Link to STR-Belgium’s contribution
STR-Belgium is a not-for-profit association that defends the interests of private individuals and professional operators of non-hotel tourist accommodation in Belgium, and of vacation rentals in particular.
STR-Belgium welcomes the European Commission’s initiative to set up a European plan for affordable housing. STR-Belgium hopes that this plan will provide structural and lasting solutions to the acute crisis in affordable housing, which is particularly severe in the EU’s cities.
It should be noted that many towns and regions need governance in defining their housing policy. While it is quite clear that some politicians, for electoral reasons in relation to a low-income population or for opportunistic reasons in relation to hotel lobbies, prefer to forcibly stop the operation of short-term rentals (sealing them off), even when these are operated by ‘best of the class’ players, we can wonder about the real effect of these actions, apart from the media and sensational effect sought.
The example of the Brussels-Capital Region, where the capital of Europe is located and which should be setting a good example, is quite revealing: with 475,619 dwellings in the Region (Statbel data – 2020), and a number of non-hotel tourist accommodations of around 4,975 units on average over the period 2022-2024 (including vacation rentals rented out all or part of the year and rooms in private homes – visit.brussels data), we can see that dwellings used for short-term rental would represent, at the upper limit, only 1.05% of the Region’s housing stock. However, some politicians, without much scientific justification, have announced that short-term rental accommodation accounts for 30% in certain tourist areas of cities. As well as validating this figure, it would also be interesting if these same politicians could reasonably define the acceptable ratios for each district. Even if the desire to spread tourism in cities is understandable, it could still be understandable that there is a greater concentration of accommodation rented out to tourists than in other areas. Today, and unfortunately, the outgoing government has made the unreasonable choice, in total contradiction with the evolution of travel preferences of the citizens of the world (cfr Eurostat figures), to define the ratio ‘~ 0’ on the territory of the 19 communes of the Region, without any distinction. This leads to a 95-98% illegal market, with 96 vacation rentals registered according to 2022 figures from Brussels-Economy and Employment. And this situation is catastrophic for all categories of tourist accommodations. It seems that the outgoing Government of the Brussels-Capital Region is playing for time and impatiently awaiting the entry into force in May 2026 of the draft regulation on short-term rental in the European Union: at that point, the majority of the underground market would be wiped out, reducing to nothing the alternative and complementary offer to the traditional hotel that short-term rental represents, which is so essential to cities in the perspective of a competitive, innovative and sustainable tourist market, for the benefit of the citizens of the world, whether they are tourists, residents or economic players. So the real questions will be: what will be the real impact of abolishing these 5,000 short-term lets on the housing problem? And what will be the impact on the economic dynamism of cities (STR operators and associated STR-services, frequentation restaurants and bars, …) ? And what will be the impact for consumers (tourists) – ie evolution of the hotel rooms prices ? It is essential not to examine this complex social problem without a minimum of critical thinking. And we need to follow the sequence: data … then decisions that are justified, proportionate and non-discriminatory!
While we are well aware that the purpose of this call for contributions is not to argue the case for the added value of short-term rental, it is nonetheless imperative for us to react as an association defending a sector that is under threat and being singled out as the scapegoat for the structural housing problem – wrongly so!
We would like to draw your attention to a few points on the borderline between the themes of permanent housing and short-term rental, which must be taken into account in the definition of this European plan for affordable housing:
The 2 key solutions for the successful quantitative and qualitative integration of short-term rental in towns and rural areas have been clearly identified:
- Quotas on a neighbourhood-by-neighbourhood basis, expressed as a percentage, and dynamic. This requires the authorities to have detailed data for urban planning purposes. This is far from being the case in Brussels, since the PRAS (Plan Régional d’Affectation du Sol – Regional Land Use Plan) does not take into account the granularity of the different types of tourist accommodation (everything is referred to as ‘hotel establishments’ and we have defended our request for revision to perspective.brussels without much success to date). It should be noted that this quota mechanism makes no sense in terms of the primary residence, as it provides no solution to the housing problem.
- Labels to successfully integrate short-term rentals into neighbourhoods. Unlike quotas, these labels should be implemented for all types of short-term rental (with the exception of shared accommodations in primary residences) : why should a person renting out their home (main residence) in its entirety for up to 120 days a year would have the right to disturb the neighbourhood more than another party?
We insist that the problem of housing in the Union and the solutions found should be defined at a systemic level with a rigorous multi-criteria analysis, and in compliance with the rules of the Union, in particular the Services Directive. It seems that we are a long way from achieving this in the Brussels-Capital Region, since :
- decisions taken by the outgoing Regional Government are allegedly ‘justified’ even though the academic world itself is complaining about the lack of data: ‘There’s no data’ … ‘The fog is total’ … It can’t go the other way, because we’re taking away housing’ … ’… It’s just that when it comes to quantifying the impact, we’ll have to go back to the drawing board, given the paucity of data’. The fundamentally divergent figures (4,500 vs. 20,000) put forward by Brussels politicians on abandoned/unoccupied housing are a good illustration of this lack of data, and of the intentional use that could be made of it – L’Echo of 24th November 2024 – Le Soir of 26th February 2024 vs La Capitale of 3rd December 2023
- We cannot find a serious study on the housing problem that points to the abolition of short-term rentals as a structural solution to this problem. On the other hand, we refer to the OECD study that puts forward concrete structural solutions to be implemented, of which the following is an extract: ” The report does not shirk from the strategic efforts made over the past two decades to improve the situation, including ‘incentives for the private sector to build more affordable housing’. But it also points to a number of obstacles, such as the continuing lack of funding and the complexity of issuing planning permission. His recommendations for stemming the crisis are based on one mantra: increase the supply of affordable housing where it is needed. By reviewing and streamlining the policy for granting permits. Or supporting production by making planning and urban development rules more flexible, and extending public-sector tax breaks to motivated investors and developers. Finally, the OECD suggests offering municipalities greater flexibility to build more and higher, for example, in exchange for more social housing, the introduction of rent price regulation and a more even distribution of public housing supply across the region.” (OECD Territorial Reviews: Brussels-Capital Region, Belgium et Le Soir of 6 February 2024)
Last but not least, STR-Belgium advocates :
- for a real partnership between politicians, the sector and all the stakeholders, in order to take advantage of the opportunities that exist to meet the objectives of creating (long-term) housing by reallocating derelict buildings, initially for short-term rental, based on win-win business models to be established between the stakeholders. To achieve this, certain politicians must have the courage to change their tune!
- impartial involvement of the academic world in the clear and unambiguous definition of the quota mechanism on a neighbourhood-by-neighbourhood basis, taking into account the multi-dimensional impacts mentioned above (housing, direct and indirect economy, etc.)
