STR-Belgium commends this excellent study by ING Belgium and would like to offer the following comments to inform the deliberations of the new Government of the Brussels-Capital Region as it works to implement a proportionate regulatory framework for the short-term rental industry:
- The populist myth that blames short-term rentals for the housing crisis has been definitively debunked.
Selected excerpts:
“Stronger regulations and better data sharing regarding short-term rentals could help bring back some of the housing units that have been taken off the traditional residential market, but the impact will remain limited and will only marginally ease the housing shortage.
The issue of housing affordability stems primarily from a persistent shortage of suitable housing supply, which does not adequately respond to demographic changes and is hampered by rising construction costs, lower production levels, and an overly restrictive regulatory framework. Consequently, the main challenge for public authorities is to increase the supply of affordable housing, particularly by better aligning it with the growing demand for small housing units and by ensuring a stable investment framework to support construction and renovation projects.
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In conclusion, housing affordability will therefore depend on the supply’s ability to adapt to demand. This involves, in particular, streamlining permit approval processes and promoting projects that place greater emphasis on smaller housing units, such as apartments. At the same time, a stable and predictable investment framework is needed to support construction and renovation decisions, so that projects can continue to be carried out despite an environment of higher costs and higher interest rates.
Finally, it is essential that strengthened standards for housing quality and energy efficiency be part of a coherent framework, with adequate support and realistic transition periods, in order to prevent an accelerated withdrawal of housing from the rental market. This will help reduce the gap between supply and demand and contribute to greater affordability and greater fluidity in the housing market.”
Of course, some will resort to the facile argument that short-term rentals are exacerbating the housing crisis. STR-Belgium emphasizes that this is a simplistic argument because, with a single-criterion approach, one could argue that any short-term rental that is not in a primary residence is one too many. Beyond precisely quantifying the impact (see below), it is important to weigh the economic benefits of this activity against its costs in order to define proportionate regulatory policies. Opting for a single-criterion approach for populist reasons is a bit like deciding to ban cars because they can cause serious accidents.
- The concept of the “illegality” of short-term rentals must be assessed with the usual caution, especially in light of the Opinion of the Advocate General of the Court of Justice of the European Union dated February 5, 2026.
As a reminder, the Opinion of the Advocate General of the CJEU in the Smartflats case is decisive regarding the illegality of the Brussels regime (order of May 8, 2014, and, by extension, the new order of February 1, 2024) under the European Union Services Directive. It is important to reiterate this fact and to await the judgment of the Court of Justice of the European Union before addressing the issue of inspections and the implementation of regulations that are potentially illegal by their very nature. The short-term rental sector, just like the hotel lobbies, is calling for a “level playing field.” How could this be the case with Brussels regulations that, in practice, effectively ban the professional activity of short-term rentals—without any nuance and in a completely disproportionate manner—across all neighborhoods of the 19 municipalities in the Brussels-Capital Region, and moreover without any economic impact assessment (see below)? Could it be that the Vervoort governments have, for opportunistic reasons, attempted to (give the appearance of) protecting the hotel sector, to the detriment of the public interest? With 95% of the market having been “illegal” from 2014 to the present, one is justified in remaining perplexed about the true objectives pursued by these outgoing governments.
- Data transparency is essential for developing proportionate regulatory policies in the medium term. This will require a series of iterations.
It is clear that European Regulation 2024/1028 of April 11, 2024—which (theoretically) entered into force on May 20, 2026, and will not take effect until the coming months—represents a major step forward toward transparency in the short-term rental industry and is an essential pillar for building proportionate regulatory frameworks for the future. However, this European regulation is not intended to legitimize disproportionate—or even potentially illegal—regulatory frameworks under European Union law. Let’s imagine for just a moment how it would be applied as is in the Brussels-Capital Region. Who, apart from certain hotel lobbies, would dream of such a scenario—one in which a service so widely embraced by citizens around the world is whittled down to almost nothing? And who would bear the economic consequences, given that citizens around the world will have every opportunity to turn away with a single click from destinations whose offerings fail to meet their expectations, whether in terms of diversity or price?
At a time when certain populists are perpetuating a blurred distinction between causation and correlation regarding real estate prices (sales prices and rents) in relation to short-term rental activity (see the Oxera study), an in-depth analysis of actual market data will make it possible to gradually develop—through comparisons and successive approaches—proportionate regulatory models tailored to the distinct characteristics of different regions (cities, rural areas, coastal regions, etc.). The European Union, through its “Affordable Housing Act” initiative, will soon seek to consolidate these efforts with proposals designed to ensure proportionality, particularly by avoiding drastic measures whose effects could be devastating, as is currently the case in the Basque Country.
- Last but not least, it is urgent and essential to conduct studies that focus on the economic impact of short-term rentals
The ING Belgium study touches on the subject indirectly without delving into it:
“In recent years, online booking platforms have rapidly gained prominence among both travelers and property owners. In 2024, according to Statbel data, 1,232,000 stays were booked in Belgium through these platforms, representing 12,280,000 overnight stays. This corresponds to an 11% increase in the number of overnight stays compared to 2023, and the highest level of stays and overnight stays in private accommodations since records began. This strong growth continued in 2025. In the first three quarters, the 10-million-overnight-stay mark had already been surpassed, representing a 10% increase compared to the same period a year earlier, suggesting that 2025 will once again exceed 2024.”
Given this growing success, it is high time to assess the economic impact of short-term rentals, especially in light of the disproportionate regulatory policies based on the single (and ineffective—see above) criterion of housing protection: creation of direct and indirect jobs, tourist spending in bars, cafes, and restaurants, impact on consumers—prices of tourist accommodations that eat into travelers’ vacation budgets (who have not changed their destinations), …
The new Brussels government could benefit from drawing on the expertise of universities by establishing a systemic framework for this impact analysis. STR-Belgium will, in any case, pay close attention to this issue during the planned discussions aimed at jointly developing a proportionate regulatory framework that ensures a competitive, innovative, and sustainable tourist accommodation market while safeguarding the public interest.
