Link to the European Commission call
Link to STR-Belgium’s contribution
STR-Belgium is a non-profit association that defends the interests of private individuals and professionals operating non-hotel tourist accommodations in Belgium, and tourism residences in particular.
STR-Belgium welcomes the initiative of the European Commission to establish a European plan for affordable housing. STR-Belgium hopes that this plan will provide structural and sustainable solutions to the acute crisis of reasonably priced housing, particularly pronounced in cities across the Union.
It must be acknowledged that many cities and regions need stronger governance in defining their housing policies. While it is evident that, for electoral and/or opportunistic reasons — sometimes also linked to hotel lobbies — certain politicians prefer to forcibly halt short-term rental activities (by sealing properties), even when these are operated by “best-in-class” actors, one may question the real impact of such actions beyond the intended media and sensational effect.
The example of the Brussels-Capital Region, which also hosts the capital of Europe and should therefore set the right example, is quite revealing: with 475,619 dwellings in the Region (Statbel data – 2020) and approximately 4,975 non-hotel tourist accommodation units on average over the 2022–2024 period (including tourism residences rented all or part of the year and rooms in private homes – visit.brussels data), it appears that dwellings used for short-term rental represent, at most, only 1.05% of the Region’s housing stock. However, some politicians, without much scientific justification, claim that such short-term rentals account for 30% in certain tourist neighbourhoods. Beyond validating this figure, it would also be useful for these same politicians to reasonably define acceptable ratios on a neighbourhood-by-neighbourhood basis. Indeed, while the desire to spread tourism across cities is understandable, it may nevertheless be reasonable for certain areas to have a higher concentration of tourist accommodation than others.
Today, unfortunately, the caretaker government has made the unreasonable choice — in total contradiction with the evolving travel preferences of citizens worldwide (see Eurostat figures) — to define a ratio of approximately “zero” across the territory of all 19 municipalities of the Region, without any distinction. This leads to a 95–98% underground market, with only 96 registered tourism residences according to 2022 figures from Brussels Economy and Employment. This situation is catastrophic for all categories of tourist accommodation. It appears that the outgoing Government of the Brussels-Capital Region is stalling and eagerly awaiting the entry into force in May 2026 of the EU regulation on short-term rentals: at that point, the predominantly underground market would be wiped out, drastically reducing the alternative and complementary supply to traditional hotels that short-term rentals represent — yet which is essential for cities aiming at a competitive, innovative, and sustainable tourism market, benefiting global citizens, whether tourists, residents, or economic actors.
The real questions will then be: what will be the actual impact in Brussels of eliminating these 5,000 short-term rentals on the housing issue? What will be the impact on urban economic dynamics (STR operators and related services, restaurant and bar attendance, etc.)? And what will be the impact on consumers (tourists), including hotel room prices? It is indeed essential not to examine such a complex societal issue without a minimum level of critical thinking — and to respect the sequence: data first… then justified, proportionate, and non-discriminatory decisions.
Although we are fully aware that the purpose of this call for contributions is not to argue the added value of short-term rentals, it is nevertheless imperative for us to react as an association defending a sector that is being threatened and wrongly portrayed as a scapegoat for the structural housing problem.
We would therefore like to draw attention to several points at the intersection between permanent housing and short-term rentals that must be taken into account in defining this European affordable housing plan:
The two key solutions for successfully integrating short-term rentals quantitatively and qualitatively in cities or rural areas are clearly identified:
• Quality labels to ensure the social integration of short-term rentals within neighbourhoods. Note that, unlike quotas, these labels should apply to all types of short-term rentals except home-sharing (primary residence). Indeed, why should a resident renting out their entire primary residence for up to 120 days per year be allowed to disturb neighbours more than any other operator?
We insist that housing issues in the Union and the solutions provided should be defined at a systemic level with rigorous multi-criteria analysis, in compliance with EU rules, particularly the Services Directive. It appears that we are far from this situation in the Brussels-Capital Region, since:
• we cannot find any serious study on housing issues identifying the suppression of short-term rentals as a structural solution. On the contrary, we refer to the OECD study, which proposes concrete structural solutions to be implemented, including the following excerpt:
“The report does not overlook the strategic efforts implemented over the past two decades to improve the situation, notably ‘incentives for the private sector to build more affordable housing’. However, it highlights numerous obstacles such as insufficient funding and the complexity of obtaining planning permits. Its recommendations to curb the crisis rely on one mantra: increase the supply of affordable housing where it is needed. This includes revising and streamlining permit policies, supporting production through more flexible planning and zoning rules, and extending tax incentives from public actors to motivated investors and developers. Finally, the OECD suggests offering municipalities greater flexibility to build, for example, more and higher buildings in exchange for more social housing, introducing rent regulation, and achieving a more balanced distribution of public housing across the Region.”
(OECD Territorial Reviews: Brussels-Capital Region, Belgium; Le Soir, 6 February 2024)
Last but not least, STR-Belgium advocates:
• the impartial involvement of the academic community to clearly and unambiguously define neighbourhood-based quota mechanisms, taking into account the multi-dimensional impacts mentioned above (housing, direct and indirect economic effects, etc.).
