondents: 15 

103 

26.7%26.7%6.7%6.7%6.7%6.7%6.7%6.7%6.7%GermanyIrelandUKDenmark & UKFinlandNetherlandsSwitzerlandItalyDemarkWhere the booking platform headquarter is located 80.020.0Have you ever received a data request from a public authority?YesNoOptions 
 
 
 
Type of data requested 

Identification data 

The  table  1  below  shows  the  type  of  identification  data  of  the  host/owner  that  was 
requested by public authorities. 

Identification data of the host/owner (multiple replies possible): 
Name, address and contact details (telephone and/or email) of the host 
Name, address and contact details (telephone and/or email) of the owner 
(if different from the host);Address of the real estate unit rented 
Social Security number of host 
Tax identification number of host 
Address of the real estate unit rented 
Cadastral information of the real estate unit rented 
Type of real estate unit rented (e.g. room, 
Capacity of real estate unit rented (e.g. number of beds) 
Whether the real estate unit is a primary residence 
Other 
Total replies 

Number of 
replies 
9 

Percentage 
75% 

16.7% 
16.7% 
41.7% 
66.7% 
8.3% 
33.3% 
8.3% 
25% 
66.7% 
12 
Table 2. Number of respondents: 12 

2 
2 
5 
8 
1 
4 
1 
3 
8 
12 

The  table  below  shows  the  breakdown  of  the  type  of  data  requested  to  platforms  of 
different  sizes.  This  shows  the  great  variety  of  the  type  of  data  requested  to  different 
types of platforms across the EU. 

Name, address and contact details  
(telephone and/or email) of the host 
Name, address and contact details  

In more than 
4 EU MS 

In 2 to 4 
EU MS 

In one city 
of 1 EU MS 

Other 

In more than 
one region 
within 1 EU 
MS 

87.5% 
50% 

0% 
0% 

100% 
100% 

33.3% 
0% 

0% 
0% 

104 

66.733.3100.0100.080.020.0In one city of 1 EU MSIn more than one region within 1 EU MSIn 2 to 4 EU MSIn more than 4 EU MSHave you ever received a data request from a public authority?YesNoOptions 
 
 
  
  
  
  
(telephone and/or email) of the owner  
(if different from the host) 
Social Security number of host 
Tax identification number of host 
Address of the real estate unit rented 
Cadastral information of the real estate  
unit rented 
Type of real estate unit rented (e.g. room, 
Capacity of real estate unit rented  
(e.g. number of beds) 
Whether the real estate unit is a  
primary residence 
Other 
Total replies by respondent 

Activity data 

25% 

50% 
87.5% 

13% 
38% 

12.5% 

37.5% 
50% 
8 

0% 

0% 
0% 

0% 
0% 

0% 

0% 
100% 
1 

0% 

0% 
100% 

0% 
100% 

0% 

0% 
100% 
1 

0% 

33.3% 
0% 

0% 
0% 

0% 

0% 
0% 
3 

0% 

0% 
0% 

0% 
0% 

0% 

0% 
0% 
0 

Online  platforms  have  been  requested  to  share  different  types  of  activity  data  with 
public  authorities,  and  mainly  the  number  of  nights  that  the  real  estate  unit  has  been 
rented  out  (75%  -  9)  and  the  revenues  generated  by  the  STR  activity  (75%  -  9). 
However,  other  types  of  activity  data  have  also  been  requested  to  online  platforms 
which shows the great variety of data requests. 

Activity data (multiple replies possible): 

Number of nights the real estate unit has been rented 
Number of guests hosted 
Reason of the booking of the guest (leisure/business/other) 
Revenues generated by the short-term rental activity 
Other [please specify] 
Total replies 

Number of 
replies 
9 
4 
3 
9 
5 
12 

Percentage 
75% 
33.3% 
25% 
75% 
41.7% 
12 
Table 3. Number of respondents: 12 

The  table  below  gives  additional  information,  with  a  breakdown  by  size  of  online 
platform. 

In more 
than 4 
EU MS 

In 2 to 4 
EU MS 

In more than 
one region 
within 1 EU MS 

In one 
city of 1 
EU MS 

Other 

Number of nights the real estate unit has been 
rented 
Number of guests hosted 
Reason of the booking of the guest 
(leisure/business/other) 
Revenues generated by the short-term rental 

100% 
25% 

13% 
63% 

100% 
100% 

0% 
100% 

0% 
0% 

0% 
0% 

0% 
0% 

0% 
0% 

0% 
0% 

0% 
0% 

105 

 
 
 
 
 
  
  
 
 
 
 
 
  
 
 
 
 
 
activity 

Other [please specify] 
Total replies by respondent 

Origin of the request  

13% 
8 

0% 
1 

0% 
1 

0% 
1 

0% 
2 

The  table  below  shows  the  origin  of  data  requests.  It  shows  that  data  requests  come 
from  almost  all  Member  States  and  all  levels  of  government,  stressing  the  high 
fragmentation with regards to data sharing on STR data in the EU. 

Member State  

National 

Regional 

Local 

Austria 

Belgium 

Croatia 

Czech Republic 

Denmark 

Estonia 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

1 

1 

1 

0 

3 

1 

4 

1 

2 

1 

4 

2 

1 

1 

2 

0 

0 

0 

3 

1 

106 

4 

2 

1 

2 

0 

0 

3 

3 

0 

0 

0 

1 

1 

1 

0 

1 

0 

1 

4 

0 

4 

2 

1 

3 

0 

0 

5 

7 

0 

0 

1 

1 

2 

1 

0 

1 

1 

1 

3 

0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total 

29 

24 

33 

Estimation of the number of requests received and answered 

The graph below shows that the number of requests has increased over the years, with a 
slight  decrease  in  2021  which  can  be  explained  by  the  COVID  crisis.  The  number  of 
data requests answered, in turn, has remained very low over the years.  

Frequency of data requests 

While most platforms declare to receive annual requests, the frequency of data requests 
still  varies  greatly,  and  respondents  also  indicate  that  the  frequency  even  varied 
depending on the public authorities issuing the request. 

Ad hoc requests 

Weekly 
Monthly 
Annually 
The frequency varies depending on the public authority 
Other 
Total replies 

Number of replies 
1 
1 
9 
3 
2 
12 
Table 4. Number of respondents: 12 

Percentage 
8% 
8% 
75% 
25% 
17% 
12 

The table below offers a further breakdown based on the size of the online platform. 

In more than 4 EU 
Member States 

In 2 to 4 EU 
Member States 

Weekly 
Monthly 
Annually 
The frequency varies 

13% 
13% 
88% 
38% 

0% 
0% 
100% 
0% 

In more than one region 
within 1 EU Member 
State 
0% 
0% 
0% 
0% 

In one city of 1 EU 
Member States 

0% 
0% 
50% 
0% 

107 

0500100015002000Number of requests20172018201920202021YearNumber of requestsNumber of requests answered 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
depending on the public 
authority 
Other 
Over a total of 
respondents 
Divergence and similarities of data requests 

13% 

8 

0% 

1 

0% 

0 

50% 

2 

Figure 2 shows the degree of divergence with regards to the type of data requests, the 
format, the frequency, and the technical means used to transfer the data. Overall, online 
platforms have very different experiences with regards to these four aspects, while some 
have  experiences  similarities  among  data  requests,  and  other  have  experienced  very 
divergent requests. 

The  figures  below  offer  an  additional  breakdown  based  on  the  size  of  the  online 
platform for each category. 

Figure 5. Number of respondents: 12 

108 

50.033.316.7Type of data requested 41.78.38.316.725.0Format of data requested 33.316.716.716.716.7Frequency of data asked 33.316.750.0Technical means used for transmitting the dataVery SimilarSomewhat SimilarNeutralSomewhat DivergentVery DivergentOptions100.0100.0100.037.537.525.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU METype of data requested Very SimilarSomewhat SimilarVery DivergentOptions 
 
 
 
 
 
Harmonizing data sharing at EU level: what impact in terms of costs  

Most online platforms believe that a harmonization of data sharing requirements at EU 
level will have a positive impact in terms of cost reduction.  

109 

100.0100.0100.025.012.512.512.537.5In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEFormat of data requested Very SimilarSomewhat SimilarNeutralSomewhat DivergentVery DivergentOptions100.0100.0100.025.025.012.512.525.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEFrequency of data asked Very SimilarSomewhat SimilarNeutralSomewhat DivergentVery DivergentOptions100.0100.0100.012.512.575.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU METechnical means used for transmitting the dataVery SimilarNeutralVery DivergentOptions 
 
 
 
 
The  figures  below  offer  an  additional  breakdown  based  on  the  size  of  the  online 
platform for each category. 

Figure 6. Number of respondents: 12 

110 

9.136.418.236.4Type of data requested8.333.316.741.7Format of data requested9.136.454.5Frequency of data asked8.333.350.08.3Technical means used for transmitting the dataVery negative impactNeutralPositive impactVery positive impactOptions100.0100.0100.028.628.642.9In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU METype of data requestedVery negative impactNeutralPositive impactVery positive impactOptions 
 
 
 
 
111 

100.0100.0100.025.025.050.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEFormat of data requestedVery negative impactNeutralPositive impactVery positive impactOptions100.0100.0100.028.671.4In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEFrequency of data askedVery negative impactNeutralVery positive impactOptions100.0100.0100.025.062.512.5In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU METechnical means used for transmitting the dataVery negative impactNeutralVery positive impactOtherOptions 
 
 
 
 
 
Costs related to data requests (in FTEs) 

The  table  below  shows  the  costs  declared  by  online  platforms  for  each  step  of  data 
sharing  requests.  Overall,  this  table  shows  that  answering  data  sharing  requests  is  a 
costly procedure, and therefore the  costs for online platforms are expected to  increase 
without a streamlining of data sharing procedures at EU level. 

Legal 
assessment 
of the 
request 
30% 
30% 
30% 
10% 
0% 

Gathering 
the 
requested 
data 
20% 
30% 
30% 
10% 
10% 

Preparing 
the data 
for the 
sharing 
18% 
36% 
27% 
9% 
9% 

10 

10 

11 

Transmitting 
the data 

Communication 
with public 
authorities 

Ex-post 
follow up 
needed 

Other 

20% 
60% 
20% 
0% 
0% 

10 

18% 
45% 
27% 
0% 
9% 

11 

30% 
40% 
20% 
0% 
10% 

10 

100% 
0% 
0% 
0% 
0% 

2 

0 FTE 
1-2 FTE 
3-4 FTE 
5-6 FTE 
over 6 FTE 
Total number of 
replies 

The  figures  below  offer  an  additional  breakdown  based  on  the  size  of  the  online 
platform for each category. 

112 

25.025.025.08.316.7Legal assessment of the request20.030.030.010.010.0Gathering the requested data20.040.030.010.0Preparing the data for the sharing18.254.518.29.1Transmitting the data16.741.725.08.38.3Communication with public authorities27.336.418.29.19.1Ex-post follow up needed0 FTE1-2 FTE3-4 FTE5-6 FTEOtherOptions 
 
  
  
 
 
 
113 

50.050.0100.0100.012.525.025.012.525.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MELegal assessment of the request0 FTE1-2 FTE3-4 FTE5-6 FTEOtherOptions50.050.0100.042.928.614.314.3In one city of 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEGathering the requested data0 FTE1-2 FTE3-4 FTE5-6 FTEOtherOptions50.050.0100.057.128.614.3In one city of 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEPreparing the data for the sharing0 FTE1-2 FTE3-4 FTEOtherOptions 
 
 
 
 
 
114 

50.050.0100.075.012.512.5In one city of 1 EU MEIn 2 to 4 EU MEIn more than 4 EU METransmitting the data0 FTE1-2 FTE3-4 FTEOtherOptions50.050.0100.0100.050.025.012.512.5In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MECommunication with public authorities0 FTE1-2 FTE3-4 FTEOver 6 FTEOtherOptions50.050.0100.012.550.012.512.512.5In one city of 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEEx-post follow up needed0 FTE1-2 FTE3-4 FTEOver 6 FTEOtherOptions 
 
 
 
 
Data requests leading to the substantial changes of online platforms’ websites (in order 
to request additional data to hosts or guests)  

Data  requests  by  public  authorities  could  affect  booking  platforms  altering  their 
interface or working methods. Concretely, 41.7% (5) of the platforms confirm that they 
have changed their website multiple times. 1 platform changed it once following a data 
requests. 3 platforms did not alter their product or change their website. 

The  figure  below  offers  an  additional  breakdown  based  on  the  size  of  the  online 
platform for each category. 

Figure 7. Number of respondents: 12 

If  yes,  how  costly  was  it?  Please  provide  evidence  of  such  costs,  if  available,  as  an 
attachment at the end of this survey. 

Among  the  platforms  that  altered  their  website  due  to  the  data  requests  from  public 
authorities, one (16.7%) consider the impact as very costly for their business and other 2 
(33.3%) consider that the changes created some impact on them, assuming certain costs. 

115 

41.7%8.3%8.3%25.0%16.7%Yes, my company needed to changeYes, my company needed to changeNo, my company requiredMy company neverOtheraltered its producthosts to report extra informationits website onceits website multiple timesHave you adapted your website because of a data request by PA?100.0100.0100.037.512.512.512.525.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEHave you adapted your website because of a data request by PA? Yes, website was changed multiple timesYes, website was changed onceNo, hosts/guests had to report additionat dataProducts weren't altered and additional information wasn'r neededOther 
 
 
 
Among those that change their website due to data requests, only two operating in more 
than  4  countries  (50%  -  2)  and  one  operating  in  more  than  one  region  within  one 
member state (100% - 1) consider that the adaptation has a considerable impact.  

Figure 8. Number of respondents: 6 

Purposes of data requests 

The  table  below  shows  the  wide  variety  of  reasons  put  forward  by  public  authorities 
when  requesting  data  to  online  platforms:  taxation  purposes  (declared  by  91.7%  -  11 
online  platforms),  local  housing  market  regulation  (83.3%  -  10),  or  health  and  safety 
requirements (41.7% - 5). 

Answers 

Taxation 
Security 
Health and safety requirements 

Number of replies 
11 
3 
5 

Percentage 
91.7% 
25% 
41.7% 

116 

50.033.316.7How costly was it?Normal impact, like other processesSomewhat impactfulVery costly and impactfulOptions100.0100.050.025.025.0In more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEHow costly was it?Normal impact, like other processesSomewhat impactfulVery costly and impactfulOptions 
 
 
 
  
  
Tourism flows management 
Local housing market regulation 
Statistics 
Reason was not disclosed 
Other 
Total replies  

3 
10 
5 
3 
0 
12 

25% 
83.3% 
41.7% 
25% 
0% 
12 

Table 5. Number of respondents: 12 

The table below offers an additional breakdown based on the size of the online platform 
for each purpose. 

In more than 4 EU 
Member States 

in 2 to 4 EU 
Member States 

In more than 
one region 
within 1 EU 
Member State 

In one city of 1 
EU Member 
States 

Taxation 
Security 
Health and safety requirements 
Tourism flows management 
Local housing market regulation 
Statistics 
Reason was not disclosed 
Other 
Total replies by respondent 

100% 
37.5% 
50% 
37.5% 
87.5% 
62.5% 
37.5% 
0% 
8 

100% 
0% 
100% 
0% 
100% 
0% 
0% 
0% 
1 

100% 
0% 
0% 
0% 
100% 
0% 
0% 
0% 
1 

50% 
0% 
0% 
0% 
50% 
0% 
0% 
0% 
2 

3.  Current level of cooperation with public authorities 

Voluntary agreements for data sharing  

Four  (26.7%)  booking  platforms  already  have  a  voluntary  agreement  in  place  with 
public authorities for data sharing. These are mainly platforms who operate in more than 
4 Member State, and those that operate only in one city. Respondents indicate that they 
have  such  agreement  in  place  for  instance  with  Eurostat,  the  Greek  authorities  or  the 
Irish authorities. Most of the platforms (73.3% - 11) have no agreement in place.  

117 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
Figure 9.Number of respondents: 15 

Format of the data requests (e.g. registration number, or other personal data) 

Online platforms report a great fragmentation in terms of format of data requests. 40% 
(6) platforms indicate that some data requests are based on registration numbers. 20% 
(3) specify that the vast majority of the requests are based on registration numbers while 
the  remaining  platforms  indicate  that  these  requests  are  based  on  other  data  from  the 
host. 

118 

26.7%73.3%YesNoDo you have voluntary agreements in place with public authorities to share data on STRs?33.366.7100.0100.030.070.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEDo you have voluntary agreements in place with public authorities to share data on STRs?YesNoOptions 
 
 
 
 
 
Figure 10. Number of respondents: 15 

The  figure  below  offers  an  additional  breakdown  based  on  the  size  of  the  online 
platform. 

Obligation to display registration numbers  

Most  platforms  declare  that  they  are  currently  required  to  display  registration  number 
(73.3% - 11).  

119 

20.0%40.0%26.7%13.3%The vast majority of data requestsSome data requests are based onAll requests are based on otherOtherare based on registration numbersregistration numbersdata from the hostWhat is the format of the data requests?33.333.333.3100.0100.020.050.020.010.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEWhat is the format of the data requests?The vast majority of data requests are based on registration numbersSome data requests are based on registration numbersAll requests are based on other personal data of the hostOther 
 
 
 
 
 
 
 
The  figure  below  offers  an  additional  breakdown  based  on  the  size  of  the  online 
platform. 

Figure 11. Number of respondents: 15 

Denial of data requests 

Almost  half  of  the  platforms  declare  that  they  have  already  denied  an  access  to  data 
request. 

120 

73.3%26.7%YesNo66.733.3100.0100.080.020.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEYesNoOptions 
 
 
 
 
The  figure  below  offers  an  additional  breakdown  based  on  the  size  of  the  online 
platform. 

Figure 12. Number of respondents: 15 

Reasons for denying data requests 

Online  platforms  put  forward  a  number  of  reasons  to  justify  such  denial.  33%  (4)  of 
them  allege  that  they  do  not  have  the  needed  data  and  42%  (5)  state  that  they  do  not 
share  it  due  to  legal  reasons.  Two  platforms  allege  they  do  not  share  the  date  due  to 
technical difficulties and only one attribute it to the cost. 

121 

46.7%53.3%YesNoHas your company ever rejected/denied a data request from a public authority?100.0100.0100.050.050.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEHas your company ever rejected/denied a data request from a public authority?YesNoOptions 
 
 
 
 
 
Answers 
Your company did not have the data 
Legal reasons (e.g. no legal basis for providing the data 
Technical difficulties (e.g. absence of efficient technical means 
to share the data) 
Costs (e.g. lack of resources) 
Other 

Total replies  

Number 
of 
replies 
4 
5 

Percentage 
33% 
42% 

2 
1 
0 

12 

17% 
8% 
0% 

12  

The table below offers an additional breakdown based on the size of the online platform 
for each reason. 

In more 
than 4 EU 
Member 
States 

In 2 to 4 
EU 
Member 
States 

Your company did not have the data 
Legal reasons 
Technical difficulties 
Costs 
Other 
Over a total of respondents 

33% 
44% 
22% 
0% 
0% 

9 

0% 
100% 
0% 
0% 
0% 

1 

In more 
than one 
region 
within 1 
EU 
Member 
State 
50% 
0% 
0% 
50% 
0% 

2 

In one city 
of 1 EU 
Member 
States 

0% 
0% 
0% 
0% 
0% 

0 

Challenging data requests in court 

26.7% (4) of online platforms even declare to have challenged data requests in courts. 
These challenges were initiated exclusively by platforms operating in more than 4 EU 
Member States (larger platforms). 

122 

 
 
  
  
                            
 
  
 
 
 
 
 
 
 
 
 
 
Figure 13. Number of respondents: 15 

123 

26.7%73.3%YesNoHave you ever challenged a data request in court?100.0100.0100.040.060.0In one city of 1 EU MEIn more than one region within 1 EU MEIn 2 to 4 EU MEIn more than 4 EU MEHave you ever challenged a data request in court?YesNoOptions 
 
 
 
 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  Practical implications of the initiative 

The initiative will concern mainly online platforms and public authorities. 

Public authorities: under the preferred option 2, public authorities will be able to opt in 
in the data-sharing framework and have transparency over the STR segment’s services 
in  their area.  Local  public authorities will need to adjust existing registration schemes 
(or create new one if needed). National public authorities will be responsible to set up a 
single  point  of  contact  (single  digital  entry  point)  for  the  interactions  with  online 
platforms,  allowing  them  to  have  efficient  data-sharing  processes.  With this  initiative, 
public  authorities  will  receive  solid  and  timely  data  on  the  STR  segment  facilitating 
their STR-related activities (e.g. reallocation of resources made available by a facilitated 
enforcement of STR rules).  

Online  platforms,  under  the  preferred  option,  will  have  to  report  activity  data  and 
develop  automated  connections  with  public  authorities  (only  the  biggest  ones).  They 
will  share  data  through  a  single  digital  entry  point,  ensuring  timely  and  reliable  data 
sharing  operations.  Micro  platforms  will  still  be  allowed  to  report  through  a  manual 
option in the relevant national single digital entry point.  

Hosts 

Without the initiative, platforms will face a growing pressure from public authorities to 
share data. The initiative will ensure legal certainty and optimise data sharing processes 
across Europe. 

In sum, the legislative initiative under the preferred option includes the following: 

  Obligation on local public authorities to maintain a registration system for hosts  
  Obligation on national public authorities to maintain a single point of contact 

with online platforms for information and data sharing  

  Obligation on platforms to ensure the display of registration numbers 
  Obligation on platforms to share activity data  

2.  Summary of costs and benefits 

A synopsis of the cost-benefit of the different policy options based on the considerations 
and the data in Annex 4 is reported in the two tables below. In particular, section 4.4 of 
Annex 4 can be summarised as follows, in absolute and relative values, with respect to 
the baseline. 

124 

 
 
 
 
 
 
Table 1 - Overview of Benefits (total for all provisions) – Preferred Option 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Comments 

Direct benefits 

faster 
and 
Easier 
registration  scheme  for 
hosts 
(Economic 
benefits) 

Savings  for  hosts  of  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 
first  5  years  after 
the 
areas) 
(based  on  baseline 
implementation 
number  of  2019  and  growth 
rate 
estimations. 

in 

Based on the assumption that 87% of the 
hosts  are  peers195 and  13%  professional 
hosts,  the  cumulative  cost  savings  for 
citizens  over  five  are  estimated  at 
around EUR 1287.6 million. 

Adapting/Creating  local  registration 
schemes  based  on  a  defined  EU 
template  will  reduce  the  minimum 
time  (and  hence  costs)  associated 
with  registration  for  hosts  where 
registration is required. 

Streamlined 
data-
sharing  framework  for 
across 
platforms 
Europe 
(Economic 
benefits) 

Savings  for  online  platforms  over  a 
period  of  5  years  will  amount 
to 
between EUR 54 million (based on 800 
requests per year) and EUR 115 million 
(based on 1700 requests per year) 

The  data-sharing  infrastructure  will 
help  online  platforms  to  share  data, 
requests 
avoiding  uncoordinated 
from Public authorities 

Reliable 
data-sharing 
framework  for  public 
authorities 
with 
appetite  for  data  across 
(Economic, 
Europe 
Social 
and 
Environmental 
benefits) 

Indirect benefits 

Less litigations with platforms to obtain 
data  and  knowledge  to  better  address 
STR activities (Not quantifiable) 

The  data-sharing  infrastructure  will 
secure  public  authorities  with  the 
legal  basis  and  technical  tools  to 
request  and  obtain  data 
from 
platforms 

195 Hosts having max 2 listings. 

125 

 
 
                                                           
Predictability  of 
the 
volumes  of  tourists  for 
other  operators  in  the 
tourism ecosystem 

(Not quantifiable) 

Better  transparency  will  translate  in 
better  knowledge  and  predictability 
of 
touristic 
operators,  which  will  be  more 
equipped to adapt their offers 

segment 

the 

for 

Administrative cost savings related to the ‘one in, one out’ approach* 

Structured  data  sharing 
process  for  platforms 
across 
Europe 
(Economic benefits) 

Savings  for  online  platforms  over  a 
to 
period  of  5  years  will  amount 
between EUR 54 million (based on 800 
requests per year) and EUR 115 million 
(based on 1700 requests per year) 

The  data-sharing  infrastructure  will 
share  data, 
help  Platforms 
avoiding  uncoordinated 
requests 
from Public authorities 

to 

faster 
and 
Easier 
registration  scheme  for 
hosts 
(Economic 
benefits) 

Savings  for  hosts  of  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 
first  5  years  after 
the 
areas) 
(based  on  baseline 
implementation 
number  of  2019  and  growth 
rate 
estimations. 

in 

Based on the assumption that 87% of the 
hosts  are  peers196 and  13%  professional 
hosts,  the  cumulative  cost  savings  for 
citizens  over  five  are  estimated  at 
around EUR 1287.6 million. 

Table 2 - Overview of costs – Preferred option 

II. Overview of costs – Preferred option 

Citizens  (hosts peers)  Business 

and 
hosts)_ 

(platforms 
professional 

Public  Administrations 
(national and local) 

196 Hosts having max 2 listings. 

126 

 
 
 
 
 
                                                           
One-off  Recurrent 

One-off  Recurrent 

One-off 

Recurrent 

(yearly) 

(yearly) 

(yearly) 

Direct 
adjustment 
costs 

€ 

5.96 

EUR 
million 
(registration 
costs for new 
hosts)198 

EUR  8.2 
million 
for 
online 
platform 
for  API 
connecti
ons  

EUR 
2 
million  for 
large 
platforms 
for  hosting 
and 
maintenanc
e 

EUR 
1.6 
million  for 
and 
small 
micro 
platforms 
that  would 
qualify  for 
more 
lenient 
reporting 
obligations 

EUR  3.87 
for 
new 
professiona
l  hosts  for 
registration 

EUR  3  million 
national 
for 
to 
authorities 
setup 
the 
infrastructure 
for 
registration 
schemes 
and 
the 
develop 
national  single 
digital 
entry 
point 

the 

3.6 
for 

 EUR 
million 
local 
authorities  for 
IT 
infrastructure 

2.4 

EUR 
million 
hosting and 
maintenanc
e 
for 
national 
authorities 

4.2 

EUR 
million 
hosting and 
maintenanc
e  for  local 
authorities 

197 

of 

EUR 
97.44
million 
(registrati
on 
current 
hosts) 

Data-
sharing 
infrastr
ucture  

Direct 
administrative 
costs 

Direct 
regulatory  fees 
and charges 

197 87% of hosts are peers (citizens). One-off costs for all hosts estimated at EUR 112,4 million 
198  Average annual cost of the cumulative administrative costs for citizens over five are estimated at 
around EUR 149 million. 

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Direct 
enforcement 
costs 

Indirect costs 

Costs related to the ‘one in, one out’ approach 

Direct 
adjustment 
costs  

Indirect 
adjustment 
costs 

Total   

Administrative 
costs 
(for 
offsetting) 

199 

of 

EUR 
97.44
million 
(registrati
on 
current 
hosts) 

n/a 

n/a 

5.96 

EUR 
million 
(registration 
costs for new 
hosts)200 

EUR  8.2 
million 
for 
online 
platform 
for  API 
connecti
ons 

EUR  7.47 
million 
201 (cumulati
ve  for  all 
type 
of 
business 
stakeholder
s impacted)  

3.  Relevant sustainable development goals 

Table  3  -  Overview  of  relevant  Sustainable  Development  Goals  –  Preferred 
Option(s) 

III. Overview of relevant Sustainable Development Goals – Preferred Option(s) 

Relevant SDG 

Expected progress towards the Goal  Comments 

SDG 

no. 

11 

– Increase in access to data to allow public  This  initiative  will  not  regulate  STR 

199 87% of hosts are peers (citizens). One-off costs for all hosts estimated at EUR 112,4 million 
200 This costs will be offset by savings for hosts due to shorter registration estimated at  EUR 257.52 
million 
201 This cost will be offset by annual costs savings for platforms due to streamlined data requested 
estimated at EUR 10.8-20.3 million 

128 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
sustainable  cities  and 
communities 

in  order 

authorities  to  design  proportionate  STR 
policies,  e.g. 
to  ensure 
availability of affordable housing, protect 
the  urban  environment  and  redirect 
tourism  flows  from  urban  to  pre-urban 
and rural areas. 

on substance but only give tools and 
a  clear  legal  framework  enhance 
transparency  in  the  STR  segment. 
The  impact  of  this  initiative  on  the 
SDGs  is  hence  indirect,  as  it  will 
depend  on  the  regulatory  actions  of 
public authorities. 

ANNEX 4: ANALYTICAL METHODS & SME TEST 

DISCLAIMER:  Data  and  calculations  presented  in  this  Annex  and  used  in  the  body 
text  of the  Impact  Assessment are made based on estimation,  projections and proxies. 
No exact data are available on the STR segment, core problem assessed by this initiative 
itself.  Therefore,  specific  hypothesis  are  made  in  order  to  build  the  below  reasoning. 
When  possible,  quantification  is  made  in  ranges.  Please  refer  to  the  reasoning  below 
taking it into account.  

4.1 STR MARKET PLAYERS: HOSTS AND MAIN PLATFORMS 

The number of hosts is expected to almost double in 2025 with respect data of 2019 and 
grow by 185% by 2030.202 

Table 1 – Number of hosts and platforms 

202 Estimations on unique hosts in EU made by JRC based on listings registered in 2019 (AIRDNA data) 
and growth rate based on the evolution of the market and historical data. 

129 

 
 
 
                                                           
The table above also indicates the number of online platforms and property managers in 
2019. In the data, we observe 142 platforms that represent 80% of total internet traffic 
to STR sites. Assuming a Pareto rule (80-20 proportion) these platforms represent 20% 
of all platforms operating in the STR segment. This means that the number of platforms 
representing  the  missing  80%  of  operators  covering  the  remaining  20%  of  traffic  is 
equal to 568. This makes a total number of platforms to be 710. In the cost calculations, 
under Policy Options 2 and 3, it is assumed that 30 companies will need to connect to 
single digital entry points and 680 would qualify for more lenient reporting obligations. 
Unfortunately,  detailed  information  is  not  available  for  all  countries.  However,  the 
countries  for  which  data  is  missing  are  those  that  have  the  lowest  number  of  listing 
across the EU. This has been taken into consideration in the assessment of the costs of 
the impact of the initiative by taking the most conservative value of costs estimation. 

4.2 COSTS LINKED WITH STR ACTIVITY IN THE BASELINE SCENARIO 

Under the status quo scenario, the STR activity across the EU is characterised by many 
different types of costs for stakeholders. Below a cost model for hosts’ registration and 
data-sharing  requests  for  platforms  has  been  identified.  Modelling  other  costs  linked 
with high number of litigations, poor law enforcement or delay in policy making is not 
possible.  

130 

 
 
 
Registration for hosts 

In  order  to  determine  the  costs  associated  with  registration  of  hosts,  the  total  sum  of 
hosts  identified  in  20  Member  States 203 during  a  survey  conducted  in  2021  by  DG 
GROW is taken into account. Of the total hosts identified in these 20 MS, we consider 
that  40%  (conservative  approach)  are  in  areas  where  some  identification  process  is  in 
place (registration scheme or other). 

Table 2 – Costs for Hosts’ registration in the baseline scenario 

Estimation  of  hosts’  growth  has  been  taken  into  consideration  for  2025  and  2030.  To 
identify the average number of days needed to complete registrations across the EU, the 
study  by  Oxford  Research  has  been  used.204 In  the  study,  the  average  number  of  days 
needed  to  complete  registration  is  28  days. 205  However,  this  calculation  takes  into 
account  extreme values (as those imposed by the system of Berlin, reaching 70+ days 
for  completion).  For  the  purpose  of  this  exercise,  an  adjusted  average  without  the 
outliers has been estimated, equal  to  ~15 days.  Computing this data with the average 
hourly salary indicated in the One In – One Out (OIOO) tool, the single host registration 
turns  out  to  cost  between  2.500  EUR  and  4.000  EUR.  Given  the  hosts  already  in  the 
market  in  those  countries,  it  is  estimated  that  hosts  have  already  faced  a  total  cost 
around 1.5bln  EUR. The same range of cost  is  expected to  be spent  by the new hosts 
entering in the market by 2025. 

Requests for data sharing for platforms 

203 AT,  BE,  BG,  HR,  CZ,  DK,  DE,  FR,  HU,  GR,  IE,  IT,  LV,  LT,  MT,  NL,  PL,  PT,  SK,  ES.  These 
Member  States  replied  to  have  in  place  a  system  (at  national  or  regional  level)  for  hosts’  registration. 
Please note that France and Romania did not reply to the Questionnaire, while data on Cyprus is missing. 
However,  it  is  known  that  France  has  local  registration  scheme  and  some  STR  market  access 
requirements are present on the territory. Therefore, we are including France in this set of countries and 
excluding Cyprus. “Questionnaire II on the collaborative economy  - Registration schemes”, DG GROW 
2021. 
204 Oxford Research. “Study on national regulatory approaches to short-term accommodation services”  - 
European Commission, Luxembourg (2021) (upcoming). 
205 Ibid. 

131 

 
 
 
                                                           
Usually, for each request sent by public administration to platforms (online platforms or 
property  managers),  an  assessment  needs  to  be  performed.  This  includes  legal 
assessment  as  well  as  administrative  assessment  of  the  request.  Non-IT  specialised 
employees  can  perform  this  task.  Data  processing  has  to  be  performed  by  an  IT-
specialised employee.206 Data processing include data collection through the IT systems 
and  data  preparation  before  it  is  sent  out.  Finally,  there  is  the  activity  of  Data 
Communication to the requester and internal reporting to the company. Again, a non-IT 
specialised  employee  might  take  this  task  in  charge.  Here  below  a  model  of  the  cost 
function. 

𝑪𝒐𝒔𝒕𝒔 𝒑𝒆𝒓 𝒅𝒂𝒕𝒂 𝒔𝒉𝒂𝒓𝒊𝒏𝒈 𝒓𝒆𝒒𝒖𝒆𝒔𝒕  = 

𝑛

∑ (((𝑅𝐴𝑖 + 𝐷𝐶𝑖) ∗ 𝐴𝑊 ∗

𝑖=1

𝛿
2

) + (𝐷𝑃𝑖 ∗ 2𝛿 ∗ 𝑆𝑊)) ,

  𝑤𝑖𝑡ℎ   𝛿 = [1,10], n = [1, ∞[ 

𝑤ℎ𝑒𝑟𝑒 𝑅𝐴 = 𝑅𝑒𝑞𝑢𝑒𝑠𝑡 𝐴𝑠𝑠𝑒𝑠𝑠𝑚𝑒𝑛𝑡 (𝐿𝑒𝑔𝑎𝑙 + 𝐴𝑑𝑚𝑖𝑛𝑖𝑠𝑡𝑟𝑎𝑡𝑖𝑣𝑒) 
𝐷𝑃 = 𝐷𝑎𝑡𝑎 𝑃𝑟𝑜𝑐𝑒𝑠𝑠𝑖𝑛𝑔 (𝐶𝑜𝑙𝑙𝑒𝑐𝑡𝑖𝑛𝑔 + 𝑃𝑟𝑒𝑝𝑎𝑟𝑖𝑛𝑔) 
𝛿 = 𝑚𝑢𝑙𝑡𝑖𝑝𝑙𝑖𝑒𝑟 𝑓𝑜𝑟 𝑡ℎ𝑒 𝑠𝑖𝑧𝑒 𝑜𝑓 𝑡ℎ𝑒 𝑎𝑟𝑒𝑎 𝑖𝑛𝑡𝑒𝑟𝑒𝑠𝑠𝑒𝑑 
𝐷𝐶 = 𝐷𝑎𝑡𝑎 𝐶𝑜𝑚𝑚𝑢𝑛𝑖𝑐𝑎𝑡𝑖𝑜𝑛 

𝐴𝑊 = 𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑤𝑎𝑔𝑒 (𝑐𝑜𝑟𝑝𝑜𝑟𝑎𝑡𝑒)  

𝑆𝑊 = 𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑠𝑝𝑒𝑐𝑖𝑎𝑙𝑖𝑠𝑒𝑑 𝑤𝑎𝑔𝑒 (𝐼𝑇 𝑑𝑒𝑣𝑒𝑙𝑜𝑝𝑒𝑟) 
𝑛 = 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑟𝑒𝑞𝑢𝑒𝑠𝑡𝑠 received 

In  the  model,  a  variation  for  the  extension  of  the  area  is  taken  into  consideration 
through  the  factor 𝛿.  Factor 𝛿 can  take  values  from  1  to  10  –  at  the  highest  level  it 
represents communities of 2 million inhabitants or above, like large cities or capitals. 
For computational purposes, we assume an average value of δ of 5.2. 

Table 6 – Average δ factor of cities size distribution 

During  stakeholder  consultations,  some  platforms 207  referred  that  each  request  on 
average  would  cost  not  less  than  10.000  EUR  and  would  take  from  one  to  three 
months  to  be  processed  and  dispatched.  In  the  calculation  below,  what  was  reported 
has been taken into consideration and an average 𝛿 factor has been therefore factored 
in.  Calculations  result  in  an  average  cost  per  request  of  around  13.500  EUR.  A 
projection of future requests have been modelled based on the growth rate of host by 
2025 and 2030. Additionally, in order to compute the total costs associated with data 

206 Average Salary per hour of IT-specialised FTE identified at 75 EUR, based on consulting made within 
DG GROW and private sector IT specialists. 
207 Consultations with online platforms – players in the top 20% in Europe per volumes. 

132 

 
 
 
 
 
 
 
                                                           
sharing requests for all platforms, it has been considered that only the top 60% of the 
biggest  ones (30 companies) will be reached by data-sharing requests, assuming that 
smaller  platforms  will  not  be  asked  to  share  data.  At  the  same  time  is  assumed  that 
each online platform will receive requests only from 40% of the total 150 local public 
authorities  identified.  Under  these  assumptions,  it  has  been  calculated  that  already 
more than EUR 1.6 million are spent yearly on average by a platform on data sharing 
requests,  and  it  is  estimated  that  around  EUR  146  million  will  be  spent  by  all 
companies cumulatively in the next 5 years. 

Table 7 - Costs for Platforms data-sharing requests in the baseline scenario  

Other unquantifiable costs 

Unfortunately, not all costs could be modelled and estimated. It is difficult to create a 
robust  quantification  of  the  costs  that  stakeholders  in  this  market  are  incurring  due  to 
ongoing  litigations.  It  is  known  that  there  has  been  a  significant  amount  of  litigation 
between public authorities and platforms (and some legal complaints are still ongoing) 
over  data-sharing  requests,  as  well  as  numerous  cases  between  public  authorities  and 
hosts  on  the  justification  of  market  access  requirements  imposed  in  some  areas. 208 

208 See Annex 7 for some examples. 

133 

 
 
 
 
 
                                                           
Additionally, it is difficult to quantify the delay in enforcement of STR rules by public 
authorities.  As  previously  mentioned,  lack  of  data  in  this  market  is  a  key  issue  for 
knowledge  and  policy  making;  therefore,  the  need  to  tackle  this  problem  with  this 
initiative.  

4.3 INFORMATION FLOW BETWEEN STAKEHOLDERS AND IT INFRASTRUCTURE 

The graph below explains what should be the process and the information flow that this 
proposal  would  like  to  achieve. 209  In  the  graph,  it  is  possible  to  identify  each 
stakeholder  and  the  actions  linked  to  them  in  the  blueprint  of  the  process.  It  is  also 
possible to identify the type of tool requested for each data sharing operation. Different 
degrees  of  realisation  of  this  framework  are  associated  with  different  combinations  of 
options and sub options of this proposal. If we refer to sub option 1 (under option 2 or 
3) the framework will only apply to Member States who will develop such scheme. This 
blueprint  should  stay  valid  also  under  option  1,  limited  to  the  voluntary  registration 
scheme at national level and the data sharing agreement with platforms dependent of the 
voluntary adherence to the Code of Conduct. 

134 

 
 
 
                                                           
 
Figure 1 - Information flow between stakeholders and IT infrastructure 

135 

 
 
136 

 
 
 
Below  a  description  of  the  costs  identified  for  stakeholders  in  this  initiative  and  subsequently  a 
description of the computations for total costs for each of the options (and sub options) identified in 
this proposal is presented. 

4.4 COSTS LINKED WITH THE INITIATIVE 

Costs  associated  with  adaptation  of  registration  scheme  (creation  of  a  new  national  one  or 
coordination of existing decentralised ones) 

Here below the breakdown of the cost  associated with  the adaptation  of registration scheme(s).210 
For the purpose of the IA exercise, the costs associated to the creation of a new national registration 
system are modelled. To model the average costs associated with the optimisation of existing ones, 
the cost of a new creation are taken as a base and a 30% saving is applied. Costs associated with 
optimisation  of  decentralised  registration  schemes  are  estimated  to  be  marginal  and  negligible,  as 
already  existing.  Costs  associated  with  the  creation  of  the  connection  between  decentralised 
registration schemes with a central national infrastructure (single digital entry point) are estimated 
below and considered in the overall cost calculation. 

The  creation  of  a  new  general  registration  scheme  will  require  the  consideration  of  three  sets  of 
costs:  (1)  Database  setting  up  and  APIs  development,  (2)  Data  storage  and  accessibility,  (3) 
Maintenance. 

1.  Database  setting  up  and  APIs  development:  these  costs  should  be  considered  as  fixed  and 

very marginally impacted by the volume of data of the Database.  

2.  Data storage and accessibility: these costs should be considered variables with respect the 
volume of data that are meant to be stored – so the estimation will differ if the Database has 
to be national and elective or national and to be applied to all-hosts in the national territory 
(as described respectively in option 2 and option 3). 

3.  Maintenance: these costs should be considered as fixed and very marginally impacted by the 

volume of data of the Database. 

Breakdown takes into consideration costs associated with the setting up (valid for the first  year of 
functioning of the IT infrastructure) and maintenance costs – e.g. recurring costs as from the second 
year linked with maintenance and hosting.  

A  possible  variance  of  +/-  35%  of  total  cost  for  the  setting  up  of  the  infrastructure  has  been 
identified.  Being  conservative,  a  +25%  has  been  added  to  the  cost  function.  Costs  have  been 
identified for setting up the IT infrastructure, for setting up the APIs connectors and for hosting and 
maintenance.211 Under these hypotheses, the cost for setting up an IT infrastructure including API 
connection is  set  in  between EUR 150 000 and EUR 190 000 EUR. Yearly  costs for hosting  and 
maintenance has been identified respectively to around EUR ~60 000 and EUR ~35 000, for a total 
of roughly EUR 100 000. 

210 Estimations were made based on consultations with IT unit internal to DG GROW, as well as benchmarking the data 
with estimations made by experts in the private sector. 
211 Please note that hosting and maintenance costs have not been parametrised with the size of the database. 

137 

 
 
                                                           
Table  8  -  Costs  estimations  (ROM)  for  Registration  Scheme  and  SINGLE  DIGITAL  ENTRY 
POINT for MSs 

Costs associated with the creation of an API System 

The  reasoning  behind  the  cost  estimation  for  the  creation  of  an  automated  data-sharing 
infrastructure  is  explained  below.  It  considers  systems’  connection  through  APIs  that  entails  two 
nodes: (a) between platforms towards public authorities (and vice versa) and (b) public authorities 
towards public authorities (and vice versa).212 In the first node, connection will be established by an 
online platform to share data with public authorities, while in the node a local public authorities will 

212 Estimations were made based on consultations with stakeholders, as well as benchmarking the data with estimations 
made by experts in the private sector outside the STR segment. 

138 

 
 
 
                                                           
connect to the national single digital entry point through automated connection to obtain data timely 
(daily).  

The cost breakdown includes the cost for setting up “push” data APIs (needed by online platforms 
to  share activity data with  public authorities) and “pull” data APIs (needed by local  authorities to 
receive  data  or  by  platforms  to  receive  notifications  on  illegal  content  by  public  authorities. 
Considering a possible variation of +/- 25% in the cost function, an additional +20% has been added 
in order to be conservative. Under these hypotheses, the cost of one connection is around EUR 30 
000.  

Table 9 - Costs estimations (ROM) for APIs (data push and pull) 

In the computation of the costs, the complexity linked with the number of connections to establish 
has been taken into consideration. An intermediary that operates in more than one country will need 
to connect to each national dataset to share the relative data with public authorities. Once the first 
connection  has  been  developed,  a  20%  extra  cost  should  be  considered  for  each  marginal 
connection. In the most expensive scenario foreseen in option 3, the cost to connect to 27 different 
national systems is therefore set between EUR 150 000 and EUR 250 000. 

Additionally,  in  the  breakdown  of  the  costs,  costs  for  maintenance  have  been  identified  with  one 
third of FTE for each year. Considering an hourly IT specialised salary of 75 EUR, the computation 
for yearly maintenance is for EUR ~36 000 per year. 

In the assessment, two additional adjustments to the cost function have been modelled. The first one 
is  an  adjustment  of  the  above  setting  for  larger  players.  It  is  expected  that  bigger  players  with  a 
more  complex  IT  structure  and  higher  volume  will  need  more  resources  to  implement  the 
connections  to  national  datasets  (they  might  have  more  teams  involved  in  the  technological 
implementation, as well as possibly more volume of data to be shared). Therefore a multiplier of 5x 
for the 5 bigger players which together represent between 64% and 65% of the total market volume 

139 

 
 
 
is foreseen.213 The second adjustment is modelled for online platforms that might find expensive to 
develop automated connections respect the volumes of data they would need to report. They will be 
able to report manually (upload of data file) directly in the system214 once every three months, in a 
cheaper  and  user-friendly  way.  The  cost  is  estimated  to  be  around  EUR  600  for  each  reporting 
activity, translating in a total yearly cost of around EUR 2.400 per online platform. Limitation to the 
size  of  the  file  to  be  uploaded  will  be  imposed  (based  on  estimation  of  volumes  of  data  to  be 
reported) and this will ensure that players with higher and relevant volumes will develop the data-
sharing  infrastructure.  For  the  purpose  of  this  exercise,  the  assumption  that  every  company  that 
owns less than 0.45% of the total EU market will be entitled to use this simplified reporting system. 
This translates in 680 companies. 

Table 10 - Cost estimations reporting for SMEs -  Option for more lenient reporting obligations 

Costs associated with Hosts’ registration  

The  costs  associated  with  hosts’  registration  has  been  calculated  starting  from  the  study  made  by 
Oxford Research.215 In the study, a survey to hosts has been submitted, identifying the time needed 
to  complete  the  registration  in  different  systems.  Additionally,  the  breakdown  of  the  time  needed 
has  been  identified.  In  line  with  what  should  be  the  national  registration  scheme  under  the 
framework  foreseen  by  this  initiative  (fast,  free  and  user-friendly),  the  schemes  of  Portugal  and 
Greece  have  been  identified  as  benchmark.  In  these  two  systems,  the  minimum  time  needed  for 
registration  is  2  days.  Since  any  check  is  supposed  to  happen  only  ex-post,  guaranteeing  the 
immediate entrance into the market to new hosts, the number of days has been adjusted subtracting 
the  possible  delays  (by  third  parties  and  personal)  identified  in  the  study.  Therefore,  it  has  been 
estimated that the needed time for registration is between 1.4 and 1.7 day. Under these assumptions, 
the  cost  associated  with  the  registration  for  hosts  under  the  characteristics  required  in  this 
initiative216 is set between EUR 300 and EUR 340. 

213 This data translate in having 137 companies sharing 15% of the EU market and other 500+ companies sharing the 
marginal 20% of the market volume. This estimation is in line with consultations with main stakeholders within on-line 
platforms.  
214 The idea is to develop a “drag and drop” option, with the possibility to upload files with maximum of 5 Megabyte. 
215 Oxford  Research.  “Study  on  national  regulatory  approaches  to  short-term  accommodation  services”  -  European 
Commission, Luxembourg (2021) (upcoming). 
216 Registration scheme has to be free, quick, user-friendly and respect the one-stop-shop principle. 

140 

 
 
 
                                                           
Table 11 - Cost estimation for Registration for Hosts 

4.5 ASSESSMENT OF THE COST (AND SAVINGS) ASSOCIATED TO EACH OPTION 

4.1.1  Option 1 

Costs. Under this option, it is expected that at least sixteen countries217 would implement provisions 
on  a  voluntary  basis.  It  is  assumed  also  that  these  countries  will  exploit  (at  least  partially)  the  IT 
infrastructure  already  developed,  resulting  in  30%  saving  with  respect  the  cost  estimated  for  the 
development  of  a  new  infrastructure.  Under  Option  1,  the  data-sharing  agreements  with  STR 
platforms  is  not  obligatory  and  will  be  defined  by  the  Code  of  Conduct  that  will  be  developed. 
Therefore,  in  the  costs  estimations,  the  development  of  APIs  connections  cannot  be  properly 
modelled. The total adjustment costs for national public authorities under this option are estimated 
to be between EUR 1 500 000 and EUR 1 600 000. 

217 Ibid 228. 

141 

 
 
 
 
                                                           
Table 8 – Costs for National Public Administrations for infrastructure, option 1 

For  local  public  authorities,  the  working  hypothesis  for  the  purpose  of  this  exercise  is  that  local 
authorities that have already in place a system in place for monitoring STR activity – a registration 
scheme  –  will  voluntarily  implement  the  provisions  in  the  recommendations.  It  is  possible  to 
assume, being conservative, that around 100 cities/areas in the 16 Member States mentioned above 
will want to implement the provisions and will need to adapt their systems. It is expected that these 
cities have already in place a system (of any sort). Therefore, on average, it is possible to expect that 
costs of adapting their systems will be only 20% of the costs estimated to create a new system.  This 
will result in a cumulated adjustment cost of EUR 600 000 and a recursive yearly maintenance cost 
of about EUR 720 000. 

Table 9 – Costs for Local Public Administrations for infrastructure, option 1 

142 

 
 
 
 
 
 
 
Hosts in the abovementioned cities/areas (100, estimated) will be possibly requested by competent 
local  authorities  to  eventually  adapt  their  registration  information  with  the  EU  dataset  template 
suggested in the recommendation. Using the assumption that data already used in the active systems 
will be re-used, it is possible to assume that any adaptation will not cost more than ~30% of a new 
registration for  each host.  Taking into account  that  “big” cities  (more than 250 000 inhabitant) in 
Europe are around 130 over a total of 800, it is possible to assume that 40% of the hosts would be 
concentrated in highly dense areas more impacted by tourism, while the other 60% could be spread 
around  e  rest  of  the  territories.  Accordingly  with  the  number  of  cities  that  would  opt-in  into  the 
system, is it possible to estimate that at least 50% of these hosts will be impacted by the provisions 
and  be  subject  to  a  request  to  ratify  their  data  in  present  registration  schemes.  Estimations  for 
number  of  hosts  affected  in  the  table  below  follow  this  logic.  A  rough  estimation  brings  a  total 
adjustment cost for hosts of around EUR 15 million and EUR 16 million. Additionally, new hosts 
that will register after the implementation of provisions should be granted a more slim registration 
form,  at  least  to  start  offering  their  accommodation  services,  resulting  is  some  savings.  It  is 
imperative to remind that these costs are fictitious as a rough quantification of the time hosts will 
need  to  use  for  modifying  the  data  (if  needed).  Registration  scheme  should  be  always  be  free  of 
charge.  

Table 10 – Costs for Hosts for new/adjustment registration under option 1 

the  assumption  of 

Savings.  Considering 
the 
recommendations,  it  could  be  foreseen  a  total  cost  for  new  hosts’  registrations  are  estimated  to 
around EUR 490 million in the first 5 years of implementation. This estimation is computed taking 
account the average number of days needed to complete registration218 (15 days, as specified above) 
and the average hourly salary available in the OIOO tool. Under these assumptions, each new host 
registration would cost around 3.000 EUR.  

sixteen  Member  States 

implementing 

218 Oxford  Research.  “Study  on  national  regulatory  approaches  to  short-term  accommodation  services”  -  European 
Commission, Luxembourg (2021) (upcoming). 

143 

 
 
 
 
                                                           
It is therefore possible to assume that in the first 5 years of implementation of the initiative (under 
option 1) an expected saving for hosts of about EUR 438 million could be reached cumulatively for 
all hosts. 

Table 11 – Savings for Hosts under option 1 

Savings  for  companies  in  this  scenario  cannot  be  properly  estimated  as  there  will  be  not  an 
obligation 
the 
follow  data 
recommendations. 

for  public  authorities 

requests  procedures 

included 

in 

to 

4.1.2  Option 2  

Costs.  Cities and areas that will like to receive data from platforms will be obliged to introduce a 
registration scheme and develop (together with national authorities) an infrastructure to be able to 
receive  activity  data  from  online  platforms.  If  anywhere  in  the  national  territory  there  is  a  local 
authority  having  appetite  for  data  on  STR  activity  under  its  authority,  national  authorities  will  be 
indeed  required  to  coordinate  existing  schemes,  assess  the  IT  infrastructures  already  in  place  and 
develop  the  IT  system  single  digital  entry  point  that  will  connect  online  platforms  and  local 
authorities.  Therefore,  under  option  2,  it  expected  that  (at  least)  twenty-five  European  Member 
States219 would  need  to  comply  with  the  provisions  and  coordinate  local  registration  schemes  or 
create  a  new  one.  This  number  is  computed  taking  into  account  that  in  all  25  MSs  some  kind  of 
registration scheme is  present  – at  least  in  one locality in  their territory.  Therefore,  assuming that 
those local authorities will still have appetite for data, national authorities will need to adapt their 
systems.  Based  on  dialogues  with  member  states,  it is  clear  that  only  two  member  states  have  no 
interest in data with respect STR activity.  

It is assumed also that these countries will exploit (at least partially) the IT infrastructure that have 
already  developed,  resulting  in  30%  saving  with  respect  the  cost  estimated.  In  the  cost  structure, 

219 AT, BE, BG, HR, CZ, CY, FR, DE, GR, HU, IE, IT, LU, MT, NL, PL, PT, RO, SK, ES, SE. Data for Cyprus is not 
available.  Listing  based  on  Airbnb  mapping  on  existing  registration  schemes  present  at  national,  regional  and  urban 
level. 

144 

 
 
 
                                                           
development  of  APIs  connections  has  been  included.  Member  States  are  expected  to  spend  at 
around EUR 3 million to coordinate and link existing registration schemes, and develop the national 
single digital entry point. Additionally, a yearly cost for hosting and maintenance is calculated to be 
around EUR 96 000 for each Member State, for a cumulative cost of EUR 2.4 million per year. 

Table 12 – Costs for National Public Administrations for coordination under option 2 

It is expected that local authorities will connect their systems to the national one in order to retrieve 
data from online platforms. The assumption is that (at least) local authorities with already a system 
in place will develop such connections. In 2020 online platforms received more than 1700 requests 
for data. In 2021 they received more than 800.  Considering that one area might have been asking 
data  to  more  than  one  platforms  (and  considering  that  10+  platforms  replied  to  the  dedicated 
survey),  it  can  be  assumed  that  at  least  200220 local  authorities  within  the  25  MSs  will  develop  a 
new  system  or  adapt  an  old  one.  In  line  with  Option  1,  it  is  possible  to  assume  that  100  of  the 
urban/local  areas  opting  in  in  the  system  have  already  a  system  in  place  and  therefore  will  save 
~80%  of  the  costs  estimated  for  the  creation  of  a  new  system.  The  other  50%  of  the  urban/local 
areas  will  face  the  whole  cost  of  setting  up  (of  around  30.000  EUR  for  APIs  development).  It  is 
possible to foresee a cumulative adjustment cost for local public authorities of  around 3.6 million. 
Additionally, a cumulative yearly cost for hosting and maintenance is calculated to be around EUR 
4.3 million. 

Table 13 – Costs for Local Public Administrations under option 2 

220 Inference based on the Airbnb mapping mentioned in the previous note. 

145 

 
 
 
 
                                                           
Costs linked with the registration and the reporting of hosts have the same structure as in Option 1. 
Therefore, 40% of the hosts will need to (eventually) adjust the info they already provided and the 
other 50% will need to register ex novo. Considering the hosts in the above-mentioned 25 MSs, it is 
expected adjustment costs of around EUR 112.4 million for them.221  

Table 14 – Costs for Hosts for new/adjusted registration under option 2 

For  platforms’  cost  estimation,  the  assumption  made  is  that  the  majority  of  the  platforms  (112 
medium companies and 568 fringe companies identified) would likely qualify as small and micro-
enterprises and would use the option with more lenient reporting obligations for reporting to public 
authorities. The reason behind this is to safeguard medium and fringe companies from extra burden 
while the vast majority of bookings for STRs are made through bigger platforms (30, each of them 
with average monthly active hosts equal or higher to 1000 ). Nonetheless, it is important to include 
these smaller players  and hosts in  the system of reporting to  not  create loopholes in  the reporting 
system  or  create  disincentives  for  hosts  to  use  services  of  bigger  platforms  (creating  potential 
distortion in the market). Under these hypotheses, the adjustment cost for platforms are estimated to 

221 This  estimation  is  conservative  and  could  exceed  the  real  impact  the  initiative  will  have,  especially  if  public 
administration will be able to retrieve data already shared by hosts. 

146 

 
 
 
 
                                                           
around EUR 8.2 million for the first year of enforcement, while yearly maintenance (administrative) 
costs are expected to be around EUR 2 million for the biggest 30 companies. For small and micro-
enterprises  with  average  monthly  active  hosts  equal  or  lower  to  1000  ,  there  is  only  a  yearly 
cumulative reporting cost of around EUR 4 million. 

Table 15 – Costs for Platforms for data-sharing under option 2 

Savings.  Under  option  2,  two  areas  of  savings  could  be  identified:  savings  for  hosts  on  the 
registration schemes and for platforms on the data sharing requests. Taking into consideration  that 
only 25 Member States will be adopting the data sharing framework and for the cost considerations 
made above, it could  be possible to  save more than EUR 5 million for the new hosts that will be 
starting  their  activities  (hence  need  to  register  in  those  areas)  by  2025.  Additionally,  another  ~46 
million EUR could be saved for platforms by 2025 if the more efficient data-sharing system will be 
in place. This estimation is made again based on a conservative reasoning, which consider that only 
40% of the platforms will be reached by a data-sharing request from public authorities of localities 
with STR market access restriction. 

147 

 
 
 
Table 16 – Savings for Hosts under option 2 

Under  option  2,  savings  for  online  platforms  are  expected  to  be  substantial.  In  2020,  online 
platforms  reported  to  have  received  more  than  1700  requests  for  data  sharing.  In  2021  requests 
lowered  to  800.  It  is  important  to  factor  in  the  impact  that  the  COVID  pandemic  had  on  tourism 
flows and therefore on the need of local public authorities to check STR activity. Until 2020, data 
requests have been growing exponentially. However, if no growth is assumed and data on requests 
received  in  2020  are  taken  as  baseline,  in  the  next  5  years  it  is  expected  a  cumulative  costs  for 
online platforms of more than EUR 115 million. If, otherwise, data on requests of 2021 are taken as 
baseline and no grow of requests is considered, in the next 5 years it is expected a cumulative costs 
for online platforms of more than EUR 54 million. Calculations are made assuming a cost for each 
company to process singular request estimated at EUR 13 549, as discussed above in section Annex 
4.1.  A  streamlined  data-sharing  framework  will  enable  online  platforms  to  eliminate  the  costs  for 
legal assessment and put in place an automated way to process incoming data requests from public 
authorities, thus making the cost to process  a single request very limited and negligible (therefore 
reducing  the  cost  to  process  single  requests  from  EUR  13  549  to  EUR  0).  On  this  basis,  it  is 
estimated  that  savings  for  online  platforms  over  a  period  of  5  years  will  amount  between  around 
EUR  35.8  million  and  EUR  96.8  million  (baseline  costs  minus  adjustment  costs  of  around  EUR 
18.2 million as presented in table 14 above). 

4.1.3  Option 3 

Costs. Costs for option 3 follow the same structure of option 2, with the difference that under this 
option, all hosts in the European Single Market will need to register before  offering STR services.  
With  respect  option  2,  under  Option  3  all  27  Member  States  have  to  be  develop  the  needed  IT 
infrastructure to coordinate existing local registration schemes or create one national ex-novo and to 
facilitate  the  exchange  of  data  between  public  authorities  and  online  platforms  through  the  single 
digital entry point. Cost savings will apply only to those Member States that already had in place 
some form of IT infrastructure. Therefore, for the setting up of the systems in the 27 Member States, 
a total adjustment cost of between EUR 3.5 million and EUR 3.6 million is expected to set up the 

148 

 
 
 
 
data-sharing  infrastructure  at  national  level.  Additionally,  a  yearly  administrative  cost  for  hosting 
and maintenance is calculated at around EUR ~100.000 for each Member State. 

Table 17 – Costs for National Public Administrations for coordination under option 3 

It is expected that more local authorities would like to create connections to the national system to 
retrieve data from online platforms. It can be assumed that at least 220222 local authorities within the 
27 MSs will develop a new system or adapt an old one. In line with Option 1 and 2, it is possible to 
assume that 100  (45% of the 220)  of the urban/local  areas opting in  in  the system have already  a 
system  in  place  and  therefore  will  save  ~80%  of  the  costs  estimated  for  the  creation  of  a  new 
system. The other 120 (55% of the 220) of the urban/local areas will face the whole cost of setting 
up (of around 30 000 EUR for APIs development). It is possible to foresee a cumulative adjustment 
cost for local public authorities at around EUR 4.3 million. Additionally, a yearly cost for hosting 
and maintenance is calculated to be around EUR 5.2 million. 

Table 18 – Costs for Local Public Administrations under option 3 

222 Inference based on the Airbnb mapping mentioned in the previous note. 

149 

 
 
 
 
 
                                                           
Costs associated with  hosts follows the same reasoning of  option 2. Under option 3, however, all 
hosts will be subject to the same obligation to register. Hosts in Europe that had not be subject  to 
any kind of registration before will incur full cost of registration estimated (i.e. 320 EUR). The total 
one-off costs for hosts will be at around EUR 376.6 million. This estimation takes into account the 
total  number  of  hosts  in  the  EU  and  that  the  majority  of  the  hosts  will  need  to  perform  a  new 
registration (i.e.  all hosts  in  2 MSs and  80% of all hosts in the remaining  25 MSs)  as  well as the 
hosts who would need to adapt their actual registration to the new template (20% of hosts in 25 MSs 
already  subject  to  some  form  of  registration).  This  means  that  compared  to  Option  2,  as  the 
registration is obligatory across all 27 Member States, around 825 683 additional hosts would need 
to register under Option 3, with an estimated one-off cost of EUR 264.2 million. Additional yearly 
administrative  costs  for  the  next  5  years  after  the  implementation  of  the  provisions  foreseen  by 
option 3 are estimated to be around EUR 438.4 million for new hosts entering the market. 

150 

 
 
 
Table 19 – Costs for Hosts for new/adjusted registration under option 3 

For what  concerns online platforms, cost structure will follow exactly what has been discussed in 
the  previous  section  of  Option  2.  It  is  estimated  that  the  adjustment  cost  associated  with  data 
reporting  for  platforms  is  around  EUR  8.2  million,  while  administrative  costs  cumulative  for  the 
next 5 years after the implementation of the provisions foreseen by option 3  would be around 9.5 
million. 

151 

 
 
 
Table 20 – Costs for online platforms under option 3 

Benefits.  Areas  of  savings  could  be  identified  for  hosts  and  online  platforms.  For  hosts,  option 3 
will  not  translate  in  direct  saving  in  the  short  terms  (as  more  hosts  will  be  required  to  register). 
However  savings  in  the  medium  terms  could  come  by  other  means.  Therefore,  compared  with 
option  2,  saving  for  hosts  will  be  positive  but  reduced  to  EUR  794  million  in  the  first  5  years  of 
implementation  of  the  initiative.  Additionally,  more  than  45  million  EUR  would  be  saved  for 
platforms  by  2025  if  the  more  efficient  data-sharing  system  will  be  in  place.  Also  this  time  this 
estimation  is  made  based  on  a  conservative  reasoning,  which  consider  that  only  40%  of  the 
platforms will be reached by a data-sharing request from Public authorities of localities with STR 
market access restriction. 

152 

 
 
  
 
 
4.6 SME TEST 

(1) Preliminary assessment of businesses likely to be affected  

Where in the impact 
assessment 

See Chapters 2 and 6 as well 
as Annex 4 

Preferred Option – Option 2 

Directly affected: SMEs in the Platforms stakeholders’ groups:  

The  preferred  Option  foresees  an  obligation  for  public 
authorities  who  want  data  on  STR  to  set  up  registration 
schemes for hosts. All platforms will need to comply with the 
data  sharing  framework,  display  registration  numbers  and 
share data with the single digital entry point set up at national 
level. 

With  an  increased  legal  certainty  on  data  sharing  and 
appropriate  communication  channels,  market  barriers  are 
reduced  giving  higher  chances  to  SME  online  platforms  who 
operate  cross-border  or  wish  to  expand  their  geographical 
reach to more than one Member State to do so.. Nevertheless, 
it  is  important  to  stress  that  data  reporting  and  display 
requirements  will  have  the  same  cost  impact  on  companies, 
without differentiating between  small  and medium enterprises 
or  larger    players  –  resulting  in  a  more  substantial  negative 
impact on the former. 

Small and medium-sized enterprises (SMEs) are defined in the 
EU  recommendation  2003/361/EC.  This  definition  refers  to 
companies that operate in traditional markets and have adopted 
classic  business  models.  In  the  past  years,  thanks  to  digital 
technologies, a new type of companies – i.e., online platforms 
– have emerged which base their business model on the value 
of intermediation between different groups of stakeholders, by 
leveraging their capacity to use algorithms and data to provide 
matching services. Online platforms operate in digital markets, 
where indirect network effects are a crucial element of market 
structure  and  competition.  Hence,  the  classic  definition  of 
SMEs  cannot  be  applied  to  platforms,  and  there  is  no 
equivalent  definition  yet  for  this  type  of  companies  operating 
in the digital domain. 

However,  the  preferred  option  foresees  a  lighter  reporting 
regime  for  platforms  that  qualify  as  small  and  micro-
enterprises  within 
the  meaning  of  Recommendation 
2003/361/EC  (i.e.,  enterprises  with  staff  headcount  of, 
respectively,  <50  and  <  10  and  turnover  or  balance  sheet  of, 
respectively,  ≤  10  €  m  ≤  €  2  m),  provided  that  they  do  not 
reach a number of average monthly active recipients in the EU 
equal  to  or  higher  than  a  monthly  average  of  1000    active 

153 

 
 
hosts. The assumption is that companies below such thresholds 
would likely qualify as small and micro-enterprises. 

Indirectly affected: SMEs in the ancillary services in the STR 
ecosystems:  Relatively  speaking,  auxiliary  services  offering 
activities  linked  directly  with  the  STRs  (such  as  laundry, 
cleaning,  concierge,  etc.)  offered  by  local  SMEs  will  have  an 
advantage from this measure. They will not incur in any direct 
costs  and,  at  the  same  time,  they  will  have  a  more  stable 
market. Should public authorities decide to make the data that 
they received from platforms available at aggregate level, these 
SMEs will also  have the possibility to  have better insights  on 
market projections and plan their business accordingly.  

(2) Consultation with SMEs representatives 

Bilateral  with  SMEs:  Meeting  were  held  between 
the 
Commission  and  SME  companies  from  various  stakeholder 
groups: platforms, property managers and hosts. 

Annex 2 (Stakeholder 
consultation) 

Participation  of  SMEs  in  Workshops:  Two  workshops  on  the 
topic  of  'Developing  a  responsible,  fair  and  trusted  single 
market  for  short-term  rental  services’  were  organised  on  22 
October  and  10  December  2021,  each  attracting  around  150 
participants across all stakeholder categories. 

OPC  and  SMEs  replies:  SMEs  took  part  in  the  consultation 
process  through  submitting  their  feedback  on  the  Inception 
Impact  Assessment  from  16  September  to  14  October  2021 
and  replying  to  the  Open  Public  Consultation,  which  was 
conducted from 27 September to 13 December 2021. 

Targeted  survey:  SMEs  took  part  in  the  targeted  survey  to 
platforms. 

(3) Measurement of the impact on SMEs 

It  is  estimated  that  680  platforms  would  qualify  for  the  more 
lenient  reporting  requirements.  These  will  take  advantage  of 
data  reporting  possibility  through  the  functionality  for  more 
lenient  reporting  obligations.  The  administrative  costs  of 
manual reporting for these platforms will amount to around 1.6 
million EUR per year (EUR 2 400 per platform per year). 

See Annex 4. 

4) Assess alternative options and mitigating measures 

154 

 
 
Alternative options: The option of a full exemption for certain 
SMEs  online  platforms  from  reporting  obligations,  based  on 
the  volume  of  STR  activity 
intermediated  (number  of 
bookings) was assessed and discarded at an early stage.  

See chapter 5; see Annex 2 
for the stakeholder 
consultations 

For the purpose of this  assessment, it has been identified that 
680 companies  could  fall into the reporting derogation. There 
would  be  a  direct  positive  effect  for  online  platforms  which 
would  be  able  to  save  “costs”  deriving  from  the  data  sharing 
obligations: the implementation of this variant will translate in 
around  EUR  1.6  million  savings  per  year  for  all  EU 
companies  falling  into  this  reporting  derogation.  However, 
other considerations (below) need to be taken into account. 

In the first  place, under  (preferred) Option  2 these companies 
would be anyhow under a very light  regime of  data reporting 
obligation,  not  being  asked  to  develop  any  IT  system  to 
guarantee automated data reporting. Therefore, the saved costs 
will  be  merely  linked  to  monetisation  of  the  time  needed  to 
prepare and upload (manually) the data every  three months in 
the  national  IT  systems  (single  digital  entry  points  to  be 
ensured  by  each  Member  State,  where  relevant).  Even  if  this 
can be considered a tangible benefit as cost saving, it will be a 
“monetisation”  of  the  time  needed  by  companies  to  comply 
with  the  reporting,  as  they  do  not  need  to  develop  any 
additional infrastructure. 

Secondly,  exempting  some  companies  from  the  reporting 
obligation would create a loophole in the stream of information 
public  authorities  will  be  able  to  receive.  This  will  lower  the 
completeness  and  reliability  of  information  at  disposal  of 
public  authorities  to  tackle  positive  and  negative  externalities 
linked with STR activity. Consequently, the enforceability  of 
STR  rules  in  place  will  be  jeopardised:  the  exemption  will 
create loopholes  in  the monitoring system, incentivising hosts 
to escape monitoring of their activity by using exempted small 
platforms  for  listings.  This  will  eventually  lower  the  quality 
standards  of  data  and  weaken  the  efficacy  of  the  tool  set 
offered to public authorities by this initiative. 

A  third  point,  linked  with  the  previous  one,  is  represented  by 
the distorted incentive for hosts to use smaller platforms to list 
their  rental  units  due  to  lower  probability  to  be  monitored.  If 
there  could  be  an  initial  benefit  for  SMEs  online  platforms  – 
concretely, hosts will divert some of their intermediation needs 
toward smaller platforms at expenses for the bigger ones –, this 
will not represent a consistent incentive prolonged in time. As 
soon  as  a  small  online  platforms  will  reach  the  minimum 
volume of transactions, the company will need to  report data. 

155 

 
 
Therefore  hosts  will  be  incentivised  to  shift  again  to  other 
smaller platforms in order to keep their activity unmonitored. 

that 

stressed 

in  discussions  explicitly 

Finally,  all  SMEs  stakeholders  and  their  representatives 
total 
involved 
exemptions for SMEs are not perceived as a positive tool to 
help  small  companies  develop.  The  reason  behind  this  is  a 
possible  cumulative  effect  resulting  from  the  sum  of  multiple 
exemptions for SMEs: this could create an artificial barrier to 
scale up  as reaching  a certain  volume of business will trigger 
multiple  obligations  all  together.  SMEs  experts  suggest  that 
smaller  companies  should  always  be  involved  in  provisions, 
adapted  to  their  possibility  and  eventually  limiting  costs  as 
much  as  possible.  In  this  way,  companies  will  incorporate 
obligations  set  by  legislations  gradually  in  their  processes 
avoiding disruptions during their scale up process. 

Mitigating  measures:  In  order  to  safeguard  certain  smaller 
platforms  from  extra  burden  with  regard  to  the  reporting 
obligation,  small  and  micro-enterprises  which  do  not  reach  a 
number of average monthly active recipients in the EU equal to 
a monthly average of 1 000 active hosts can use the option for 
more  lenient  reporting  obligations  for  reporting  data.  The 
reason for introducing this option was to include these smaller 
players  in  the  system  of  reporting,  while  the  vast  majority  of 
bookings  for  STRs  are  being  made  through  bigger  platforms 
(or  property  manager  websites).  This  avenue  will  prevent  the 
creation  of  loopholes  in  the  reporting  system  and/or  of 
disincentives for hosts to use services of bigger platforms. 

156 

 
 
 
 
 
ANNEX 5: DESCRIPTION OF THE SECTOR223 

In  the  first  part  of  this  Annex,  the  main  players  are  described,  while  in  the  second  part  a  more 
detailed  and  quantitative  analysis  is  assessed  on  their  presence  in  the  European  economy.  This 
overview  will  focus  on  the  STR  intermediary  platforms.  For  more  detailed  information  about  the 
STR ancillary services segment, please refer to Duch-Brown (2021). 

1.1 STR SECTOR: DESCRIPTION OF THE PLAYERS 

The structure of the STR sector is complex and involves the participation of many different players 
and activities. 

1)  STR Intermediary Platforms.  

Each of the STR Intermediary Platforms have different business models: 

  Airbnb:  global  platform.  Entire  or  shared  properties  are  advertised  which  may  be  hosted  by 

peers (individual hosts) or managed by property managers.  

  Vrbo  (Expedia  Group):  global  platform.  Only  entire  properties  are  advertised  (a  part  of  the 
property is never shared with strangers) which may be hosted by peers (individual hosts) or 
managed  by  property  managers.  Have  other  brands  in  DE  (FeWo-Direkt.de)  and  FR 
(Arbitrel.fr).  

  Booking.com: global platform. Only entire properties are advertised (a part of the property is 
never shared with strangers) which may be hosted by peers (individual hosts) or managed by 
property managers. 

  Marriott Home and Villas (Marriot International): global platform. Advertises only premium 
and  luxury  STRs  (which  comply  with  Marriott’s  standards)  which  are  managed  by 
professional  home  management  companies  only.  Due  to  the  recognition  of  the  brand  name, 
gives an access to Marriott’s loyal members’ base. 

  Tripadvisor  Rentals  (FlipKey,  Holiday  Lettings,  Niumba,  Vacation  rentals  and  HouseTrip): 
global  platform.  Entire  or  shared  properties  are  advertised  which  may  be  hosted  by  peers 
(individual hosts) or managed by property managers. 

  Leboncoin Group: France only. Only entire properties are advertised (a part of the property is 
never shared with  strangers) which may be managed by peers (individual  hosts) or property 
managers/OTAs (for example, locasun) 

  Traum-FerienWohnungen (part of OYO Vacation rentals): global, Germany based. Entire and 
shared properties are advertised which may be hosted by peers (individual hosts) or managed 
by property managers. Also lists holiday homes to sell or buy. 

Meta  Search  Platforms.  They  could  be  also  considered  intermediary  platforms  while  do  not 
vertically in serving the STR segment. 

223 This  annex  is  based  on  the  following  publication:  Duch-Brown,  N.  (Coord.),  The  Short-Term  Accommodation 
Rentals market in the EU, JRC Digital Economy Working Paper 2021-09.  

157 

 
 
                                                           
  Hometogo:  based  in  Germany.  list  offers  from  thousands  of  providers,  including: 
Booking.com, Tripadvisor, Vrbo (Expedia Group), Airbnb, Vacationrentals.com, HouseTrip, 
Flipkey  (Tripadvisor),  perfectplaces.com,  homestay.com,  onlyapartments.com,  Interhome, 
BedyCasa, Novasol, Homeescape.com  

  Holidu: based in Germany. Scans hundreds of websites to let you choose from more than 14 
million  vacation  homes  offered  by  the  following  vacation  rental  partners:  Interchalet,  TUI, 
Novasol, Booking.com, E-Domizil, Housetrip, Tripadvisor and other. 

  Google  in  March  2019  added  a  Vacation  Rental  filter  (you  can  search  for  vacation  rentals 
directly  on  Google  Travel).  There  was  an  issue  with    vacation  rental  properties  being  not 
instantly bookable (TBC if it was solved). The company has partnered with Expedia Group, 
Tripadvisor  (not  all  STR  intermediary  platforms  opted  in)  and  channel  managers  (Property 
Management Tech) like Rentals United, Kigo and others. 

2)  Hosts  

Individual  hosts.  Individual  hosts  can  rent  their  entire  properties  or  rent  only  a  part  of  it 
(shared  properties).  Entire  properties  and  shared  properties  can  be  rented  out  occasionally 
(usually these are primary residences, but can be second homes too) or year-around (usually 
second homes). 

Majority  of  them  rent  their  properties  via  STR  Intermediary  Platforms  directly  (with  an 
exception of Marriott Home and Villas (Marriot International) as they allow advertisements of 
STRs managed by professional home management companies only.  

If individual hosts do not want the burden of the entire short-term rental process (advertising, 
getting a booking, keeping contact with a guest, accommodating, cleaning and other), they are 
very likely to turn to a professional property manager (they can turn to Property Management 
companies  and/or  Branded  Home  Managers  and/or  Traditional  Holiday  Home  Managers). 
These professionals come in different shapes and sizes.  

Property  Portfolio  Owners/Property  Managers  (Entrepreneurs).  Property  Portfolio 
Owners/Property  Managers  (Entrepreneurs)  are  hosts  who  have  more  than  their  primary 
residence and/or second home to rent for short-term. They like renting out the properties they 
own already and have more properties to rent out (built out their properties portfolio). These 
are  entrepreneurs.  Entire  properties  and  shared  properties  can  be  rented  out  occasionally  or 
year-around. 

As  in  the  case  of  Individual  Hosts,  they  can  rent  their  properties  via  STR  Intermediary 
Platforms directly (with an exception of Marriott Home and Villas (Marriot International) as 
they  allow  advertisements  of  STRs  managed  by  professional  home  management  companies 
only (as they may not qualify yet).  

Property  Portfolio  Owners/Property  Managers  (Entrepreneurs)  handle  their  own  guest  stays 
but  can  turn  to  other  professional  property  managers  (they  can  turn  to  Branded  Home 
Managers  and/or  Traditional  Holiday  Home  Managers)  for  a  support  in  marketing  and 
distribution. These entrepreneurs come in different shapes and sizes. 

3)  Ancillary services providers 

158 

 
 
support  Property  Portfolio  Owners/Property  Managers 
STR  Ancillary  Services 
(Entrepreneurs) depending on how big their property portfolio is and what is the willingness 
and resources to take up STR Ancillary Services. 

Real Estate Agents/Property Developers/Property Management companies. Real Estate 
Agents  can  use  services  provided  by  Branded  Home  Managers  which  enable  owners  and 
landlords to fill the voids in their portfolio and earn additional income while waiting for the 
right sale or long-term let. 

Property  developers  with  new  units  coming  on-stream,  or  professional  property  managers 
with  vacant  homes,  can  benefit  from  additional  revenue  generated  while  finding  the  right 
tenants or buyers. They can also turn to Branded Home Managers for the support. 

Branded  Home  Managers.  Branded  home  managers  offer  an  end-to-end  service  for  both 
homeowners  and  guests,  on  average  charging  between  40%  and  50%  of  the  total  booking 
value.  They  only  works  with  homes  that  meet  their  brand  standards.  They  are  also  more 
involved with the interaction with guests, generally meeting the guest to hand-over the keys 
and do ID checks, as well as provide maid or butler services to increase brand engagement. 

Branded  home  managers  clearly  state  they  are  managing  a  STR  advertisement.  Besides 
listing  on  all  the  STR  Intermediary  platforms,  they  often  have  their  own  website  with  its 
own booking engine to enhance the brand identity and association with guests. 

They  are  also  more  likely  to  work  with  Marriott  Home  and  Villas,  corporate  booking 
platforms (Bridgestreet), traditional travel agents, and realtors. 

Some  of  the  Branded  Home  Managers  are:  Onefinestay  (owned  by  Accor  Hotels),  Altido, 
Under  the  doormat,  Sonder,  Oasis,  Thirdhome  Rentals  (focuses  on  second  luxury  homes), 
Yonder (focuses on nature-rich STRs) and others.  

There  is  some  convergence  happening  between  Traditional  Holiday  Home  Managers  and 
Branded Home Managers, but there tends to be one major difference between these players. 
While Traditional Holiday Home Managers tend to focus on entire second homes in holiday 
destinations,  Branded  Home  Managers  predominantly  focus  on  first  and  second  homes  in 
urban areas (with an exception of Thirdhome Rentals and Yonder). 

Traditional  Holiday  Home  Managers.  These  companies  count  many  years  in  helping 
owners of second homes in holiday destinations to manage their properties throughout a year 
(majority of them are 40+ years old). Traditional Holiday Home Managers continue to adapt 
to  changes  in  the  market,  they  are  increasingly  converging  with  other  property  managers, 
particularly the Branded Home Management companies. 

Traditional  Holiday  Home  Managers  are  full-service  businesses  which  take  care  of  the 
whole  renting  process  for  homeowners.  From  getting  bookings  to  key  handling,  cleaning 
services and taking care of check-outs. Homeowners and guests can reach out to companies’ 
international customer contact teams, that is familiar with all vacation rentals, when any help 
is needed. 

Traditional Holiday Home Managers: 

Belvilla (with focus on Benelux region) and Dancenter (Europe) (OYO VH) 

159 

 
 
Novasol, cottages.com, Hoseasons, James Villa Holidays, Landal Green Parks (Awaze) 

Interhome Holiday Home Division (Interhome, Interchalet) 

The STR Ancillary Services landscape in the STR segment is by far the fastest growing area 
when considering new entrants entering the market. The Property Management technology 
area is especially fragmented, with different players offering property management systems, 
channel  management,  customer  relationship  management,  digital  marketing  solutions, 
website builders, revenue  management systems,  and  guest-facing tech like messaging, app 
builders, digital guidebooks, chatbots, and voice assistants. 

While  the  short-term  rental  sector  has  grown  strongly,  the  number  of  STR  Ancillary 
Services providers has too. The fragmented nature of the sector means there are still many 
small property managers who will not have significant funds to purchase software, instead 
trusting their own local knowledge and experience to manage processes, market their listings 
and set prices. 

It is still hard for STR Ancillary Services providers to scale Europe-wide or internationally 
and become dominant players (nearly all of them are SMEs). Most players instead focuses 
on  a  few  tools  or  systems,  based  on  the  demand  in  their  initial  core  market.  Vertical 
expansion usually follows growing demand amongst the client base, rather than seeing a true 
gap in the market. 

Some Ancillary services are: 

•  Property  operations  –  STR  Ancillary  Services  which  offer  hotel-standard  cleaning  and 
linens are seeing their business grow as more and more property managers are outsourcing 
cleaning  and  linens  to  professional  providers  using  the  latest  work  order  management 
systems, rather than retaining this function in-house. 

•  Property  hardware  - As the Internet of Things (IoT) enters the home, where devices and 
appliances are connected to the internet and can be controlled and tracked remotely, short-
term  rental  property  managers  and  homeowners  can  have  more  control  over  their  rental 
while  not  physically  present.  From  smart  locks  which  can  be  accessed  with  unique  codes 
provided  to  guests,  to  thermostats  which  can  be  accessed  remotely,  to  noise  monitors  to 
identify potentially noisy and disruptive guests. 

•  Guest-facing  tech  –  As  guests  staying  at  short-term  rentals  expect  a  tech-enhanced 
personalized  service  there  is  a  growing  group  of  STR  Ancillary  Services  providers  which 
offer in-property tablets or mobile enabled apps or websites to offer a personalized service to 
guests.  

•  Other  Support  Services  –  These  are  platforms  which  facilitate  local  networks  of  key 
exchanges  and  luggage  storage  in  shops  or  safe  boxes,  as  well  as  insurance  providers, 
mortgage providers, and legal support.  

1.2 STR SECTOR: ANALYTICS AND DATA ON PLAYERS 

Following  Eurostat’s  classification,  accommodation  industries  are  divided  in  three  main 
categories: 
ii)  Holiday  and  other  short-stay 
accommodation;  and  iii)  Camping  grounds,  recreational  vehicle  parks  and  trailer  parks.  The 

i)  Hotels  and  similar  accommodation; 

160 

 
 
number  of  nights  spent  in  tourist  accommodation  in  the  EU  grew  in  2019  by  2.5  %,  reaching 
almost  2.9  billion  nights.  Holiday  and  other  short-stay  accommodation  -such  as  rented 
apartments-  almost reached one quarter (23 %). In 2010, the share of holiday and other short-
stay accommodation in total night spent was 20% (Table 1). 

Table 1 - Evolution of nights spent at tourist accommodation establishments 2010-2019 

Hotels1 
% 
2010 
65.4 
2011 
66.2 
2012 
65.5 
2013 
65.5 
2014 
65.4 
2015 
65.2 
2016 
65.3 
2017 
64.9 
2018 
64.9 
64.5 
2019 
1: Hotels and similar accommodation; 2: Holiday and other short-stay accommodation 

Total 
Billion nights 
2.2 
2.2 
2.3 
2.3 
2.4 
2.5 
2.6 
2.7 
2.8 
2.9 

Source: Eurostat (TOUR_OCC_NINAT) 

STR2 
% 
20.1 
19.7 
21.2 
21.3 
21.5 
21.9 
22.0 
22.4 
22.5 
22.9 

The  increasing  relevance  of  STR  in  the  recent  years  can  also  be  confirmed  looking  at  the 
evolution in the number of establishments and bed-places, as shown in Figure 2. As the graph 
shows,  the  number  of  STR  establishments  grew  at  an  average  yearly  rate  of  8.6%  over  the 
period 2010-2019, from little more than 200 thousand to 431 thousand. Despite the fact that the 
number of STR bed-places grew by 4.2% per year in the period 2010-2019 and those of hotels 
only grew at 1.1% per year in the same period, the share of STR bed-places only reached 27%, 
up from 22% in 2010. 

Figure 2 - Evolution of establishments and bed-places in hotels and STR, 2010-2020 

Establishments

Bed-places

s
d
n
a
s
u
o
h
T

500

450

400

350

300

250

200

150

100

50

0

s
n
o

i
l
l
i

M

14

12

10

8

6

4

2

0

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Hotels

STR

Hotels

STR

Source: Eurostat (TOUR_CAP_NAT) 

161 

 
 
 
 
 
The collaborative economy had a significant impact on the tourist accommodation market in the 
decade. In 2019, more than 512 million guest nights224 spent in the EU were booked via one of 
four platforms (Airbnb, Booking, Expedia Group and Tripadvisor). Figure 3 shows that one in 
five guest nights was spent in Spain (106 million guest nights), followed by France (99 million). 
Italy (76 million guest nights), Germany (37 million) and Portugal (31 million) complete the top 
five.  

Figure 3 - Guest nights spent at short-term accommodation offered via collaborative economy 
platforms, 2019 (in million) 

s
n
o

i
l
l
i

M

120

100

80

60

40

20

0

ES FR

IT DE PT HR EL PL AT CZ NL HU BE

IE DK CY RO SE MT BG FI

SI

SK LT

EE LV LU

Source: Eurostat (Experimental statistics) 

During  the  COVID  crisis,  the  STR  segment  has  proven  to  be  particularly  resilient.  While  the 
number of nights spent in EU tourist accommodation in the first semester of 2020 dropped by 60% 
compared to the same period in 2019 (from 1.2 billion in 2019 to less than 0.5 billion in 2020), the 
number  of  STR  bookings  during  the  summers  2020  and  2021  were  above  2018  levels  during  the 
same period in certain EU regions. The results below (Figure 4) cover virtually all Airbnb listings in 
all  27  EU  Member  States.  Reviews  are  quite  timely,  and  allow  for  assessing  short-term  rental 
tourism activity with a time lag of ca. 14 days and analyse the evolution of reviews and the expected 
bookings derived from those reviews, controlling for the season. 

Web Traffic and the Short-Term Rental sector in Europe 

In  this  section  we  provide  an  overview  of  the  STR  segment  by  focusing  on  traffic  to  the  main 
platforms in 20 EU countries.225 We start by identifying the main players in the STR segment in the 
20 EU countries  under study.  In order to  do that,  we  considered the full  list  of domains  from  the 

224 The number of guest nights takes into account the number of nights spent during a stay and the number of tourists in 
the travel party. The concept is similar to the "nights spent at tourist accommodation establishments" generally used in 
official tourism statistics. 
225  The  analysis  is  based  on  the  web  analytics  data  provided  by  Similarweb.  We  focused  on  the  category 
“Accommodation and Hotels” traffic data and identified the  main STR platforms on that basis.  Similarweb covers 20 
EU Member States, namely: Austria, Belgium, Bulgaria, Czech Republic, Germany, Denmark, Spain, Finland, France, 
Greece, Croatia, Hungary, Ireland, Italy, Nederland, Poland, Portugal, Romania, Sweden, and Slovakia. These countries 
represent 98.17% of the EU GDP and 97.7% of the EU population in 2019 (Eurostat). 

162 

 
 
 
                                                           
“Accommodation and Hotels” category, ranked by traffic share in each country. The identification 
of the STR sites was performed manually. The procedure has covered at least 80% of the traffic in 
each of the countries or it has stopped once at least 10 STR platforms were identified. The definition 
of STR adopted in classifying the domains has taken a consumer centric perspective. In other words, 
we considered the choices of a consumer interested in holiday or short-term accommodation that it 
is  not  a  canonical  hotel,  residence  or  inn.  The  classification  procedure  itself  produced  a  first 
important insight: STR websites are characterised by a wide variety of business models.   

Figure 4 - Evolution of Airbnb reviews 

120000

100000

80000

60000

40000

20000

0

5
1
-
1
0
-
1
0

5
1
-
4
0
-
1
0

5
1
-
7
0
-
1
0

5
1
-
0
1
-
1
0

6
1
-
1
0
-
1
0

6
1
-
4
0
-
1
0

6
1
-
7
0
-
1
0

6
1
-
0
1
-
1
0

7
1
-
1
0
-
1
0

7
1
-
4
0
-
1
0

7
1
-
7
0
-
1
0

7
1
-
0
1
-
1
0

8
1
-
1
0
-
1
0

8
1
-
4
0
-
1
0

8
1
-
7
0
-
1
0

8
1
-
0
1
-
1
0

9
1
-
1
0
-
1
0

9
1
-
4
0
-
1
0

9
1
-
7
0
-
1
0

9
1
-
0
1
-
1
0

0
2
-
1
0
-
1
0

0
2
-
4
0
-
1
0

0
2
-
7
0
-
1
0

0
2
-
0
1
-
1
0

1
2
-
1
0
-
1
0

1
2
-
4
0
-
1
0

1
2
-
7
0
-
1
0

1
2
-
0
1
-
1
0

2
2
-
1
0
-
1
0

14 day rolling avg.

Expected value

Nb. Daily reviews

Source: ECFIN (http://b1scrap2.westeurope.cloudapp.azure.com/airbnb/) 

Most people probably have in mind the Airbnb business model when thinking of STRs. In reality, 
most  platforms  have  different  design  features  that  make  them  extremely  heterogeneous.  For 
example, a first issue is what share of private home is necessary to consider a platform belonging to 
the  STR  segment.  For  the  purpose  of  this  report,  Booking.com  has  been  considered  an  Online 
Travel Agency (OTA) platform. Indeed, despite it also supplies STR, that is not its core business.226 
At  the  same  time,  in  some  countries  under  study  (e.g.,  Croatia,  Slovakia)  some  of  the  main  STR 
platforms also list small independent hotels and inns. Moreover, Airbnb and other platforms charge 
a percentage fee per completed transaction. Other websites have a listing annual fee. Sites also vary 
on whether hosts, guests, or both are charged. Another dimension of heterogeneity is the approval of 
the  listings:  some  platforms  inspect  all  the  listed  properties  and,  in  some  case,  there  is  a  sort  of 
affiliation to a network (e.g., for luxury villas and apartments). In other cases, the platform is a sort 
of notice board where anyone can post a  listing without any moderation. Finally, certain  domains 
appear to be provided by local tourism authorities to promote the supply of rooms and apartments to 
visiting  tourists.  In  other  cases,  cooperatives  with  different  aims  are  involved,  as  for  example  the 

226 This  choice  is  backed  by  evidence  in  Annex  B.B  in  Duch-Brown  (Coord.)  2021.,  showing  a  relatively  limited 
percentage of traffic for STR on the Booking.com domain.  

163 

 
 
 
                                                           
case  of  Fairbnb,  which  tries  to  promote  sustainable  tourism  by  linking  listings  of  STRs  to 
experiences of the local territory.227         

Table  2  presents  the  indicators  of  concentration  for  the  20  EU  countries  and  some  selected 
members, reporting the most and least concentrated countries according to the web traffic HHI and 
the EU average of the 80th percentile of the traffic. The average web traffic HHI in the 20 countries 
is  136.  Slovakia,  Greece  and  France  have  a  substantially  higher  concentration,  ranging  from  256 
and  290.  Romania,  Bulgaria  and  Hungary’s  traffic  is  more  spread  between  the  80th  percentile 
websites  and  the  HHI  ranges  between  15  and  57.  These  features  are  also  reflected  in  the  80th 
percentile traffic share (column 2). On average, the 80th percentile websites account for 23% of the 
traffic shares in the category "Accommodation and Hotels" in Similarweb.  

Column 4 highlights the differences in the less popular between the STRs in the 80th percentile. On 
average, that STR  attracts  0.86% of the traffic "Accommodation and Hotels" category, but  values 
range from as little as 0.15% in France and the Nederlands to 4.26% in Bulgaria.  

Table 2 - Concentration by country - Top 80 percentile domains 

Country 

percentile 
traffic 

Slovakia 
Greece 
France 
EU 20 
Nederland 
Bulgaria 
Hungary 
Source: own calculations with Similarweb data. 

80th 
total 
share 
30% 
22% 
39% 
23% 
23% 
4% 
4% 

percentile 
traffic 

80th 
sites 
HHI228 
290 
270 
256 
136 
57 
18 
15 

80th 
STR 
share 
0.95% 
0.28% 
0.15% 
0.86% 
0.15% 
4.26% 
3.91% 

percentile 
traffic 

percentile 

80th 
number of STR 

5 
7 
26 
13.6 
20 
1 
1 

Although  similar  information  can  be  obtained  by  looking  at  the  top  10  platforms,  from  a 
methodological perspective we will focus the ensuing analysis on the Top 80th percentile websites, 
but  for  countries  with  only  a  very  limited  number  of  STRs  we  will  consider  at  least  the  Top  3 
domains. 

From a conceptual viewpoint, the measures of traffic concentration suggest that the 20 EU countries 
under study are rather heterogeneous in terms of concentration of traffic to the STR segment. This 
may  indicate  that  the  STR  segment  has  different  levels  of  development  and  popularity  across 
countries,  which  is  also  reflected  in  the  market  structure  and  the  resulting  web  traffic.  The  STR 
segment  is  heterogeneous  in  terms  of  web  traffic  concentration  between  countries  and  across 
domains. The traffic heterogeneity to STR platforms identified may suggest that the market in the 
EU is not particularly integrated and it has local specificities. 

227 More details on Fairbnb are provided in Eco&Eco (2021). 

164 

 
 
                                                           
 
We can go more in depth in trying to grasp the size and development of the sector by studying the 
cumulative  share  of  traffic  to  the  STR  segment  in  comparison  to  the  Hotel  traffic  and  the  Online 
Travel Agencies segment’s traffic of the "Accommodation and Hotels" category.       

Table 3, panel (a), counts the domain types in the Top 80 percent of traffic. On average in the EU20 
countries  studied  there  are  more  STR  websites  than  OTAs:  the  proportion  is  2.65  STR  per  OTA. 
Countries like Denmark, Austria and Poland have more than three times STRs than hotel websites, 
whereas  Czech  Republic,  Romania  and  Greece  have  less  STR  sites  than  OTAs.  A  similar  picture 
emerges from panel (b). On average, there are more STR domains than hotels or hotel chains, 2.94 
in  the  EU20.  This  may  be  because  many  small  chains  and  independent  hotels  do  not  command a 
substantial  share  of  clicks  and,  hence,  may  not  feature  in  the  top  80  percent  of  traffic.  Italy, 
Denmark, and Bulgaria have more than three STR per hotel website, whereas Sweden, Slovakia and 
Ireland  have  relatively  more  hotel  domains.  To  conclude,  the  STR  segment  attracts  comparable 
traffic  shares  as  the  OTA  sector  in  many  EU  countries  and  appears  to  be  an  established  and 
important accommodation option in the EU.   

Table 3 - Domain types in the Top 80 percent traffic   

(a) STR vs. OTA 

(b) STR vs. Hotels 

Country 

OTA 

STR 

STR/OTA  Country  HOT 

STR 

STR/HOT 

Denmark  

Austria  

Poland  

EU 20  

3 

7 

2 

36 

Czech Republic   9 

Romania  

Greece  

5 

9 

11 

22 

6 

82 

7 

3 

5 

3.67 

3.14 

3.00 

2.65 

0.78 

0.60 

0.56 

Italy  

4 

Denmark   3 

Bulgaria   1 

15 

11 

3 

EU 20  

37 

113 

Sweden  

12 

Slovakia   4 

Ireland  

50 

11 

3 

22 

3.75 

3.67 

3.00 

2.94 

0.92 

0.75 

0.44 

The  domains  identified  so  far  are  often  found  in  several  countries  and  it  is  interesting  to  analyse 
unique websites. Indeed, from the 20 EU Member States for which Similarweb collects data, some 
relevant info is the following. First, 122 unique websites are identified when looking at the Top 10 
per  country  (out  of  200  –10  websites  per  20  countries).  Second,  we  also  identify  194  unique 
websites when looking at the top 80% of the traffic per country. From the combination of both lists, 
208 unique websites are identified. 

The  dominance  of  Airbnb,  with  its  subdomains,  it  is  clear  from  Table  4,  listing  the  websites  that 
appear in most countries. The site Vrbo.com also enjoys popularity throughout the EU 20 countries 
under study. Airbnb is the main player in most countries. Multiple sub-domains of the platform 
figure in the Top10 of several countries. 

165 

 
 
 
Table 4 - STR websites present in most countries 

Website  

Number of countries 

Top 10 

Top 80% 

Airbnb.com 

Vrbo.com 

Airbnb.co.uk 

19 

14 

10 

19 

13 

5 

Next,  the  websites  can  be  grouped  by  country  of  origin.  Table  5  reports  the  distribution  that  is 
obtained: 

Table 5 - Countries with most STR websites 

Country  

Number of websites 

Top 10 

Top 80% 

Germany 

United States 

France 

Denmark 

Nederland 

Poland 

Czech Republic 

22 

20 

10 

7 

6 

6 

6 

38 

20 

19 

11 

14 

4 

7 

It is perhaps not surprising that large countries like Germany, the US, and France have the highest 
number  of  STR  websites  in  the  Top  10  or  Top  80  percent  of  traffic.  The  US,  one  of  the  World 
leading  countries  in  the  digital  domain,  is  the  only  non-EU  country  whose  websites  are  browsed 
also  in  EU  countries.  Interestingly,  a  number  of  websites  from  smaller  countries  as  Denmark, 
Poland  and  the  Czech  Republic  are  present  in  several  countries  in  the  EU.  This  evidence  may 
suggest  that  even  medium-sized  STR  platforms  enjoy  sufficient  network  effects  and 
scale/scope  economies  that  allow  them  to  be  active  and  relatively  popular  in  more  than  one 
country.         

166 

 
 
 
 
 
 
 
If grouping is applied at a higher level, i.e., of macro-region, the picture in Table 6 emerges. Indeed, 
as it is probably natural EU websites are the vast majority, with 93 websites in the Top 10 and 142 
in  the  Top  80  percent.  The  United  States,  again,  play  an  important  role  in  the  sector,  with  20 
websites according to both selection criteria. 

Table 6 - STR websites in the EU 20 grouped by region of origin  

Region 

Number of websites in the EU 20 

Top 10 

Top 80% 

European Union 

United States 

United Kingdom 

Rest of the World 

93 

20 

3 

3 

142 

20 

9 

5 

Finally,  we  can  group  the  websites  by  platform.  In  fact,  many  platforms  adopt  a  country  specific 
domain strategy. Table 7 reports the results of such aggregation: 

Table 7 - Main platforms by number of domains 

Platform  

Airbnb 

Hometogo 

Holidu 

Novasol 

Country of HQ 

Number of domains 

US 

DE 

DE 

DK 

24 

11 

10 

8 

The table shows the relevance of one US platform, Airbnb, in the sector.  This platform is present 
with more country specific domains than the number of countries covered by the data. Two German 
platforms  follow  with  less  than  half  the  country  specific  domains  as  Airbnb.  Novasol,  a  Danish 
platform, is present with a third of the domains that Airbnb has.    

Given the prominence of Airbnb in the sector, we compute its traffic share in the “Accommodation 
and hotels” category in  each country. The percentage of  traffic captured by Airbnb as  a platform, 
with  all  its  sub-domains,  is  on  average  16%  of  the  whole  category.  The  share  varies  by  country, 
ranging from more than 40% in countries as Czech Republic, Germany, and Bulgaria, to 5% or less 
in countries as Hungary, Romania, and Poland.  

Table 8 is going one step further, and looks at the share of traffic of Airbnb as a platform between 
all  the  STRs  that  feature  within  the  80  percent  of  traffic  in  each  country.  On  average,  the  traffic 

167 

 
 
 
 
 
share  generated  by  Airbnb  is  55%.  Whereas  certain  countries  have  very  concentrated  traffic  and 
only Airbnb features in the Top 80% of traffic, even in other countries the traffic share is quite high 
and never less than a quarter of the total STR traffic (within the Top 80 percent).  

Table 8 - Airbnb traffic share within STRs in the Top 80 percent of traffic  

Country  Airbnb share in STR Top 80pc  

BG 

HU 

GR 

100% 

100% 

94% 

EU 20 

55% 

As a final piece of evidence, we focus on the traffic share of platforms in the whole EU20 countries, 
based  on  monthly  data  of  web  traffic  between  September  2018  and  September  2021.  This 
information allows us to identify the Top 20 STR platforms by share of visits, as reported in Table 
9.  Column  2  reports  the  share  of  visits  to  the  platform  domains,  whereas  column  3  presents  the 
share  of  unique  users.  Column  4  lists  the  country  in  which  the  Headquarters  of  the  platform  are 
located and,  finally,  column 5 counts  the number of EU country domains that the platform has, a 
very rough proxy of where the platform is active. Airbnb comes across as the major player in the 
sector, as it is the only platform attracting a share of traffic in the double digits (column 2). Only 
one more platform, the German Hometogo, has more than a 5% share of the EU20 traffic. Only the 
first seven platforms have a share of visits higher than 2%. 

From the data collected, we have identified 142 STR platforms operating in the major EU markets. 
Assuming that these companies cover 80% of the traffic to STR sites and that the size distribution is 
highly skewed (Pareto), as show in figure 5, these providers should represent 20% of STR platforms 
operating in the EU market. The size distribution shows a high concentration. As indicated in table 
10, the top 15 already cover more than 60% of traffic, while Airbnb alone represents more than one 
third (37%), and its traffic share is six time higher than that of the second highest platform. 

Hence, we assume that there should be around 568 additional small platforms operating in the EU 
and  covering  the  remaining  20%  of  the  traffic.  Given  the  size  of  the  smallest  observed  platform 
(Alkatravel, with a maximum of around 1000 unique users in the summer of 2019), these operators 
are expected to be SMEs, mostly operating in localised and niche markets. 

Table 9 - The top 20 STR platforms by visits share 

EU20 
share 

visits 

EU20  unique  users 
share 

Country  of 
HQ 

#  of  EU20  country 
domains  

Platform 

Airbnb 

45.69% 

39.50% 

Hometogo 

7.61% 

8.92% 

US 

DE 

17 

9 

168 

 
 
 
 
Fewo-direkt 

Abritel 

Holidu 

Gites 

Traum-
ferienwohnungen 

Vrbo 

Novasol 

Couchsurfing 

3.89% 

3.60% 

3.36% 

2.98% 

2.88% 

1.99% 

1.54% 

1.24% 

Gites-de-france 

1.16% 

Papvacances 

Casevacanza 

Belvilla 

1.04% 

1.04% 

1.02% 

Chambres-hotes 

0.90% 

Locasun 

0.86% 

Bed-and-breakfast 

0.85% 

Wimdu 

Natuurhuisje 

Rentalia 

0.75% 

0.72% 

0.64% 

3.97% 

3.44% 

4.44% 

3.27% 

2.57% 

2.27% 

1.52% 

0.94% 

1.21% 

0.80% 

1.17% 

1.08% 

1.09% 

0.94% 

1.06% 

1.08% 

0.79% 

0.76% 

DE 

FR 

DE 

FR 

DE 

US 

DK 

US 

FR 

FR 

IT 

NL 

FR 

FR 

IT 

DE 

NL 

ES 

1 

1 

10 

1 

2 

0 

7 

0 

1 

1 

1 

2 

1 

1 

1 

3 

2 

0 

Figure 5 - Size distribution of the 142 identified platforms 

169 

 
 
 
 
 
 
 
45,0%

40,0%

35,0%

30,0%

25,0%

20,0%

15,0%

10,0%

5,0%

0,0%

1

11

21

31

41

51

61

71

81

91

101 111 121 131 141

While  the  top  platforms  are  multinational  companies  operating  in  many  countries,  little  is  known 
about the cross-border operations of smaller platforms. From the list of 142 identified platforms, a 
random selection of 20 of the 42 smaller platforms was extracted to check manually whether they 
were  operating  in  several  MS  or  not  and,  for  those  that  are  not,  whether  they  operate  in  several 
jurisdictions  within  a  single  country.  In  the  manual  check,  we  also  record  the  number  and  list  of 
countries (or regions  when possible) for which listings were detected. The results of this exercise 
are shown in Table 10. 

Table 10 Cross-border and cross-region operations in a sample of small STR platforms 

Platform sampled 

Croatialuxuryrent 
Revngo 
Stugsommar 
Gitesdewallonie 
Topgeres 
Stugsidan 
1-2-3-ubytovanie 
Ardennen-online 
Mediahols 
E-chalupy 
Hotelsline 
Hdd 
Ubytujsa 
Ubytovanivchorvatsku 
Sardinien 
Apartman 
dreamireland.com 
Checkvienna 

EU share 

Users 

Visits 

Cross 
 border 

Cross 
 region 

0.040% 
0.038% 
0.032% 
0.031% 
0.032% 
0.023% 
0.031% 
0.026% 
0.022% 
0.014% 
0.026% 
0.013% 
0.020% 
0.012% 
0.012% 
0.012% 
0.011% 
0.009% 

0 
1 
1 
0 
0 
1 
0 
0 
1 
1 
0 
1 
0 
0 
0 
0 
0 
0 

0.035% 
0.032% 
0.032% 
0.028% 
0.025% 
0.025% 
0.022% 
0.022% 
0.021% 
0.020% 
0.016% 
0.015% 
0.015% 
0.011% 
0.010% 
0.009% 
0.009% 
0.009% 

170 

1 
na 
na 
0 
0 
na 
1 
0 
na 
na 
1 
na 
1 
1 
0 
1 
1 
0 

Countries  
with  
listings (#) 
1 
7 
4 
1 
1 
47 
1 
1 
83 
2 
1 
15 
1 
1 
1 
1 
1 
1 

 
 
 
 
Levneubytovani 
Alkatravel 

0.004% 
0.001% 

0.004% 
0.001% 

1 
1 

na 
na 

6 
2 

The table indicates that around 40% of smaller platforms have cross-border operations and that the 
number of countries in which they operate can be substantial in some cases. Although some of these 
platforms could be subsidiaries of larger companies that have not been able to attract large volumes 
of  users,  others  may  simply  be  smaller  players  trying  to  enlarge  their  market  scope.  On  the  other 
hand,  the  table  also  shows  that  from  the  remaining  platforms,  35%  have  operations  in  multiple 
jurisdictions of a single country. 

Assuming that all large  platforms also  have cross-border operations, a simple extrapolation  of the 
results  would  suggest  that  50%  of  platforms  operate  cross-border,  while  another  30%  operate  in 
multiple regions or localities within their host country. Only 20% of the STR platforms identified 
operate locally. 

Two  major  players  in  the  EU  “Accommodation  and  Hotel”  sector  are  the  Online  Travel  Agent 
platforms Booking.com  and Expedia. Besides hotels, both  platforms also list STR  apartments  and 
vacation homes. Given their prominence in the sector, one may wonder what role they play in the 
STR  segment.  Our  data  allow  studying  traffic  to  the  Booking.com  and  Expedia  subdomains 
dedicated to STR. Based on those data, Booking.com STR would rank 27th for visits in the EU20 
countries,  whereas  the  traffic  to  Expedia  is  of  several  orders  of  magnitude  smaller  and,  in  many 
countries and months, almost negligible.           

Column 4 of table 9 suggests that 17 out of the 20 top STR platforms have their headquarters in the 
EU. Three US platforms complete the picture, but these are very relevant in terms of traffic share, as 
Airbnb and Vrbo jointly attract  slightly less than 50% of the total clicks. Column 5 indicates that 
most websites have at most one or two country-specific domains. Some, like Couchsurfing or Vrbo 
only  use  non-country  related  domains,  as  for  example  “.com”.    On  the  other  hand,  there  are  only 
two platforms (Airbnb and Holidu) with more than 10 country domains.  

Country domains are only a proxy of activity and listings by hosts in countries. However, manual 
checks suggest that there is a clear division between many transnational platforms, that have listings 
all  over  the  EU20  countries  analysed,  and  more  localised  platforms,  operating  only  in  one  (e.g., 
many platforms only have listings in France or Italy) or in a limited subset of countries.  

Finally,  all  top  20  platforms  receive  traffic  from  all  the  considered  EU  countries.  Our  measure 
requires at least one click in the last 24 months. Still, Figure 6 suggests that STR platforms outside 
of the Top 20 are not necessarily attracting clicks from all the EU20 countries analysed. Indeed, the 
left  panel  shows  a  correlation  between  the  traffic  share  and  the  number  of  countries  in  which  the 
STR has visitors. The left panel zooms into the same data, by visualising only platforms that have 
less than 5% traffic. The correlation emerges even more clearly. To conclude: On the basis of web 
traffic, Airbnb and US websites and platforms are important players in the EU STR segment. EU 
STR  platforms  represent  the  majority  of  firms  present  in  the  Top  10  per  country,  the  Top  80 
percent  accommodation  traffic,  and  in  the  EU20  traffic  as  a  whole.  However,  they  are  all 
medium-small in terms of web traffic (and unique users) attracted. Websites and platforms from 
the Rest of the World play a marginal role.  

Figure 7 summarises the dynamics of monthly visits to STR websites between September 2018 and 
September 2021. A number of interesting insights come up. First, as expected, there is a pronounced 

171 

 
 
 
seasonality in the visits, with peaks during the European summer and holiday seasons. Second, the 
vertical  dashed  line  indicates  the  start  of  the  COVID  pandemics  and  a  sharp  drop  in  visits  is 
immediately  apparent.  At  the  same  time,  at  the  end  of  the  first  and  long  lockdown  in  many  EU 
countries  and  with  start  of  the  summer  a  ponderous  bounce  back  is  also  clearly  visible.  Overall, 
COVID appears to have increased the volatility of traffic. For this reason, we will be performing the 
analysis  by  excluding  COVID  lockdown  completely  and  running  it  for  the  only  full  year  before 
COVID available in our data (from September 2018 to September 2019).  

In  order  to  make  the  dynamic  analysis  intelligible,  we  mostly  focus  on  the  top  and  bottom  two 
decile  platforms.  The  deciles  are  defined  in  terms  of  EU20  visits  overall.  The  first  two  deciles 
comprise 11 of the Top 20. As a first exercise, we plot the actual visits data and a fitted linear trend 
for a full year before COVID. 

Figure 6 - Number of countries with incoming traffic and traffic share per platform  

Left panel: all platforms – right panel: platforms with a traffic share of less than 5% 

 Figure 7 - Monthly visits to STR platforms in the EU20 countries   

172 

 
 
 
 
Figure 8 - Monthly visits to STR platforms and trends –top and bottom deciles  

First, we can note the massive difference in the number of visits for the top and bottom platforms: 
the  left  vertical  axis  in  Figure  8  refers  to  the  bottom  decile  and  features  only  a  few  thousands 
monthly clicks, whereas the right vertical axis is in the order of the million monthly visits. Second, 
the graphs refer to a full year of data pre-COVID. Despite that, Figure 8 registers a declining trend 
in users of the bottom decile platforms throughout the period (red line). At the same time, the top 
decile platforms display a clearly increasing trend (blue line). This pattern may have been driven by 
a summer boom, which has particularly benefited the top STR platforms. There was no equivalent 
pattern in the case of the smallest companies as, indeed, they lost visitors229.     

STR  web traffic is  highly seasonal  and the COVID pandemics has exacerbated the  volatility of 
monthly  visits  to  STR  websites.  Platforms  from  the  Top  deciles  are  characterised  by  a  mostly 

229 Results using the second from top and bottom deciles are similar, but the differences are less pronounced. 

173 

 
 
 
 
 
                                                           
positive trends of visits, both in number of visitors and growth rates, but the latter are not higher 
than those of the Bottom deciles platforms.    

Composition of platforms: the case of Airbnb 

With the goal to provide evidence on the hosts that use STR platforms and operate in the sector in 
the  EU,  we  exploit  a  rich  dataset  from  Airdna  covering  the  whole  EU  providing  detailed 
information on both Airbnb listings and hosts. Table 11 provides an overview of number of listings 
per  host230.  Following  Xie  et  al.  (2021),  professional  hosts  can  be  defined  as  those  that  list  more 
than  one  property  per  year  through  Airbnb.  This  definition  is  also  in  line  with  Gunter  and  Önder 
(2018) or Li et al. (2017). A first striking figure is that 72% of Airbnb active hosts in the EU27 
had  only  one  listing. About  15% of the hosts  have two listings  and a  further 5% have three.  On 
aggregate,  97%  of  Airbnb  active  hosts  in  the  EU27  had  five  listings  or  less,  whereas  only  3%  of 
active  Airbnb  hosts  had  more  than  five  listings.  If  we  define  as  “peers”  hosts  with  only  1  or  2 
listings and “professionals” the rest, the vast majority of hosts are “peers” (71.9 to 87.4% depending 
on the chosen definition) and a more limited share in terms of listings is “professional”.  

Table 11 - Number of listings per Airbnb hosts 

N. of listings  N. of hosts  Share 

1 

2 

3 

4 

5 

2,174,101 

71.9 

469,406 

15.5 

170,374 

78,026 

41,162 

5.6 

2.6 

1.4 

3.0 

More than 5 

89,302 

Total 

3,022,371 

100.0 

Figure 9 details the share of the total revenue that is earned by each type of hosts; i.e., the sum of all 
revenues  generated  during  the  period  under  study.  For  the  period  2014-2020,  the  total  revenue 
generated by the platform is 538,710,284$. On average, 50% of this is earned by individual hosts 
and  50%  by  professional.  However,  as  the  figure  shows,  there  is  substantial  variation  across 
countries. 

230 For a detailed overview of the number of professional and peer hosts by country, see Duch-Brown (2021). 

174 

 
 
 
 
 
 
 
                                                           
Figure 9 - Proportion of total revenue by type of host and country 

Total revenue

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

a
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A

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T

Individual hosts

Professional hosts

With  respect  to  the  type  of  listing  by  hosts,  Table  12  shows  that  professional  hosts  own  a  lower 
number  of  properties  in  absolute  terms  than  individual  hosts,  whereas  the  number  of  private  and 
shared  rooms  is  higher.  Overall,  entire  homes  represent  75.1%  of  the  sample,  whereas  the 
proportion of shared rooms is only 1.1%. 

175 

 
 
 
 
 
 
Table 12 - Number and proportion of listing by host type 

Listing Type 

Individual  % 

Professional  % 

Total 

Entire home/apartment 

3,062,768 

53.1%  2,705,399 

46.9%  5,768,167 

Private room 

907,182 

49.5%  924,053 

50.5%  1,831,235 

Shared room 

35,746 

43.9%  45,701 

56.1%  81,447 

Figure 10 presents the evolution of properties belonging to professional hosts over time. 
Notably,  the  share  of  professional  hosts  has  more  than  doubled  in  the  last  five  years, 
going from 18.7% in 2014 to 45.6% in 2020. 

Figure 10 - Evolution of professional hosts over time 

43,9%

45,0%

45,6%

41,0%

32,5%

34,6%

18,7%

2014

2015

2016

2017

2018

2019

2020

Another relevant characteristic is the presence and evolution of hosts that have multiple properties 
in more than one country (henceforth, cross-border hosts). We define a cross-border host as a host 
who has at least one property in a country different from his origin country231. As Table 13 shows, 
only 2.5% of the hosts have properties in a foreign country. Those properties represent 18% of the 
total, and generate 17% of the total revenue in the platform.  

Table 13 - Presence of cross-border hosts  

National host 

Cross-border host 

Total 

% cross-border 

Number of hosts 

3,841,588 

98,757 

3,940,345 

2.51% 

231 Unfortunately, the sample does not include the origin country of the host. Hence, in this section we assume that the 
origin country for a given host is the country in which he owns more properties. 

176 

 
 
 
 
 
  
                                                           
Number of properties 

7,728,479 

1,196,525 

6,531,954 

18.32% 

Total revenue 

300,742,279.28 

62,244,913.73 

362,987,193.01 

17.15% 

177 

 
 
 
Table 14 reports the top 5 origin countries with a higher number of cross-border hosts, 
along  with  the  total  revenue  that  these  hosts  earn  in  the  platform,  the  share  that  the 
revenue  represent  over  the  total,  and  the  number  of  properties  they  own.  Spain  is  the 
leader of the ranking, with  a revenue that represents  3.2% of the total.  Is  followed by 
France, Italy and United Kingdom, which present a similar proportion of revenue. 

Table 14 - Top 20 countries with cross-border hosts by revenue 

Rank 

Country of origin 

of the host 

Total revenue 

% revenue over 

Number of 

total in the platform 

properties 

1 

2 

3 

4 

5 

Spain 

France 

Italy 

585,711,345 

3.2% 

468,682,623 

2.6% 

428,097,104 

2.4% 

United Kingdom 

396,523,875 

2.2% 

Croatia 

196,283,498 

1.1% 

206,406 

160,001 

171,195 

102,733 

167,626 

178 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table  15  shows  the  evolution  of  cross-border  hosts  over  time.  As  it  can  be  seen,  the 
number  of  properties  and  the  average  revenue  generated  by  year  have  increased  over 
time232. Prices and ratings have remained more or less stable during the whole period.  

Table 15 - Evolution of cross-border hosts over time 

Year  Number of properties 

Mean annual revenue 

ADR  Ratings 

2014 

37,122 

2015 

78,627 

2016 

140,508 

2017 

243,131 

2018 

230,275 

2019 

236,254 

2020 

130,109 

2,376.3 

1,734.8 

1,582.5 

1,659.1 

2,220.3 

3,407.0 

5,284.0 

188.4 

4.49 

183.4 

4.49 

197.6 

4.51 

166.2 

4.49 

185.6 

4.51 

183.8 

4.51 

194.4 

4.53 

When looking at the distribution of reserved days per listing, i.e., how many days per 
year a listing was reserved, Table 16 reports the distribution of days reserved per year 
for the all EU27 countries and the whole period of study (2014-2020). The majority of 
the  listings  on  the  platform,  59%,  were  reserved  for  more  than  270  days  each  year.  
There is an 18% share of listings that had reservations for less than 30 days, and almost 
28% for less than 60 days.  

Table 16 - Range of days and available listings  

Range of days  % of listings 

1-30 

31-60 

61-90 

91-120 

121-150 

151-180 

181-210 

211-240 

241-270 

18.0 

9.8 

5.9 

3.3 

1.8 

1.1 

0.7 

0.4 

0.2 

232 Note that 2020 is not a representative year due to Covid-19 pandemic. 

179 

 
 
 
                                                           
270+ 

58.9 

Table  17  presents  the  yearly  evolution  of  the  range  of  days  reserved.  The  share  of 
listings  that were reserved for more than 270 days  each  year has declined through the 
period  of  study:  a  peak  of  78%  was  reached  in  2015,  whereas  in  2019  only  55%  of 
listings were reserved for more than 270 days. There is a 18% share of listings that had 
reservations for less than 30 days, and almost 28% for less than 60 days. The share of 
listings  reserved  for less than 30 days increased  from  12.5% in  2014 to 20% in  2019, 
whereas the share reserved for less than 60 days increased from about 19% to more than 
30% throughout the same period. 

Table 17 - Evolution of range of reservation days 

Range of reservation days 

Yea
r 

201
4 

201
5 

201
6 

201
7 

201
8 

201
9 

1-
30 

12.
5 

10.
7 

10.
9 

12.
0 

15.
0 

19.
9 

31-
60 

61-
90 

91-
120 

121-
150 

151-
180 

181-
210 

211-
240 

241-
270 

270
+ 

6.3 

3.5 

1.8 

1.1 

0.6 

0.4 

0.2 

0.1 

73.7 

5.4 

2.8 

1.6 

0.8 

0.5 

0.3 

0.2 

0.1 

77.7 

6.3 

3.8 

2.1 

1.1 

0.7 

0.4 

0.2 

0.1 

74.5 

7.0 

4.2 

2.3 

1.3 

0.7 

0.4 

0.3 

0.1 

71.8 

8.3 

5.0 

2.7 

1.5 

0.9 

0.5 

0.3 

0.2 

65.6 

10.6  6.4 

3.5 

2.0 

1.2 

0.7 

0.4 

0.3 

55.0 

Table 18 illustrates the range of days reserved by country throughout the whole 2014-
2020 period. Interestingly, Croatia and Greece have the highest share of listings that are 
reserved for less than 30 days (29 and 27 percent, respectively) and less than 60 (40 and 
39  percent,  respectively).  On  the  other  side  of  the  spectrum,  Denmark  and  the 
Netherlands have the highest share of listings reserved for more than 270 days (73 and 
69  percent,  respectively),  It  is  also  worthwhile  noting  that  in  all  countries  there  is  a 
relatively  limited  share  of  properties  that  have  an  intermediate  range  of  days  reserved 
(between 91 and 270 days).  

Table 18 - Range of reservation days by country 

1-

31-

61-

91-

121-

151-

181-

211-

241-

270

180 

 
 
 
 
 
 
 
30 

16.
9 

14.
4 

22.
9 

28.
8 

16.
7 

14.
3 

20.
1 

14.
4 

13.
8 

12.
8 

26.
6 

20.
3 

14.
5 

22.
4 

20.
1 

17.
9 

16.
6 

18.
8 

12.
2 

60 

90 

120 

150 

180 

210 

240 

270 

+ 

10.2 

6.8 

3.8 

2.0 

1.0 

0.4 

0.3 

0.1 

58.5 

7.1 

4.9 

3.6 

2.6 

2.1 

1.5 

1.2 

0.9 

61.6 

7.0 

3.1 

1.7 

0.9 

0.6 

0.4 

0.2 

0.1 

63.1 

11.1 

4.4 

1.5 

0.5 

0.2 

0.1 

0.0 

0.0 

53.4 

7.4 

5.2 

3.0 

1.7 

0.8 

0.5 

0.2 

0.1 

64.2 

5.3 

3.1 

1.8 

1.0 

0.6 

0.3 

0.2 

0.1 

73.2 

8.1 

5.3 

2.9 

1.7 

1.0 

0.6 

0.4 

0.1 

59.8 

6.2 

4.2 

2.8 

1.9 

1.2 

0.8 

0.5 

0.3 

67.6 

9.8 

7.0 

4.2 

2.5 

1.6 

1.0 

0.6 

0.4 

59.1 

6.3 

4.8 

4.1 

3.0 

2.0 

1.1 

0.6 

0.3 

65.1 

12.4 

5.4 

2.3 

1.0 

0.5 

0.3 

0.1 

0.1 

51.3 

9.3 

4.7 

2.5 

1.3 

0.8 

0.4 

0.2 

0.1 

60.3 

7.9 

6.5 

4.2 

2.5 

1.3 

0.7 

0.4 

0.2 

61.8 

11.3 

6.1 

2.8 

1.2 

0.5 

0.3 

0.1 

0.1 

55.3 

9.5 

5.6 

2.8 

1.3 

1.1 

0.5 

0.3 

0.2 

58.6 

8.3 

5.9 

3.7 

2.2 

1.2 

0.7 

0.4 

0.2 

59.6 

8.1 

5.2 

3.9 

2.1 

1.4 

1.3 

0.8 

0.3 

60.3 

9.5 

5.4 

2.8 

1.5 

0.8 

0.5 

0.2 

0.2 

60.5 

5.5 

3.9 

3.0 

2.3 

1.7 

1.2 

0.9 

0.6 

68.7 

Austria 

Belgium 

Bulgaria 

Croatia 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

181 

 
 
 
Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

16.
3 

20.
7 

20.
2 

19.
3 

21.
3 

18.
3 

15.
4 

8.8 

6.2 

4.4 

2.9 

2.0 

1.2 

0.8 

0.4 

57.0 

13.1 

8.0 

4.1 

2.2 

1.2 

0.6 

0.4 

0.2 

49.5 

6.5 

3.6 

2.4 

1.5 

1.1 

0.6 

0.3 

0.1 

63.6 

10.2 

6.5 

3.8 

2.2 

1.5 

0.8 

0.4 

0.2 

55.1 

14.1 

10.5 

4.8 

2.1 

1.1 

0.3 

0.1 

0.1 

45.7 

10.5 

5.7 

2.8 

1.4 

0.7 

0.4 

0.3 

0.1 

59.8 

8.3 

4.7 

2.4 

1.3 

0.7 

0.4 

0.2 

0.1 

66.4 

182 

 
 
 
 
 
 
ANNEX 6: LIST OF EXISTING AND PLANNED INSTRUMENTS 

6.1 EXISTING LEGISLATION 

6.1.1  Directive 2000/31/EC of the European Parliament and of the Council on 

certain legal aspects of information society services, in particular electronic 
commerce, in the Internal Market (the ‘e-Commerce Directive’) 

The  e-Commerce  Directive  applies  to  information  society  services.  These  cover  ‘any 
service  normally  provided  for  remuneration,  at  a  distance,  by  electronic  means  and  at 
the individual request of a recipient of services’.233 Online platforms are providers of 
information society services. 

The e-Commerce Directive contains provisions regulating the cross-border provision of 
information  society  services.  It  provides  that  Member  States  must  not  restrict  the 
freedom  to  provide  information  society  services  from  another  Member  State, 
unless where necessary for public policy objectives, public security, the protection 
of  public  health,  or  the  protection  of  consumers, including  investors,  and provided 
that:  

  any such restriction is proportionate to those objectives; and  
  before  taking  the  measures  in  question  the  Member  State  concerned  asked  the 
Member  State  where  the  provider  of  the  information  society  service  is 
established to  take measures and the latter did  not  take such measures,  or they 
were inadequate and notified the Commission and the Member State concerned 
of its intention to take such measures. 

In  addition,  it  provides  that  online  platforms,  as  providers  of  information  society 
intermediary  services,  are  under  certain  conditions  exempted  from  liability  for  the 
information  they  store. 234  Finally,  under  the  e-Commerce  directive  Member  States 
cannot  impose  on  collaborative  platforms,  to  the  extent  that  they  provide  hosting 
services, a general obligation to monitor or to actively seek facts or circumstances 
indicating illegal activity (prohibition of general monitoring obligation)235.  

The regulatory framework established by the e-Commerce Directive is updated by 
the  DSA, which clarifies the responsibilities of online platforms.  The DSA maintains 
and  reinforces  the  fundamental  principle  of  the  e-Commerce  Directive,  such  as  the 
conditional  liability  exemptions  for  online  intermediaries  (see  below  for  more 
information on the DSA).  

233 See Article 1(1)(b) of Directive 2015/1535. 
234 Article 14 of the e-Commerce Directive. 
235 Article 15(1) of the e-Commerce Directive 

183 

 
 
 
 
                                                           
6.1.2  Directive 2006/123/EC of the European Parliament and of the Council on 

services in the internal market (the ‘Services Directive’) 

The  Services  Directive  applies  to  services  supplied  by  providers  established  in  a 
Member State236 that are not specifically excluded from its scope237. As clarified by the 
CJEU238,  short-term  rental  services  are  ‘services’  within  the  meaning  of  the  Services 
Directive and are therefore covered by its scope.  

The  Services  Directive  applies  to  those  requirements  affecting  the  access  to,  or  the 
exercise  of,  a  service  activity. 239 The  concept  of  requirement  covers  any  obligation, 
prohibition,  condition  or  any  other  limitation  imposed  on  service  providers  (or 
recipients  of  services),  such  as  an  obligation  to  obtain  an  authorisation  or  to  make  a 
declaration to competent authorities, whether they are provided for in law, regulation or 
administrative provision and whether they are provided for at national, regional or local 
level.  For  example,  requirements  contained  in  municipal  zoning  plans 240  or  in 
regulations  adopted  by  a  city  council 241  are  covered  by  the  Services  Directive. 
‘Authorisation schemes’ include any procedure under which a provider or a recipient is 
in effect required to obtain from a competent authority a formal decision, or an implied 
decision, concerning access to a service activity, or the exercise thereof.242 

Accordingly,  the  Services  Directive  requires  that  service  providers  are  not  to  be 
subject to market access or other requirements, such as authorisations, unless they 
are non-discriminatory (i.e. not directly or indirectly discriminatory with regard to 
nationality or place of establishment), justified by an overriding reason relating to 
the public interest and proportionate (i.e. suitable to achieve the objective pursued, 
not going beyond what is necessary to attain the objective and not replaceable by 
less restrictive means to attain the same objective).243  

Ensuring  availability  and  affordability  of  housing,  the  protection  of  the  urban 
environment, public security, the protection of consumers and tax compliance have been 
recognised by the Court of Justice as relevant overriding reasons relating to the public 

236 Under Article 4(1) of Directive 2006/123 the concept of ‘service’ means any self-employed economic 
activity, normally provided for remuneration.  
237 Services  that  are  excluded  from  the  scope  of  the  Services  Directive  include,  in  relevant  part,  social 
services  relating  to  social  housing,  childcare  and  support  of  families  and  persons  permanently  or 
temporarily  in  need.  See  Article  2(2)j.  See  Article  2(2)  for  the  full  list  of  exclusions  from  the  Services 
Directive.  
238 Judgment of the Court (Grand Chamber) of 22 September 2020, C-724/18, Cali Apartments SCI and 
HX v Procureur général près la cour d'appel de Paris and Ville de Paris, ECLI:EU:C:2020:743. 
239 Article 4(7) of the Services Directive. 
240 Judgement of 30 January 2018, Visser, case C-360/15. 
241 Judgement of 1 October 2015, Trijber, case C-340/14. 
242 See the definition of “authorisation scheme” in Article 4(6). 
243 See Articles 9, 15 and 16 of the Services Directive. Articles 9 and 15 (establishment) allow Member 
States  to  justify  the  introduction  of  new  requirements  with  any  of  the  overriding  reasons  related  to  the 
public interest which have recognised by the Court of Justice (e.g. consumer protection, protection of the 
urban environment and adequate housing). However, according to Article 16 (free movement of services) 
Member States may only justify new restrictions with public policy, public security, public health or the 
protection of the environment. 

184 

 
 
 
                                                           
interest.244 At the same time, the Court has held that purely economic objectives, such 
as the protection of competitors or ensuring the economic basis of specific categories of 
providers, do not constitute an overriding reason relating to the public interest245. With 
respect  to  proportionality,  the  Court  of  Justice  has  ruled  that,  when  taking  these 
measures, Member State cannot rely on a general presumption of an objective being put 
at  risk246 and  that  they  must  present  precise  evidence  enabling  their  arguments  to  be 
substantiated247.  

The Services Directive  contains a list  of requirements that are explicitly prohibited248, 
and  a  list  of  requirements  that  can  be  imposed,  provided  that  they  are  non-
discriminatory,  necessary  and  proportionate 249 .  With  respect  to  authorisations,  the 
Services  Directive  requires  that  authorisation  schemes  be  non-discriminatory, 
justified  and  proportionate 250  and  that  their  conditions  be  non-discriminatory, 
justified, proportionate, clear and unambiguous, objective, made public in advance and 
transparent251. Authorisations must, in  principle, not  be granted for a limited period252 
and the procedures and formalities must be clear, made public in advance and allow for 
an objective and impartial assessment of the application253.  

The  Services  Directive  also  requires  Member  States  to  ensure  that  procedures  and 
formalities applicable to access to a service activity are sufficiently simple, and that 
may  be  easily  completed,  at  a  distance  and  by  electronic  means  through  the  relevant 
point of single contact and with the relevant authorities254. These provisions are relevant 
to registration schemes, which should not be burdensome and unduly restrict access to 
the market. 

244 A non-exhaustive list of overriding reasons of general interest is provided in Article 4(8) and Recital 
40  of  the  Services  Directive.  For  the  effectiveness  of  fiscal  supervision  see  Case  C-233/09,  Dijkman 
paras. 54, 58; Case C-254/97, Baxter and Others, para 18; Case C-478/98, Commission v Belgium, para. 
39. For housing policy objectives see Case C-567/07 Woningstichting Sint Servatius, para. 30, Case C-
302/97, Konle, para. 40; for combating the  long-term rental housing shortage see Joint  Cases  C-724/18 
and C-727/18, Cali Apartments, paras. 65 and 66.  
245 With regard to the TFEU, see Case C-400/08, Commission v Spain, para 74; Case C-338/09, Yellow 
Cab. Verkehrsbetrieb, para 51. 
246 See Case C-577/10, Commission v Belgium, para 53. 
247 See Case C-161/07, Commission v Austria, para 36. 
248 See  Article  14  of  the  Services  Directive.  Prohibited  requirements  include  economic  needs  tests; 
however, this prohibition does not concern planning requirements which do not pursue economic aims but 
serve overriding reasons relating to the public interest.  
249 See  Article  15  of  the  Services  Directive.  Requirements  subject  to  evaluation  include  quantitative  or 
territorial restrictions. 
250 See Article 9 of the Services Directive. 
251 See Article 10 of the Services Directive. 
252 See exceptions under Article 11(1) and 12 of the Services Directive. 
253 See Article 13 of the Services Directive. 
254 See Articles 5 and 8 of the Services Directive. 

185 

 
 
 
 
                                                           
6.1.3  Regulation (EU) 2016/679 of the European Parliament and of the Council of 
27 April 2016 on the protection of natural persons with regard to the 
processing of personal data and on the free movement of such data, and 
repealing Directive 95/46/EC (General Data Protection Regulation - GDPR) 
255 and Regulation (EU) 2018/1725 of the European Parliament and of the 
Council of 23 October 2018 on the protection of natural persons with 
regard to the processing of personal data by the Union institutions, bodies, 
offices and agencies and on the free movement of such data, and repealing 
Regulation (EC) No 45/2001 and Decision No 1247/2002/EC 

The  GDPR  applies  to  processing,  including  the  collection,  generation  and  sharing  of 
personal data, provided that they fall within the material and territorial scope defined in 
Articles 2 and 3 GDPR – in particular when online booking platforms, which hold the 
personal  data,  provide  access  to  the  Member  States  public  authorities  to  those  data, 
when  the  host  provide  their  personal  data  via  the  registration  form  and  the  Member 
States authorities process those data. All processing of personal data providing personal 
data to the Member State authorities about short-term rentals requires the existence of a 
legislation  (legal  basis)  to  process  this  data,  in  compliance  with  the  requirements  laid 
down  in  the  GDPR.  Therefore,  EU  legislation,  as  well  as  Member  States  legislation, 
have to respect the requirements of the GDPR. Under the GDPR, personal data can be 
processed  if  one  of  the  six  legal  bases  applies,  e.g.  if  the  processing  is  necessary  for 
compliance with a legal obligation or if the processing is necessary for a task carried out 
in  the  public  interest. 256 According  to  the  principles  of  purpose  limitation  and  data 
minimisation,  only  those  personal  data  must  be  collected  and  shared  which  are 
necessary  and  proportionate  for  achieving  the  purpose  of  the  processing.  Any  such 
legislation  will  have  to  specify  clearly  which  personal  data  would  be  transmitted  for 
which purpose to which public authority.  

Any technical tool developed and managed by the EU institutions would have to respect 
also  the corresponding requirements of Regulation (EU) 2018/1725  with  regard to  the 
processing of personal data by the Union institutions, bodies, offices and agencies. 

6.1.4  Regulation (EU) 2019/1150 on promoting fairness and transparency for 
business users of online intermediation services (the ‘P2B Regulation’)  

The P2B Regulation contains a set of rules to ensure a fair, predictable, sustainable and 
trusted  online  business  environment,  granting  business  users  of  online  intermediation 
services appropriate transparency, as well as effective redress possibilities.  

These rules create an obligation for online platforms, to inter alia and in accordance 
with  Article  9,  update  their  terms  and  conditions  to  provide  information  to 
business  users  about  whether  they  are  granted  access  to  the  data  generated 
through  their  use  of  the  online  platform  and  whether  data  is  shared  with  third 

255 Regulation  (EU)  2016/679  of  the  European  Parliament  and  of  the  Council  of  27  April  2016  on  the 
protection of natural persons with regard to the processing of personal data and on the free movement of 
such data, and repealing Directive 95/46/EC, OJ L 119, 4.5.2016, p. 1–88. 
256 See Article 6 of the GDPR. 

186 

 
 
 
                                                           
parties. Online platforms shall need to update their terms and conditions to refer 
to the data that could be shared with public authorities and give business users prior 
notice of this change, before it becomes effective.    

In  addition,  the  Regulation  imposes  a  reporting  obligation  on  larger  online 
platforms, which requires them to make easily available public information on the 
functioning  and  effectiveness  of  their  internal  complaint-handling  system  on  an 
annual  basis,  which  could  be  more  frequent  if  significant  changes  are  needed. 
Therefore,  any  reporting  obligations  imposed  by  the  STR  initiative  would  be  in 
addition to those already required by the P2B Regulation.  

Article 4 of the P2B Regulation requires notice  to be provided prior to the restriction, 
suspension  or  termination  of  a  business  users’  account.  Any  notice  and  takedown 
obligation  would  need  to  respect  the  time  periods,  notice  periods  and  requirements  to 
provide a reason and be listed as a possible grounds for removal of an offer in the terms 
and conditions in respect of providers of STR who are business users (Article 3(1)(c)). 
Such business users would have the possibility to lodge a complaint in accordance with 
the  procedures  for  complaint  handling  set  out  in  Article  11  and  also,  potentially  the 
subject of mediation under Article 12.  

Article  15  of  the  P2B  requires  Member  States  to  ensure  adequate  and  effective 
enforcement of the Regulation. Some Member States have taken steps to implement this 
provision  and  have  appointed  authorities  to  be  responsible  for  the  enforcement.  It  is 
possible that such authorities could take on the limited additional responsibility for the 
enforcement of the obligations on online platforms to share data.  

6.1.5  Regulation (EU) 2018/1724 of the European Parliament and of the Council 
of 2 October 2018 establishing a single digital gateway to provide access to 
information, to procedures and to assistance and problem-solving services 
(the ‘Single Digital Gateway Regulation’) 

The  Single  Digital  Gateway  was  established  to  facilitate  online  access  to  the 
information,  key  administrative  procedures  for  cross-border  users,  as  well  as  on 
available  assistance  services  for  citizens  and  businesses  encountering  problems  when 
exercising  the  internal  market  rights  while  living  in  or  doing  business  in  another  EU 
Member State.  

In particular, the Single Digital  Gateway establishes a single online point of access  to 
information, procedures and assistance, guiding users to information on national and EU 
rules, rights and procedures, as well as to the websites where they can carry out these 
procedures online and direct users towards assistance and problem-solving services. The 
gateway  includes  a  common  user  interface  integrated  into  the  existing  ‘Your  Europe’ 
portal. In practical terms, a search function on the ‘Your Europe’ portal will give access 
to the information, procedures and assistance sought. 

The  regulation  establishing  the  gateway  also  includes  provisions  for  digitalising 
administrations.  In  relevant  part,  it  requires  that  the  key  administrative  procedures  be 

187 

 
 
 
available online to both users in their own country as well as to cross-border users.257 In 
addition,  the  ‘once-only  principle’  (i.e.  users  should  not  have  to  submit  to  authorities 
documents  or  data  already  held  by  other  authorities)  will  be  applied  to  cross-border 
exchanges  of  evidence  for  a  range  of  procedures.  For  these  procedures,  users  will  be 
given  the  option  to  request  the  direct  exchange  of  evidence  between  authorities  in 
different EU countries.  

The  new  gateway  will  integrate  several  networks  and  services  that  have  been 
established  at  national  and  EU  level  to  assist  citizens  and  businesses  in  their  cross-
border  activities.  The  functioning  of  the  gateway  will  be  supported  by  technical  tools 
developed  by  the  Commission  in  cooperation  with  national  administrations.  The 
regulation shall be fully implemented by all national, regional and local administrations 
by end of 2023. 

The  Single  Digital  Gateway  does  not  have  the  purpose  to  streamline  /  coordinate 
national systems or policies towards a common European approach. It also does not aim 
at aligning national processes to one single uniformed and comprehensive EU process. 
However,  the  Single  Digital  Gateway  will  help  EU  citizens  to  identify  the  relevant 
national (or EU) Single Digital Entry Points interface, which would be relevant for an 
STR initiative.  

6.1.6  Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 

2011/16/EU on administrative cooperation in the field of taxation (s.c. 
‘DAC7’) 

Council Directive (EU) 2021/514 has amended Directive 2011/16/EU on administrative 
cooperation  in  the  field  of  taxation  extending  the  EU  framework  on  the  automatic 
exchange of information in the field of taxation. Member States have to transpose this 
Directive by 31 January 2022 and apply the new provisions from 1 January 2023.  

The  purpose  of  this  amendment  was  to  (i)  address  the  potential  loss  of  tax  revenue 
caused by unreported income earned through the sale of goods and services via online 
intermediating platforms and (ii) ensure a level  playing field  between operators active 
on platforms and traditional businesses.  

To  this  end,  the  new  rules  create  an  obligation  for  platforms  to  report  the  income 
earned  by  sellers  and  for  the  Member  State  where  reporting  takes  place,  to  exchange 
this information automatically. They introduce due diligence procedures and an annual 
reporting obligation on platforms located both inside and outside the EU concerning 
information on sellers that use the platforms to earn income. This includes, among other 
activities, the rental of immovable property, including on a short-term basis.  

Platforms  must  collect  the  following  information  and  assess  its  reliability  using  all 
information  and  documents  available  in  their  records,  including  their  electronically 
searchable records: 

257 By  end  of  2023  at  the  latest,  a  list  of  21  important  administrative  procedures  will  be  fully  available 
online in all EU countries, covering situations that are relevant for doing business, working, studying or 
moving from one location to another. 

188 

 
 
 
                                                           
 

 

 

 

 

 

 

the first and last name of the host258 who is an individual, or its legal name if the 
host is an entity; 

the primary address; 

the tax identification number (TIN) of the host, including each Member State of 
issuance,  or,  in  the  absence  of  a  TIN,  the  place  of  birth  of  the  host  who  is  an 
individual; 

the business registration number of the host that is an entity; 

the VAT identification number of the host, where available; 

the date of birth of the host who is an individual; 

the  address  of  each  property  listing  and,  where  issued,  respective  land 
registration number or its equivalent under the national law of the Member State 
where it is located, where available. 

Platforms must report the following information to the relevant Member State: 

  details  of  the  platform  (name,  registered  office  address,  TIN,  as  well  as  the 
business name(s) of the platform(s) in respect of which the Reporting Platform 
Operator is reporting)259; 

 

the information collected and listed above; 

  the  Financial  Account  Identifier  (where  the  financial  account  to  which  the 
consideration  is  paid  is  different  from  the  name  of  the  seller,  the  name  of  the 
account holder is  required along with  any other financial information available 
to the Reporting Platform Operator with regard to this account holder); ;  

  Member State(s) of residence of the host; 

 

the  revenue  received  during  each  quarter  and  the  number  of  relevant  activities 
provided with respect to each property listing; 

  any fees, commissions or taxes withheld or charged by the platform during each 

quarter; 

  where  available,  the  number  of  days  each  property  listing  was  rented  and  the 

type of each property listing. 

The Member State where reporting takes place will then share the relevant information 
with the competent tax authorities of the other relevant Member State(s).  

258 Under DAC7 the host would be identified with the “reportable seller”. 
259 The Reporting Platform Operator may be reporting on behalf of other members of the Group. 

189 

 
 
 
                                                           
DAC7  requires  Platform  Operators  to  report  certain  information  with  the  competent 
authorities of Member States. A significant  part  of this information  is  relevant  for the 
enforcement of STR rules. However, according to GDPR rules, a legal basis would have 
to be introduced in national or European law in order to allow the transfer of this data 
from  the  competent  tax  authorities  of  Member  States  to  their  public  authorities 
enforcing  STR  rules.  In  addition,  as  the  reporting  takes  place  annually,  local  public 
authorities  would  not  obtain  up-to-date  information  on  providers  of  STR  services  that 
would allow them to undertake effective and timely law-enforcement action. What they 
would obtain under DAC7, is an annual dataset that they could use to check, ex post, the 
correctness  and  completeness  of  the  data  in  the  registration  scheme  that  could  be 
established under the present STR initiative.  

6.1.7  Council Directive 2006/112/EC of 28 November 2006 on the common system 

of value added tax260 (s.c. ‘VAT Directive’)  

Article 242a of the VAT Directive is part of the e-commerce package, which came into 
effect in July of 2021. The e-commerce package introduced a set of new rules designed 
to make cross border e-commerce simpler and fairer. Under this package, online sellers 
of goods and services (including marketplaces and platforms) to private consumers 
(B2C)  are  only  required  to  register  in  one  Member  State  from  which  they  can 
discharge  their  VAT  obligations  in  other  Member  States  via  the  one-stop-shop 
(OSS).  There  is  a  threshold  of  EUR  10,000  below  which  supplies  of  telecoms, 
broadcasting  and  e-services,  and  distance  sales  of  goods  within  the  EU  are  accounted 
for on the domestic VAT return of the supplier. 

The rules also introduce ‘deemed supplier’ provisions for certain supplies of goods – i.e. 
where  a  marketplace/platform  facilitates  the  supply  of  B2C  goods  from  a  supplier 
outside  the  EU.  Article  242a  (and  the  linked  Articles  54b  and  54c(2)  of  the  VAT 
Implementing Regulation261) obliges platforms  to keep records of the B2C supplies 
of goods and services that it facilitates and make these available electronically on 
request  to  Member  States.  The  definition  of  ‘sufficient  detail’  is  outlined  in  the 
Implementing Regulation – where the platform/marketplace isn’t the deemed supplier, 
this includes the name, address, email address/website of the supplier, any VAT number 
or  national  tax  number  the  supplier  might  have,  and  details  of  the  supply.  This 
information  should  be  made  available  electronically  on  request  to  the  Member  States 
concerned.  Where  the  platform  is  the  deemed  supplier,  the  normal  VAT  accounting 
rules  apply  he  has  record-keeping  obligations  like  any  other  supplier.  In  this  respect, 
Article 54c(1) of the VAT Implementing Regulation clarifies that the deemed supplier 
shall keep the following records:  

1. 

If he uses one of the special schemes provided for in Chapter 6 of Title XII of 
the  VAT  Directive:  the  records  as  set  out  in  Article  63c  of  the  VAT 
Implementing Regulation;  

260 As  last  amended  by  Council  Directive  (EU)  2017/2455  of  5  December  2017  amending  Directive 
2006/112/EC  and  Directive  2009/132/EC  as  regards  certain  value  added  tax  obligations  for  supplies  of 
services and distance sales of goods 
261 Council  Implementing  Regulation  (EU)  No 282/2011  of  15 March  2011  laying  down  implementing 
measures for Directive 2006/112/EC on the common system of value added tax. 

190 

 
 
 
                                                           
2. 

If he does not use any of these special schemes: the records as set out in Article 
242  of  the  VAT  Directive.  In  this  situation,  each  national  legislation  sets  out 
what  are  the  records  to  be  kept  by  taxable  persons  and  in  which  form  they 
should be kept. 

Article 242a of the VAT Directive requires platforms to retain certain information 
for inspection by Member States’ authorities, for example when there are concerns of 
fraud  A  significant  part  of  this  information  appears  relevant  for  enforcement  of  STR 
rules too. However, without an obligation to systematically report this information 
to Member States’ authorities this framework is not sufficient to address the lack 
of transparency affecting the STR sector. In addition, as it is the case for DAC7, a 
legal  base  would  have  to  be  introduced  in  national  or  European  law  in  order  to 
allow the transfer of this data from the competent authorities of Member States to 
their public authorities enforcing STR rules.  

6.2 Proposals 

6.2.1  The DSA 

The  DSA,  updates  and  clarifies  the  responsibilities  for  providers  of  intermediary 
services,  and  in  particular  online  platforms 262  The  DSA  will  also  establish  a 
common  framework  for  the  supervision  of  digital  services  providers  and 
enforcement through an EU-cooperation mechanism. The Commission will also be the 
main  enforcer  for  very  large  online  platforms  (i.e.  platforms  having  more  than  45 
million  users  in  the  EU).  The  DSA  maintains  the  key  principles  of  the  e-Commerce 
Directive,  in  particular  the  country  of  origin  principle,  the  provisions  concerning  the 
liability  of  intermediaries  and  the  prohibition  of  general  monitoring  obligation.  A 
political  agreement  between  the  Council  and  the  European  Parliament  was  reached  in 
April 2022.  

The proposed DSA is relevant for the STR initiative for the following reasons:  

  Removal of illegal STR listings: According to Article 8 of the DSA, platforms 
must  inform  the  issuing  authority  on  the  effect  given  to  the  order  to  act 
against a specific item of illegal content, where such an order is issued by a 
relevant  national  judicial or administrative authority on the basis of Union law 
or  national  law,  and  in  compliance  with  the  requirements  set  out  in  the  DSA. 
The DSA does not address what is illegal content. Authorities would be able, for 
example,  to  order  to  a  platform  established  in  another  EU  Member  State  to 
takedown individual illegal STR  listings (e.g. without a registration number). 
In addition, platforms must establish notice and action mechanisms to allow any 
individual  or  entity  to  inform  them  of  the  presence  of  information  that 

262 Under  the  proposed  DSA,  online  platforms  (which  are  providers  of  hosting  services)  are  exempted 
from liability for the illegal content they store if they do not have actual knowledge of the illegal activity 
or content or if they act expeditiously  to remove  or disable access to such content upon obtaining such 
knowledge. The DSA does not address  what is  illegal but  it establishes  mechanisms  to enable Member 
States  to  enforce  the  law  by  sending  orders  to  service  providers  established  elsewhere  in  the  single 
market. 

191 

 
 
 
                                                           
constitutes  illegal  content  on  their  websites263.  Once  a  sufficiently  precise  and 
adequately substantiated notice is received it shall be processed by the platform 
without  undue  delay.  A  privileged  channel  is  foreseen  for  entities  that  have 
demonstrated particular expertise and competence (“trusted flaggers”) to  report 
illegal content to which platforms will have to react with priority.  

  Requests  for 

information:  the  DSA  also  regulates  orders  to  provide 
information in cross-border situations. According to Article 9, online platforms 
shall, upon receipt of an order to provide specific information about one or more 
specific  individual  recipients  of  the  service,  issued  by  the  relevant  national 
judicial  or  administrative  authorities  on  the  basis  of  the  applicable  Union  or 
national  law,  in  compliance  with  Union  law,  inform  without  undue  delay  the 
authority of issuing the order or any other authority specified in the order of its 
receipt,  of  the  effect  given  to  the  order,  specifying  if  and  when  the  order  was 
applied. For example, platforms can be required by an authority from a different 
jurisdiction  than  the  one  where  they  are  established  to  provide  specific 
information  about  an  apartment  owner,  but  not  entire  groups  or 
populations.  

  Due  diligence  requirements:  the  DSA  introduces  such  requirements  for  all 
intermediaries  and  more  specifically  for  online  platforms  to  make  sure  that 
online  platforms  behave  more  responsibly  and  transparently.  Due  diligence 
transparency  reporting  obligations 
requirements 
regarding  content  moderation  activities  conducted  by 
intermediaries,  a 
requirement  to  include  on  their  terms  and  conditions  information  on  any 
restriction  that  they  impose  in  relation  to  the  use  of  their  service  and  a 
complaint-handling system for users of online platforms.  

include,  among  others, 

In addition, the DSA includes specific due diligence obligations for online marketplaces 
to: 

  Ensure traceability of traders through an obligation to:  

o  collect  information  on  traders  including the name, address,  telephone 
number  and  electronic  mail  address  of  the  trader;  a  copy  of  the 
identification  document  of 
trader  or  any  other  electronic 
identification264; the bank payment account details of the trader; the trade 
register  and  registration  number  of  the  trader,  where  applicable;  and  a 
self-certification  by  the  trader  committing  to  only  offer  products  or 
services that comply with the applicable rules of Union law;  

the 

o  make best efforts to assess the information provided by traders;  

263 These notices are considered to give rise to “actual knowledge” triggering liability. 
264 In line with Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 
2014 on electronic identification and trust  services for electronic transactions in the internal market and 
repealing Directive 1999/93/EC. 

192 

 
 
 
 
 
                                                           
o  make the information concerning the identity and contact details of 
the  trader,  the  trade  register  and  registration  number  (where 
applicable) and the self-certification available to the recipients of the 
service,  at  least  on  the  product  listing,  in  a  clear,  easily  accessible  and 
comprehensible manner265; 

  Ensure ‘compliance by design’ through an obligation to design and organise 
their  online  interface  in  a  way  that  enables  traders  to  comply  with  their 
obligations regarding pre-contractual information and product safety information 
under  applicable  Union  law,  including  the  information  necessary  for  the  clear 
and  unambiguous  identification  of  the  products  or  the  services  promoted  or 
offered to consumers.266 This is relevant in case a registration number has to be 
displayed by services providers. 

With respect to the STR initiative, the DSA shows the following limitations:  

  Due  diligence  requirements  for  online  marketplaces  only  apply  with  respect  to 
listings  published  by  ‘traders’.  These  are  any  natural  or  legal  person 
“acting…for  purposes  relating  to  his  or  her  trade,  business,  craft  or 
profession”.267 STR  service  providers  (i.e.,  hosts)  are  often  private  individuals 
offering  assets  or  services  on  an  occasional  peer-to-peer  basis.  A  case-by-case 
assessment would be required to understand if in any given case such providers 
would qualify as traders for due diligence provisions to apply;  

  The  DSA  will  give  public  authorities  a  tool  to  facilitate  the  enforcement  of 
orders  to  provide  specific  information  about  individual  users,  and  thus  to 
investigate  in  more  detail  individual  providers  of  STR  services  that  authorities 
suspect act in a fraudulent manner. However, its provisions to do not extend to 
an obligation to collect and share data that applies to all hosts268.  

6.2.2  The DMA  

The DMA proposal was adopted by the Commission on 15 December 2020269 and is a 
key  component of the European digital  strategy  to  make Europe fit for the digital  age 
aiming  to  ensure  contestable  and  fair  markets  in  the  digital  sectors  across  the  Union. 
The DMA is part of the ambitious reform of the digital space together with the Digital 
Services  Act,  aiming  at  ensuring  a  safe  and  accountable  online  environment.  On  24 
March 2022, the European Parliament and the Council reached a political agreement on 
the  DMA  that  is  now  subject  to  formal  approval  by  the  two  co-legislators.  Once 

265 See Article 24c of the compromise text reached by the co-legislators. 
266 See Article 24d of the compromise text reached by the co-legislators. 
267 See Article 2(e) of the compromise text reached by the co-legislators.  
268 See recital 32 of the compromise text reached by the co-legislators. 
269 Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  and  of  the  Council  on 
contestable and fair markets in the digital sector (Digital Markets Act), COM/2020/842 final. 

193 

 
 
 
 
 
                                                           
 
adopted, the DMA Regulation will be directly applicable across the EU and will apply 
six months after entry into force. 

The  DMA  will  apply  to  gatekeepers,  companies  which  act  as  gateways  between 
businesses and consumers, and sometimes even control entire ecosystems, made up of 
different  core platform  services such as online marketplaces, operating systems,  cloud 
services  or  online  search  engines.  These  gatekeepers  will  be  subject  to  a  number  of 
clearly  defined  obligations  and  prohibitions.  The  aim  of  the  DMA  is  to  tackle  unfair  
practices, including practices that create or strengthen barriers for other companies, with 
the overall aim of ensuring the contestability of core platform services. 

At the same time, the DMA will create  an effective enforcement mechanism ensuring 
rapid compliance with the obligations and prohibitions.   

The  DMA  aims  to  curb  the  gatekeeper  power  of  gatekeepers  and  may  apply  to 
some  platforms  offering  STR  services  should  they  be  designated  as  gatekeepers 
according to the rules laid down in the DMA.  

6.2.3  Revision of the eIDAS Regulation – European Digital Identity (Proposal for 
a Regulation of the European Parliament and of the Council amending 
Regulation (EU) No 910/2014 as regards establishing a framework for a 
European Digital Identity) 

The  objective  of  the  proposal  submitted  by  the  Commission  on  3  June  2021,  is  to 
provide a future proof regulatory framework to support an EU-wide, simple, trusted and 
secure  system  to  manage  identities  in  the  digital  space,  covering  identification, 
authentication and the provision of attributes, credentials and attestations. The Proposal 
offers  a  harmonised  approach  to  security,  for  citizens  relying  on  a  European  digital 
identity representing them online, and for online service providers who will be able to 
fully rely on and accept digital identity solutions independently of where they have been 
issued. To that end, it currently requires EU Member States to issue a European Digital 
Identity Wallet that will enable all natural and legal persons in the EU to have secure, 
trusted and seamless access to cross-border public and private services.  

The EU Digital Identity Wallet will enable users (i.e., natural and legal persons) to 
securely  request  and  obtain,  store,  select,  combine  and  share  the  necessary  legal 
person  identification  data  and  electronic  attestation  of  attributes  to  authenticate 
online  and  offline  in  order  to  use  online  public  and  private  services  and  sign  by 
means of qualified electronic signatures270.  

The proposal includes provisions on the cross-border reliance on the European Digital 
Identity Wallet. The aim is to ensure that users can rely on the use of European Digital 
Identity  Wallets  to  access  online  services  provided  by  public  sector  bodies  and  by 
private  service  providers  requiring  the  use  of  strong  user  authentication.  In  addition, 
where  private  parties  are  required  by  national  or  Union  law  to  use  ‘strong  user 

270 Article 6a of the proposal. 

194 

 
 
 
                                                           
authentication’ 271  for  online  identification,  or  where  strong  user  authentication  is 
required  by  contractual  obligation,  such  parties  are  also  required  to  accept  the  use  of 
European Digital Identity Wallets issued in accordance with the requirements set forth 
in the proposal.  

There could be added value for the STR sector: hosts could be obliged to only offer 
services  under  their  digital  identity  and  this  would  provide  authorities  with  some 
valuable  insights,  as  well  as  trusted  data  while  strengthening  traceability  of  hosts  and 
enforceability  of  applicable  rules.  Moreover,  there  could  be  an  automation  of  the 
registration of hosts if and when they can only sign up for a platform using their digital 
identity.  The  European  Digital  Identity  Wallet  it  will  make  it  easier  to  provide  STR 
accommodation services cross-border. 

6.2.4  The Data Act Proposal 

The Data Act Proposal was adopted by the Commission on 23 February 2022272 and is 
the second major legislative initiative implementing the European strategy for data and 
building on the Data Governance Act.  

With the Data Act Proposal, the Commission wants to maximise the value of data for 
the  economy  and  society,  while  respecting  the  legitimate  interests  of  companies  that 
invest in tools and technologies for generating the data.  

The  Data  Act  will  ensure  fairness  in  the  digital  environment,  stimulate  a  competitive 
data  market,  open  opportunities  for  data-driven  innovation  and  make  data  more 
accessible for all. It will lead to new, innovative services and more competitive prices 
for aftermarket services and repairs of connected objects.  

Pending  the  adoption  of  the  proposal,  it  is  expected  that  the  Data  Act  will,  among  a 
range of other measures, introduce new  mechanisms  for  the  reuse  of  commercially-
held  data  by  public  sector  bodies  in  exceptional  ad-hoc  situations.  These 
mechanisms  will  cover  both  public  emergencies  and  other  exceptional  situations 
where  the  data  needs  of  public  authorities  cannot  be  met  through  available 
mechanisms  or  where  a  different  way  of  collecting  the  data  would  lead  to 
substantial  reduction  of  administrative  burden  for  companies,  replacing  existing 
reporting obligations.  

The Data Act Proposal, however, explicitly excludes obligations laid down in Union or 
national  law  for  the  purposes  of  reporting,  complying  with  information  requests  or 
demonstrating or verifying compliance with legal obligations from its scope. It does not 
impose reporting obligations on online platforms. The Data Act is therefore expected 

271 Strong  user  authentication  means  “an  authentication  based  on  the  use  of  two  or  more  elements 
categorised  as  user  knowledge,  possession  and  inherence  that  are  independent,  in  such  a  way  that  the 
breach of one does not compromise the reliability of the others, and is designed in such a way to protect 
the confidentiality of the authentication data”. 
272 Proposal for a Regulation of the European Parliament and of the Council on harmonised rules on fair 
access to and use of data (Data Act), COM/2022/68 final.  

195 

 
 
 
                                                           
to not provide a solution for access to privately-held data by public sector bodies 
on a regular or reoccurring basis as it would be the case for the STR initiative. 

6.2.5  The Tourism Data Space  

The  Data  Governance  Act  sets  the  goal  to  create  an  EU-wide  common,  interoperable 
data spaces in strategic sectors aims at overcoming legal and technical barriers to data 
sharing.  A  key  sector  of  the  EU  economy,  averaging  11%  of  the  GDP  of  the  internal 
market, tourism will also benefit from a sectoral data space, which should address the 
wide fragmentation of data sources, holders and means of collection.  

In  practice,  a  common  European  data  space  for  tourism  would  bring  together  in  one 
digital ecosystem relevant, existing data sets in order to facilitate the voluntary pooling 
and sharing of information. This would allow the stakeholders to count on a larger pool 
of  data  sets  than  they  would  be  able  to  reach  on  an  individual/national  basis,  and  it 
would  encourage  collaborations,  synergies  and  public-private  partnerships.  The  data 
space for tourism does not aim at being a market place (i.e., allowing bookings), and 
is  not  a  tool  for  data  generation:  its  objective  is  for  data  to  help  tourism  businesses 
improve  and  expand  their  services  and  authorities/destinations  manage  tourism  flows 
better.    

The  Work  Programme  2021-2022  of  the  Digital  Europe  Programme  earmarked  1mln 
EUR for a Coordination and Support Action aiming at providing the Commission with 
preparatory  work  for  a  data  space  in  tourism.  The  project  is  expected  to  kick  off  in 
Q32022, for a duration of 12 months, and deliver recommendations for a governance of 
the tourism data space, as well as a roadmap for its creation.  

196 

 
 
 
 
 
 
ANNEX 7: EXAMPLES OF LITIGATION 

1.  On cooperation of platforms 

Vienna: city authorities sent a list of illegal STRs located in municipal (social) housing 
to platforms, asking them to remove those listings. Airbnb refused to comply – in 2020 
the city took  the platform  to  court for failure to meet  its  obligation. The  Commercial 
Court  of  Vienna  (Handelsgericht)  ruled  in  a  first-instance  decision  that  municipal 
(social)  housing  apartments  may  not  be  offered  for  rent  through  the  platform.  The 
Higher  Court  partly  confirmed  the  judgment  of  the  Commercial  Court,  insofar  as 
Airbnb  is  obliged  to  cease  to  display  listings  for  rentals  or  subletting  of  apartments 
belonging to the City of Vienna, of which the addresses are known to Airbnb. However, 
several additional claims of the City of Vienna were dismissed, namely: the obligation 
for  the  platform  to  display  the  name  and  address  of  the  host  on  the  website;  the 
obligation  for  the  platform  to  share  with  the  City  of  Vienna  any  sales  and  profits 
generated  from  offers  renting  social  housing;  the  obligation  for  the  platform  to  hand 
over such profits to the City of Vienna.273 The judgment is not final. An appeal to the 
Supreme  Court  (OGH)  against  this  judgment  has  been  lodged  by  both  parties  to  the 
proceedings.  

Barcelona:  at  the  national  level,  according  to  a  change  in  national  tax  law  (Real 
Decreto 1070/2017), as of 1/01/2019, STR platforms had to send Spanish tax authorities 
details of all their operations in Spain, including: identity of owner of STR unit, address, 
number of days  of occupation, revenues collected. This  obligation was cancelled by  a 
Supreme Court judgement of 23/07/2020 but will be reinstated again for the 2021 tax 
year through a new, duly approved, national law.274 

intermediaries  (platforms) 

Brussels:  Regional  ordinance  of  2016  requires 
to 
communicate detailed data on individual operators and bookings to regional tax office. 
If  they  refuse  a  fine  of  €10,000  can  apply.  Airbnb  received  several  fines  for  not 
transferring  required  data.  The  platform  lodged  a  court  case  against  the  regional 
ordinance in front of the Belgian  Constitutional  Court, which turned to the CJEU in 
November  2020  to  ask  whether  regional  law  is  compatible  with  the  e-Commerce 
Directive.275 In  its  judgment  issued  on  27  April  2022,  the  CJEU  confirmed  that  the 
relevant national provision imposing such information obligations for tax purposes is in 
line with the EU law.276 

Paris:  Lack  of  display  of  registration  number  on  listings:  €12,500  per  listing  (in 
February 2019 the Mayor of Paris lodged a court case in order to fine Airbnb €12.625 
million for the publication of 1,010 listings that did not display a registration number). 

273 Handelsgericht Wien – 43Cg 51/20b, OLG Wien 2R 95/21m. 
274 C. Colomb, T. Moreira de Souza, Regulating short-term rentals. Platforms-based property rentals in 
European Cities: the policy debates, op. cit. 
275 Ibid, 76. 
276 Judgment of the Court (Second Chamber) of 27 April 2022, Airbnb Ireland UC v Région de Bruxelles-
Capitale, Case C-674/20. 

197 

 
 
 
                                                           
Airbnb  was  fined  €8  million  for  displaying  listings  without  registration  number  by  a 
ruling of the tribunal judiciaire de Paris of July 2021.277 

Paris: failure to comply with data sharing obligation by Booking.com. The French law 
provides  that  until  31st  December  of  the  following  year,  cities  where  registration 
schemes are in place can request online platforms certain data on STR listings (number 
of nights rented out, host’s name, address, registration number, main residence or not). 
This information can be asked once a year, and platforms have one month to send the 
data.  Failure  to  comply  with  the  request  is  punishable  by  a  fine  of  up  to  €50,000  per 
illegal  STR  listing.  On  6  January  2021 278,  the  City  of  Paris  sued  Booking.com  for 
failure to comply with this obligation. The Paris Judicial Court rendered its ruling on 18 
October 2021. It ruled that the contested provisions are not a restriction to the freedom 
to  provide  information  society  services,  and  that  Booking.com  is  a  content  editor  and 
presumed to hold the data required by law. For the determination of the quantum of the 
fine, the judges observed that although Booking.com did not respect the timeframe set 
by the law for the transmission of the information it requires regarding more than 6,000 
ads  (the  City  of  Paris  only  complained  about  3,085),  it  did  end  up  making  efforts  to 
transmit  them  in  the  required  format.  As  a  consequence,  it  sets  the  fine  at  €400  per 
illegal  STR  listing,  amounting  to  a  total  fine  of  €1,234,000  (the  City  asked  for 
€154,250,000). 

2.  On short-term rental rules 

Barcelona:  the  Special  Plan  for  Tourist  Accommodation  (PEUAT)  was  approved  in 
January 2017. It applies to all types of tourist accommodation (hotels, hostels and STR) 
and is based on a principle of ‘zero growth’ of the existing total number of licenses for 
such  forms  of  accommodation.  C.  Colomb  finds  that:  “As  of  early  2020,  nearly  100 
legal cases against the PEUAT had been lodged in front of the High Court of Justice 
of  Catalonia.  In  August  2019,  the  Court  published  a  decision  that  called  for  the 
cancellation of the PEUAT on the grounds of a lack of evaluation of the financial and 
economic  impacts  of  its  implementation.  In  other  decisions,  it  only  invalidated  some 
parts of the PEUAT. The regional court, however, did not question the overall objective 
of the plan (i.e. the strict regulation of tourist accommodation in certain parts of the city 
for reasons of public interest), nor did it suggest it contravened the Spanish legislation 
translating  the  EU  Services  Directive  (see  Section  5.3).  In  November  2019,  the  city 
government of Barcelona appealed against the cancellation of the PEUAT in front of the 
Spanish Supreme Court, which has yet to issue its ruling. Meanwhile, the plan remains 
valid.”279 

Madrid: In March 2019, a special plan to regulate STR was approved (Plan Especial de 
usos del Hospedaje). It imposed “strict conditions for the granting of a license, requiring 
in  particular  a  STR  unit  to  have  a  separate  entrance  and  lift  from  those  used  by  the 

277 Airbnb  condamnée  à  8 millions  d’euros  d’amende  à  Paris  pour  des  annonces  sans  numéro 
d’enregistrement (lemonde.fr) 
278 Paris Judicial Court, 18th October 2021, City of Paris vs Booking.com 
279 C. Colomb, T. Moreira de Souza, Regulating short-term rentals. Platforms-based property rentals in 
European Cities: the policy debates, op. cit. 

198 

 
 
 
                                                           
residents  of  the  building.  These  rules  apply  in  specific  zones  defined  in  the  plan  that 
cover the historic centre and surrounding neighbourhoods. These strict requirements de 
facto turned 95% of the existing STR offer in Madrid (approximately 10,000 flats) into 
illegal units.”280 The plan was challenged in Court. In February 2021, the  High  Court 
of Justice of the Madrid Region upheld the plan approved in March 2019, ruling that 
its  objectives  constitute  acceptable  ‘reasons  of  public 
the 
desertification and gentrification of specific neighbourhoods. 

to  avoid 

interest’ 

Amsterdam:  the  city  government  banned  all  vacation  rentals  from  three  city  centre 
districts in the old town from 1 July 2020, responding to concerns about ‘overtourism’. 
The  professional  organisation  representing  STR  operators  (Amsterdam  Gastvrij) 
challenged the ban, which was declared illegal by the Court of Justice of Amsterdam 
on  12  March  2021.  The  court  argued  that  a  system  of  permits  cannot  contain  a  total 
prohibition,  which  infringes  on  the  right  to  property  and  the  free  movement  of 
services.281 

Berlin: the relevant framework is the Law on the Prohibition of Misuse of Housing of 
2013 (Zweckentfremdungsverbot) and the associated decree of 2014, which banned the 
use  of  apartments  for  purposes  other  than  permanent  residence.  ‘Misuse’  includes 
commercial  use,  long-term  vacancy  and  short-term  letting.  The  law  included  a  2-year 
transition  period  for  ‘misuses’  that  were  active  before  1/05/2014,  allowed  until 
1/05/2016.  After  that,  STR  was  only  allowed  if  a  permit  was  obtained  from  district 
(Bezirk) authorities. The law was modified on 20/04/2018 (following court rulings)  to 
allow the STR of a primary or secondary residence subject to condition.282 

Paris: 420 cases pursued by the city of Paris again Airbnb hosts283; these hosts have not 
respected the obligation to register to start a STR activity and/or the nightly stay cap of 
120 days per year for primary residences. These cases were put on hold until the ruling 
by the Court of Justice in the Cali Apartments case on 22 September 2020. The penalty 
incurred is 50.000 euros. 

280 Ibid, 42. 
281 Ibid, 42. 
282 Ibid, 73. 
283 AIRBNB : Reprise des poursuites par la Ville de Paris - Romain Rossi-Landi (rossi-landiavocat.fr) 

199 

 
 
 
 
 
                                                           
ANNEX 

8:  OVERVIEW  OF  REGISTRATION  PROCEDURES  AND 
REQUIREMENTS  ON  PLATFORMS  CONCERNING  STR  IN  EU  MEMBER 
STATES 

Based on the information gathered through consultations284, surveys, questionnaires and 
research 285 ,  there  are  overall  23  Member  States  with  some  type  of  registration 
procedures286 and/or  requirements  that  would  enable  them  to  gather  information  from 
platforms. These Member States are the following: 

Austria 

Belgium 

Bulgaria 

Croatia  

Cyprus  

Czechia  

Denmark  

France  

Germany  

Greece  

Hungary  

Ireland  

Italy  

Latvia  

Lithuania 

Luxembourg  

Malta  

The Netherlands  

Poland  

Portugal  

Slovakia  

Slovenia 

Spain 

In  addition  to  the  countries  where  these  measures  are  in  place,  for  one  Member  State 
(Romania) legislation is in preparation. 

rentals 

284 These include consultations with Member States and platforms. 
285 See,  in  particular:  C.  Colomb,  T.  Moreira  de  Souza,  Regulating  short-term  rentals.  Platforms-based 
property 
(2021): 
https:/www.propertyresearchtrust.org/short_term_rentals.html;  and  Oxford  Research.  “Study  on  national 
regulatory  approaches  to  short-term  accommodation  services”  -  European  Commission,  Luxembourg 
(2021) (upcoming). 
286 The  term ‘registration procedure’ is used  without prejudice as to whether such procedures consist in 
declaratory systems or authorisations. 

European 

debates 

Cities: 

policy 

the 

in 

200 

 
 
 
 
 
 
                                                           
Among Member States where registration systems are in place (22), these vary in scope, 
procedures (e.g., online or offline), requirements (e.g., information  to  be submitted by 
the hosts) and enforcement mechanisms, including the level of cooperation required by 
platforms.  In some cases registration procedures  are implemented at  the national  level 
(e.g.,  Greece),  in  other  cases  at  the  regional  (e.g.,  Spain)  or  local  level  (e.g.,  France). 
However, it is worth noting that there also are commonalities as well. These cover, for 
example, some key information that is requested from the hosts.287 

In an attempt to streamline the information gathered, the table below summarises their 
main features of national legislation: 

Member State 

Registration procedures 

Cooperation of platforms 

Austria 

procedures 

Registration 
are 
regulated  at  regional  level,  and 
can  be  applied  at  regional  or 
local level.288 

Depends  on  local  requirements.  In  Vienna, 
platforms were requested to remove illegal 
STR identified by authorities and located in 
municipal  (social)  housing  to  platforms.  In 
addition,  in  Vienna  platforms  are  required 
to report  details of all bookings (provider’s 
name  and  addresses  of  rented  units)  each 
month  to  the  City’s  tax  authorities,  or  to 
collect and remit the tourist tax. 

Depends  on  local  regulations.  In  Brussels 
the  registration  number must  be  displayed 
by platforms on all listings.  

Belgium 

Bulgaria 

Croatia 

procedures 

Registration 
are 
regulated  at  the  regional  level. 
There  are  procedures  in  place  in 
Flanders 
and 
and  Wallonia 
requirements in Brussels.289 

There  is  a  procedure  in  place  at 
national level. 

n.a. 

n.a. 

a 

has 

Croatia 
registration 
procedure  through  the  eVisitor 
system,  which  is  mandatory  for 
all  commercial  tourist  service 
providers (for tax purposes).290  

287 For an overview of the typologies of registration schemes in EU Member States, see Oxford Research 
“Study  on  national  regulatory  approaches  to  short-term  accommodation  services”  -  European 
Commission, Luxembourg (2021) (upcoming) 
288 See, e.g., Salzburg e-government process. 
289 See registration procedure in: Flanders, Wallonia and requirements applicable in Brussels.  
290 See https://gov.hr/en/tourist-registration-and-deregistration/1432.  

201 

 
 
 
                                                           
Cyprus 

Czechia 

Denmark 

France 

There  is  a  procedure  in  place  at 
national level.291 

n.a. 

for 

The  Trade  Licensing  Act  sets 
certain 
the 
requirements 
provision  of  STR  services  when 
this is a professional activity. The 
but 
system 
registration  is  conducted  at  the 
local registry office.292 

national 

is 

National  law  requires  platforms  to  share 
host and booking data with municipal trade 
licensing  office.  Arrangements 
for  the 
transfer of  data  have  been  concluded  with 
Airbnb for the purpose of VAT  and income 
tax collection.  

There is currently no registration 
procedure 
in 
for 
Denmark.293  

hosts 

in  place  between 
is 
A  tax  agreement 
platforms  and  the  tax  authority  that 
facilitates  sharing  of  information  needed 
for tax reporting and compliance.294 

National  law  allows  cities  with  a 
certain  minimum  population  to 
registration 
put 
scheme.295 

in  place  a 

Where  a  registration  scheme  applies, 
platforms  are  required  i.a.  to  inform  hosts 
about  their  legal  obligations,  ensure  that 
listings have a registration number and that 
legal  120-night 
hosts  comply  with  the 
annual 
listed 
when 
cap, 
accommodation is the primary residence of 
the host. In French cities where registration 
in  place,  all  platforms  must 
system 
transmit 
government 
to 
information  on  units  rented  the  previous 
year,  the  registration  number,  and  the 
number of nights rented out (together with 
the income earned).  

city 

the 

the 

is 

Germany 

Registration  procedures  apply  at 
local 
Federal  State 

level  and 

Depends on local regulations (e.g., in Berlin 
publish 
platforms 

required 

are 

to 

291 See 
https://www.tourism.gov.cy/tourism/tourism.nsf/application11_en/application11_en?OpenForm.  
292 See, in relevant part, the Trade Licensing Act 455/1991 Coll.: §17(4) and the Business  license  registry. 
Act 189/2020 Coll. amending Act 159/1999 Coll., on the Performance of Certain Activities in the Field of 
Tourism requires platforms to share  host and booking data  with  municipal trade licensing office. There 
have been proposals to update this legislation.  
293 Instead, in Denmark there is an authorisation scheme for professionals only. See the Holiday Home 
Act (Sommerhusloven) https://www.retsinformation.dk/eli/lta/2007/785.  
294 See the official notification of the Tax Agreement: https://www.skm.dk/aktuelt/presse-
nyheder/pressemeddelelser/historisk-aftale-med-airbnb-traeder-i-kraft-fra-1-juli-2019/  
295 See: the national decree on registration; the National Tourism Code (relevant article on the registration 
number here); the Law 2016-1321 (République Numérique), which allows cities over 200,000 inhabitants 
to set up registration system for STR and require STR platforms to include registration number in listings; 
and  Law  2018-1021  (ELAN  Evolution  du  Logement,  de  l’Aménagement  et  du  Numérique)  which, 
together with Law 2019-1461 (Engagement et Proximité) require platforms to share list of individualized 
STR  with  city  governments  where  registration  system  is  in  place  (the  system  was  clarified  in  Decree 
2020-1479) 

202 

 
 
 
                                                           
Greece 

Hungary298 

Ireland 

Italy 

registration number on every listing). 

National  law  requires  that  the  registration 
number  be  displayed  on  the  platform’s 
website.  In  addition,  a  Memorandum  of 
Understanding  was  concluded  with  three 
platforms 
collaborative 
enforcement approach. 

setting 

a 

There is a planned obligation to display the 
registration number by platforms. 

law 
lettings 

requires 
level.  National 
short-term 
be 
to 
declared  to  the  Regional  Trade 
Office. 296 

In  Greece  a  national  registration 
scheme applies.297 

A 
is 
registration  procedure 
established  at  national  level  but 
is  applied  locally.  Providers  of 
accommodations  must  register 
and  report  their  hosting  activity 
through  the  National  Tourism 
Data  Centre  (NTAK)  operated  by 
the  Hungarian  Tourism  Agency. 
Additionally,  hosts  in  Budapest 
have to notify local districts. 

National  law  requires  hosts  to 
register  with 
local 
authority.299  

their 

No. 

procedures 

Registration 
are 
regulated  and  implemented  at 
regional  and  in  one  case  at  the 
local 300 level.  In  2019,  national 
legislation  introduced  a  national 
database for the identification of 
tourist rentals.301 

In  addition,  national 

Regional 
Identification  Code  must  be 
displayed  on  all  listings  (e.g.,  in  Milan  and 
Rome). 
legislation 
required platforms to communicate data on 
non-professional  hosts  and  their  activities 
to  national 
to 
automatically  deduct  (and  transmit)  a  21% 
flat  tax  on  the  rental  income  generated. 
The legislation was challenged and the case 
has been referred to the CJEU. Agreements 
have  been put  in place in Milan and Rome 
with Airbnb for tax collection purposes. 

tax  authorities,  and 

296 See, e.g., registration scheme in Hamburg. 
297 See Law no. 4446/2016. See also link to national registration website. 
298 See National Tourism Data Centre.  
299 See regulations of Dublin City Council. 
300 The Autonomous Province of Trento. 
301 See  i.a.,  Decree  50/2017,  on  the  fiscal  regimes  for  ‘tourism  rental’  (allowing  21%  flat  tax);  Decree 
34/2019, on the establishment of a  national  database of accommodation  facilities and STR; and Decree 
161/2021, providing details on the content of the database and modalities of implementation. 

203 

 
 
 
                                                           
Latvia 

Lithuania 

There  is a registration procedure 
for tax purposes 

No. 

There  is a registration procedure 
for tax purposes. 

Agreement  over  automated  tourist  tax 
collection through Airbnb in Vilnius. 

Luxembourg 

There  is a registration procedure 
established at national level.302 

n.a. 

Malta  

There  is a registration procedure 
established at national level. 

n.a. 

The Netherlands 

There  is  a  national  registration 
system 
for 
with 
municipalities.303 

opt-in 

Platforms  are  required  to  only  advertise 
properties with a registration number. 

Poland 

Portugal 

Romania  

Slovakia 

No. 

There  is a registration procedure 
at  the  municipal  and  regional 
level.  A  number  of  cities  have 
local/regional 
introduced 
registration schemes.304 

There  is  a  national  registration 
(also  applicable  to 
procedure 
Madeira)  implemented  locally.  A 
specific 
system 
registration 
applies for the Azores region.305 

Platforms 
registration numbers. 

are 

required 

to 

display 

A proposal for the establishment 
of a national registration scheme 
appears to be in preparation. 

n.a. 

There  is  a  national  registration 
scheme 
licence 
(business 
registration  procedure)  which  is 
implemented locally.  

n.a. 

Slovenia  

There  is a registration procedure 
for  “subjects  letting  out  rooms” 

n.a. 

302 See  administrative guide  for  registration:  Putting  furnished  residential  property  up  for  short-term 
rental — Citizens — Guichet.lu - Administrative Guide - Luxembourg (public.lu). 
303 See Housing Act 2014 (Huisvestingswet) and the Tourist Rental of Residential Space’ Act 2020 (Wet 
toeristische verhuur van  woonruimte), amending Housing Act and Municipalities Act. At the  municipal 
level see Amsterdam Housing Regulations 2020 (Huisvestingsverordening Amsterdam). 
304 See e.g., Krakow registry: Usługi  (Procedury)-  Biuletyn  Informacji  Publicznej  Miasta  Krakowa  -  BIP 
MK. 
305 Relevant national law includes: Law 39/2008, modified by Law 128/2014; the Laws 62/2018, 71/2018 
and  262/2020  modify  these  laws  and  provide  more  powers  to  local  governments  to  control  new 
establishments in designated so-called ‘containment areas’. The link to the registration procedure can be 
found here. 

204 

 
 
 
                                                           
Depends on local regulations. For example, 
in  Barcelona  platforms  are  required  to 
inform  hosts  of  local  rules,  to  check  that 
any  proposed  unit  has  a  registration 
number before listing it and to publish this 
number  on  all  listings.  In  addition,  the  city 
Government  of  Barcelona  has  concluded 
agreements with platforms for the removal 
level, 
of 
legislation  required  STR  platforms  to  send 
to  tax  authorities  details  of  all  their 
operations  in  Spain.  In  Madrid,  Regional 
law  does  not  explicitly  make  registration 
number  compulsory  on  listings  advertised 
by platforms  

listings.  At  a  national 

illegal 

Spain 

into  the  Business  Register  of 
Slovenia. 

procedures 

are 
Registration 
established  at  regional  level,  but 
may be implemented locally too. 

205 

 
 
 
 
 
 
ANNEX 9: LITERATURE REVIEW  

Aguilera,  Thomas,  Francesca  Artioli,  and  Claire  Colomb.  "Explaining  the  diversity  of 
policy  responses  to  platform-mediated  short-term  rentals  in  European  cities:  A 
comparison  of  Barcelona,  Paris  and  Milan." Environment  and  Planning  A:  Economy 
and Space 53.7 (2021): 1689-1712. 

Anselmi, Guido, Letizia Chiappini, and Federico Prestileo. "The greedy unicorn: Airbnb 
and  capital  concentration  in  12  European  cities." City,  Culture  and  Society (2021): 
100412. 

Ayouba, Kassoum, et al. "Does Airbnb disrupt the private rental market? An empirical 
analysis  for  French  cities." International  Regional  Science  Review 43.1-2  (2020):  76-
104. 

Barron,  Kyle,  Edward  Kung,  and  Davide  Proserpio.  "The  effect  of  home-sharing  on 
house prices and rents: Evidence from Airbnb." Marketing Science 40.1 (2021): 23-47. 

Bekkerman,  Ron,  et  al.  "The  Effect  of  Short-Term  Rentals  on  Residential 
Investment." Available at SSRN (2021). 

Brezina,  Vilim,  Jan  Polívka,  and  Martin  Stark.  "Conditions  for  the  Introduction  of 
Regulation for Short-Term Rentals." Critical Housing Analysis 8.1 (2021): 159-170. 

Broocks, A., Duch-Brown, N. and Reggiani, C. (forthcoming) Assessing the impact of 
online  travel  agencies  on  hotels  and  travellers.  JRC  Digital  Economy  Working  Paper 
Casamatta, Georges, et al. "Host type and pricing on Airbnb: Seasonality and perceived 
market power." Tourism Management 88 (2022): 104433. 

Chen,  Yuanyuan,  Yuxin  Huang,  and  Chuan  Hoo  Tan.  "Short-term  rental  and  its 
regulations  on  the  home-sharing  platform." Information  &  Management 58.3  (2021): 
103322. 

Code  of  Conductola-Gant,  Agustín,  et  al.  "Corporate  hosts:  The  rise  of  professional 
management  in  the  short-term  rental  industry." Tourism  Management  Perspectives 40 
(2021): 100879. 

Code of Conductola-Gant, Agustin, et al.  "Short-term rentals as a new urban frontier–
evidence  from  European  cities." Environment  and  Planning  A:  Economy  and 
Space 53.7 (2021): 1601-1608. 

Colomb,  C.  and  Moreira  de  Souza,  T.  Regulating  short-term  rentals.  Platform-based 
property  rentals  in  European  cities:  the  policy  debates. London:  Property  Research 
Trust (2021) DOI: https://doi.org/10.52915/KKKD3578  

Cox,  Murray,  and  Kenneth  Haar.  "Platform  Failures.  How  short-term  rental  platforms 
like  Airbnb  fail  to  cooperate  with  cities  and  the  need  for  strong  regulations  to  protect 
housing" (2020). 

206 

 
 
 
 
Cunha,  António  Manuel,  and  Júlio  Lobão.  "The  effects  of  tourism  on  housing  prices: 
applying 
Portuguese 
the 
market." International Journal of Housing Markets and Analysis (2021). 

difference-in-differences  methodology 

to 

a 

Demunter,  Christophe.  "Tourism  statistics:  early  adopters  of  big  data." Luxembourg: 
EUROSTAT (2017). 

Dinatale, Sadie. "Assessing and Responding to Short-Term Rentals in Oregon: Enabling 
the Benefits of the Sharing Economy." (2017). 

Duch-Brown,  N.  (Coord.),  The  Short-Term  Accommodation  Rentals  market  in  the  EU,  JRC 
Digital Economy Working Paper 2021-09 

Duch-Brown, N., Pogorzelska, K. and Rodriguez de las Heras Balell, T. (forthcoming), 
The cost of legal fragmentation among EU Member States in the implementation of the 
E-commerce directive. JRC Digital Economy Working Paper. 

Farronato,  Chiara,  and  Andrey  Fradkin. The  welfare  effects  of  peer  entry  in  the 
accommodation market: The case of airbnb. No. w24361. National Bureau of Economic 
Research, 2018. 

Garcia-López,  Miquel-Àngel,  et  al.  "Do  short-term  rental  platforms  affect  housing 
markets?  Evidence  from  Airbnb  in  Barcelona." Journal  of  Urban  Economics 119 
(2020): 103278. 

Garcia-López,  Miquel-Àngel,  Rosella  Nicolini,  and  José  Luis  Roig  Sabaté.  "Urban 
Spatial Structure in Barcelona (1902–2011): Immigration, Spatial Segregation and New 
Centrality Governance." Applied Spatial Analysis and Policy 14.3 (2021): 591-629. 

Giannoni, Sauveur, et al. "Multichannel distribution strategy of Airbnb hosts." Annals of 
Tourism Research Empirical Insights 2.1 (2021): 100017. 

Hati, Sri Rahayu Hijrah, et al. "A decade of systematic literature review on Airbnb: the 
sharing economy from a multiple stakeholder perspective." Heliyon (2021): e08222. 

Hausemer, Pierre, et al. "Exploratory Study of consumer issues in peer-to-peer platform 
markets." European Commission, Luxembourg (2017). 

Heo, Cindy Yoonjoung, Inès Blal, and Miju Choi. "What is happening in Paris? Airbnb, 
hotels, and the Parisian market: A case study." Tourism Management 70 (2019): 78-88. 

Horn,  Keren,  and  Mark  Merante.  "Is  home  sharing  driving  up  rents?  Evidence  from 
Airbnb in Boston." Journal of Housing Economics 38 (2017): 14-24. 

Huang,  Yuxin,  Yuanyuan  Chen,  and  Chuan  Hoo  Tan.  "Regulating  new  digital  market 
and its effects on the incumbent market: Investigation of online peer-to-peer short-term 
rental." Information & Management 58.8 (2021): 103544. 

Katsinas,  Philipp.  "Professionalisation  of  short-term  rentals  and  emergent  tourism 
gentrification in post-crisis Thessaloniki." Environment and Planning A: Economy and 
Space (2021): 0308518X21988940. 

207 

 
 
 
Koster, Hans RA, Jos van Ommeren, and Nicolas Volkhausen. "Short-term rentals and 
the  housing  market:  Quasi-experimental 
in  Los 
Angeles." Journal of Urban Economics 124 (2021): 103356. 

from  Airbnb 

evidence 

Martinez,  Yolanda  (Marimón  Avocados),  Memorandum  for  UA  EU  C&CH  2021 
“Regulatory  Enforcement  Difficulties  In  The  Short-Term  Rental  Accommodation 
Sector  Stemming  From  The  European  Legal  Framework  For  Digital  Services”  to  be 
published at URBACT https://right2housing.eu. 

Powel,  Dyfan,  et  al.  "Research  to  Develop  an  Evidence  Base  on  Second  Homes." 
(2021). 

Rossi, Michelangelo. "Competition and Reputation in a Congested Marketplace: Theory 
and Evidence from Airbnb." (2021). 

Sanford,  Will,  Dillon  DuBois.  “COVID-19  impact  on  hotels  and  short-term  rentals.” 
AIRDNA (2020). 

Stocker,  Volker,  et  al.  "Navigating  the  Landscape  of  the  Sharing  and  Gig  Economy 
Literature: A Systematic and Interdisciplinary Review." Available at SSRN (2021). 

Tortelli,  Alessandro,  Gianfranco  Lorenzo,  Roberto  Gambassi  and  Sandro  Billi. 
“Recommendations and proposals for an in-depth analysis of tourism flows of an urban 
reality  for  a  better  governance  of  the  destination.”  Urban  Agenda  for  the  EU 
Partnership on Culture/Cultural Heritage (2021). 

Trouillard,  Emmanuel.  “Les  Locations  Saisonnières  en  Ile-De-France.  Etat  des  Lieux 
d’Avant-Crise." L’institut Paris Region (2021). 

Vaccari,  L.,  Posada  Sanchez,  M.,  Boyd,  M.,  Gattwinkel,  D.,  Mavridis,  D.,  Smith,  R., 
Santoro, M., Nativi, S., Medjaoui, M., Reusa, I., Switzer, S. and Friis-Christensen, A., 
Application Programming Interfaces in Governments: Why, what and how, EUR 30227 
EN, Publications Office of the European Union, Luxembourg, 2020, ISBN 978-92-76-
18982-4 
doi:10.2760/58129 
(online),978-92-76-18981-7 
(online),10.2760/429805 (print), JRC120429. 

(print), 

Van  Haaren,  Jeroen,  and  Susan  Vermeulen,  Jeroen  Klijs,  Ko  Koens,  and  Jorrit  Bijl. 
“Short-term  accommodation  rental  in  Amsterdam.  An  empirical  investigation  of 
statistical  correlations  between  short-term  rental,  housing  prices  and  quality  of  life 
index.” European Commission, Luxembourg (2021). 

Wachsmuth,  David,  and  Alexander  Weisler.  "Airbnb  and  the  rent  gap:  Gentrification 
through the sharing economy." Environment and Planning A: Economy and Space 50.6 
(2018): 1147-1170. 

Zervas,  Georgios,  Davide  Proserpio,  and  John  W.  Byers.  "The  rise  of  the  sharing 
economy: Estimating the impact of Airbnb on the hotel industry." Journal of marketing 
research 54.5 (2017): 687-705. 

208