Data and Studies

Statements
The tourist residence market in the Brussels-Capital Region is 98% illegal!
How, then, can tourist safety be guaranteed, which should be the legislator's top priority? And how, for that matter, can all the other objectives set out in the order of May 8, 2014 be guaranteed under these conditions?
Between 2016 and 2022, a total of 96 tourist residences were registered.
Between 2016 and 2022, a total of 96 tourist residences were registered in the 19 municipalities of the Brussels-Capital Region, in accordance with the ordinance of May 8, 2014. But... there are 4,800 on booking platforms (AllTheRooms figures, 2022)!
Brussels has almost 25 times fewer registered tourist residences than Barcelona.
Let's compare Brussels to Barcelona (Eurostat figures): for a total of 3,763,000 overnight stays in 2019, Barcelona had 9,500 registered tourist residences. And in Brussels? For 921,000 overnight stays in the same year, Brussels has only 96 registered tourist residences... for an equivalent number of overnight stays, Brussels has almost 25 times fewer registered tourist residences than Barcelona... Spot the mistake!
The draft revision of the ordinance of May 8, 2014 aims to increase fines.
The draft revision of the ordinance of May 8, 2014 aims to increase fines. But is it really in Brussels' interest to try to bring the real market (4,800 tourist residences on platforms) into line with the “legal” market (96 registered tourist residences )?
Many European and international citizens will no longer come to Brussels!
“89% of EU citizens who have booked short-term rentals would recommend it to others” . If the Government of the Brussels-Capital Region decides to destroy the sector, tourists will simply change their travel destination with a click of a button. Many citizens of Europe and around the world will no longer come to Brussels!
Fewer tourist residences in the Brussels-Capital Region undoubtedly means fewer visitors and therefore job losses across the entire ecosystem!
Tourist residences—which are booming across Europe—are one of the pillars of the tourism economy, contributing both directly (through income tax and city tax) and indirectly: guests at tourist residences support local businesses, restaurants, and bars! Fewer tourist residences in the Brussels-Capital Region undoubtedly means fewer visitors and therefore job losses across the entire ecosystem!
The Government of the Brussels-Capital Region has chosen to stand out with a procedure... of prohibition!
It is important to distinguish between the different procedures for operating a non-hotel tourist accommodation business: the registration procedure and the authorization procedure. The Government of the Brussels-Capital Region has chosen to stand out with a prohibition procedure! The registration procedure is a simple administrative procedure that allows the owner of a non-hotel tourist accommodation to register their business with the local authorities. This registration is valid for 10 years and is renewed automatically upon request. The registration procedure is open to all owners of non-hotel tourist accommodation.
STR-Belgium questions visit.brussels' stance on tourist residences
STR-Belgium questions visit.brussels' stance on tourist residences and its poor promotion (4 tourist residences on the website vs. 96 registered tourist residences vs. 4,800 on booking platforms): a strange balance between tourists and residents (see the “News” section elsewhere). It must be said that hotels do not suffer the same unfavorable treatment...
The legislator must ensure that regulations are “strictly appropriate” to the specific situation not of the municipality as a whole, but of “each neighborhood.”
The Court of Justice of the European Union (CJEU) emphasized in the Cali Apartments case in Paris (September 2020) that the introduction of an authorization system must be “justified by an overriding reason in the public interest” and must remain proportionate to that objective. In particular, the legislator must ensure that the regulations are “strictly appropriate” to the specific situation not of the municipality as a whole, but of “each neighborhood.”
Non-issuance of urban planning compliance certificates: in line with European law?
The failure to issue a certificate of urban planning compliance for a tourist residence in the Brussels-Capital Region, without considering the specific situation of each neighborhood in each of the 19 municipalities, is likely, based on the above, not in compliance with European law. The failure to issue a certificate of urban planning compliance for a tourist residence in the Brussels-Capital Region, without considering the specific situation of each neighborhood in each of the 19 municipalities, is likely, based on the above, not in compliance with European law.
Politicians must be honest and stop using the tourist accommodation sector as a scapegoat for their inefficiency in housing policy!
Let's put some housing figures into perspective: 475,000 dwellings in the Brussels-Capital Region (Statbel figures). 4,800 tourist residences (see above). Tourist residences represent at most 1% of housing in the Brussels-Capital Region . And even if all tourist residences met social housing criteria, this would only solve 10% of the problem (cf. 50,000 households waiting) by removing all tourist residences from the market, with serious collateral socio-economic consequences: let's stop the simplistic approach! Politicians must be honest and stop using the tourist residence sector as a scapegoat for their inefficiency in housing policy!
Amsterdam was wrong to ban Airbnb-rentals in three areas: court
Amsterdam was wrong to ban Airbnb-rentals in three areas: court : The verdict suggested that instead of a total ban, Amsterdam could first have investigated whether a reduced quota of Airbnb-style rentals would have had an effect, or whether it could have been achieved by withdrawing permits from people whose rentals created nuisance
“Tourist residence” is one of six distinct categories of tourist accommodation as defined by Brussels legislation.
According to the ordinance of May 8, 2014, governing tourist accommodation in the Brussels-Capital Region, “tourist residences” are one of six distinct categories, alongside hotels, aparthotels, private lodgings, youth hostels, and campsites.
A tourist residence is not a “hotel”: in urban planning terms, hotel rooms do not have kitchens and no services are offered by default in a tourist residence.
The PRAS (Regional Land Use Plan), which dates back to 2001 and is now obsolete, needs to be revised as it is not in line with the post-Airbnb world: the categories defined in the ordinance of May 8, 2014 are not included in the PRAS. And no, a tourist residence is not a “hotel”: in urban planning terms, a hotel room does not have a kitchen and no services are offered by default in a tourist residence.
Urban planning policies (e.g., Master Development Plans) must incorporate tourist residences.
Urban planning policies (e.g., Master Development Plans) must include tourist residences in their category of tourist accommodations, as defined in economic policies. This is a prerequisite for the implementation of a quota system for tourist accommodations.
review the division of responsibilities for tourism and land use planning
With the 2024 elections approaching, STR-Belgium strongly encourages Brussels politicians to review the division of powers in the areas of tourism and spatial planning: for the sake of balanced governance, these two areas should not fall under the remit of the same minister within the Government of the Brussels-Capital Region.
The tourist accommodation sector is a sector in its own right and must be recognized as such!
The short-term rental sector is booming and is the subject of a regulatory proposal by the European Commission: tourist residences represent 25% of tourist accommodation in the European Union. The tourist residence sector is a sector in its own right and must be recognized as such!
The Covid crisis has amplified demand for tourist residences:
The Covid crisis has amplified demand for tourist residences: European citizens are embracing tourist residences for the disruptive advantages they offer: space and autonomy!
« Les systèmes d'enregistrement devront être entièrement en ligne et conviviaux. »
“Registration schemes will have to be fully online and user-friendly.” We are still a long way from achieving this goal in the Brussels-Capital Region!
Tourist residences are an alternative and complementary option to hotel rooms.
Tourist residences offer an alternative and complementary option to hotel rooms. And the battle being fought by the hotel sector and the (professional) tourist residence sector is different: one is demanding the right to expand, while the other is simply asking for the right to exist! The battle being fought by the hotel sector and the (professional) tourist residence sector is different: one is demanding the right to expand, while the other is simply asking for the right to exist!
« Same Level Playing Field »
STR-Belgium défend l’idée du « Same Level Playing Field” suggérée par Hotrec  : STR-Belgium est cependant très attentif pour que le « Same Level Playing Field » soit également assuré de façon impartiale par le Gouvernement de la Région de Bruxelles-Capitale dans le processus de validation de la révision de l’ordonnance du 8 mai 2014. A suivre …
The issue of public disturbance caused by tourist residences is an easy populist argument for critics of the sector.
The issue of public disturbance caused by tourist residences is an easy demagogic argument for critics of the sector: there are many solutions available on the market that are already being implemented around the world (smart decibel meters, security services, etc.).
Controlled integration of tourist residences offers numerous opportunities
Controlled integration of tourist residences offers numerous opportunities: creation of housing (when the compensation mechanism is justified), renovation of buildings to current energy performance standards, revitalization of neighborhoods, etc.
Quota mechanisms must be implemented for professionals, neighborhood by neighborhood.
For STR-Belgium, the solution is clear: quota mechanisms must be implemented for professionals, neighborhood by neighborhood, with a clear distinction between categories of tourist accommodation, in particular tourist residences and hotel rooms.
The implementation of quotas is obviously somewhat complex, but it is nevertheless an essential solution in the short term.
The implementation of quotas is obviously somewhat complex, but it is nevertheless an unavoidable solution in the short term. Nor is it a revolutionary idea: recently applied to a disruptive mobility sector (see the quota of 8,000 scooters applied in the Brussels-Capital Region), quotas are also defined to limit the number of hospitality establishments (e.g., PPAS Rue du Marché au Charbon).
The implementation of quotas must be supported by the academic world.
The implementation of quotas must be supported by the academic world, which has a role to play in providing scientific considerations for the process: this is an operational research problem (mathematics—optimization under constraints), and the academic world must guard against relaying political slogans! The implementation of quotas must be supported by the academic world, which has a role to play in providing scientific considerations for the process: this is an operational research problem (mathematics—optimization under constraints), and the academic world must guard against relaying political slogans!
« It is very unfair to say that all of the problems of the housing market are connected to short-term renting”
The problem faced by the tourist accommodation sector is global. Politicians are gradually taking responsibility: “It is very unfair to say that all of the problems of the housing market are connected to short-term renting,” Ricardo Valente, City Councillor for Finance, Economy, and Employment, Porto, Portugal.
“Some political groups and MEPs are trying to diminish the importance of short-term rentals on the entire tourism ecosystem, which in my view is a profound mistake”
“Some political groups and MEPs are trying to diminish the importance of short-term rentals on the entire tourism ecosystem, which in my view is a profound mistake,” Monteiro de Aguiar concluded. Cláudia Monteiro de Aguiar is a centre-right Portuguese MEP and member of the Committee for Transports and Tourism. She was the rapporteur on an “EU strategy for sustainable tourism” in 2021.
Further on, it is demonstrated that tourism does indeed stimulate economic activity.
“This study seriously puts into perspective the so-called ”entrepreneurial exodus," which has been very present in certain discourses in recent years. ... Furthermore, it has been demonstrated that tourism does indeed stimulate economic activity, and I am particularly pleased with this finding, as the development of this sector has long been important to me." Philippe Close, Mayor
The Government of the Brussels-Capital Region must be mindful of the proportionality of the rules it puts in place, which tend to scare entrepreneurs—and rightly so.
The European Commission's regulatory proposal does not aim to empower disproportionate and unjustified rules. The Government of the Brussels-Capital Region must be mindful of the proportionality of the rules it puts in place, which tend to scare off entrepreneurs—and rightly so—in many sectors: for example, tourist residences and co-living.
“All Airbnb rentals are illegal”:
“All Airbnb rentals are illegal”: STR-Belgium calls for a more nuanced approach to the (often opportunistic) discourse of critics of tourist residences. It is indeed necessary to consider the full range of illegal activities on the Brussels black market: from operators who should be banned from the market, acting in total illegality (no safety certificate (possibly simplified) for the accommodation, no income declaration, no payment of city tax, , etc.) to those, often members of STR-Belgium, who are only missing the certificate of urban planning compliance ...
Find out how the European Union plans to regulate short-term rentals
Find out how the European Union plans to regulate short-term rentals in this fascinating report by euronews.next. STR-Belgium fully supports this European Union initiative and reviews the key points of this report in the news section of the website.

Studies

Impact of short-term rentals in France

A study by Strategy&, part of the PwC network

This study identifies the factors that have led to the housing crisis in France and assesses the impact of short-term rentals (Locations Meublées de Tourisme – LMT). It highlights the overall imbalance between supply and demand for housing over the past 15 years. The highest ever housing prices combined with the lowest purchasing power for real estate (cf. interest rates on loans) and strong regulatory constraints (e.g., environmental standards) are the main causes of tension in the housing market. It is important to note that the analysis is carried out by type of territory (coastal, mountain, rural, large cities); The weight of LMTs is analyzed and does not exceed 0.2% of the housing stock in France in 2022 (0.4% in large cities). Another important parameter is highlighted: dedicated LMTs (by professionals) represent only 8% of the total LMT stock.

The needs that LMTs meet are highlighted (hotel undercapacity, tourist consumption habits, network of supply in the absence of hotels – LMTs are present in more than 29,000 municipalities in France).

Contrary to popular belief, vacant (abandoned/unoccupied) housing in France weighs 41 times more than dedicated short-term rentals (this factor is still 15 in Paris!), so their impact must be put into perspective!

The study recommends increasing the construction of new housing.

 

 

October 2024

Document

Regulating Short-Term Rentals: Towards Data-Driven Policymaking?

A study by Christoph Busch for eu travel tech This highly interesting study is educational and helps us understand the ecosystem of the short-term rental market. The author proposes a “corridor of solutions” for market regulation that complies with proportionality rules. In particular, the proportionality criteria for “authorization” procedures (cf. those applied by the Government of the Brussels-Capital Region) are discussed in section 4 of this study. The importance of objectification through figures to justify any restrictive policy under European law is emphasized. Finally, access to the market for all types of economic actors must be ensured in an impartial manner, and the outlines of a distinction between individuals and professionals are drawn, with the hope that the new European regulation will simplify this exercise with the transparency of data it will provide.
Document

Assessment of the May 8, 2014 ordinance on tourist accommodation

Selected excerpts:

§ 3.1.3. A marked contrast between supply and demand (pg.10)
While the rise of online booking platforms has led to an increase in the number of tourist accommodation establishments and sustained growth in the sector's capacity, it has not yet challenged the very high concentration of overnight stays in the more traditional segments of the market.

§ 3.1.4. A high spatial concentration of supply (pg. 13) The concentration of short-term furnished rentals
in the tourist hypercenter is coupled with an
expansion into adjacent neighborhoods with few hotels and tourist facilities, and even into peripheral areas located away from tourist routes.

§ 4.2. Massive under-reporting compared to the real market (pg. 16)

§ 4.4. Urban planning compliance subject to interpretation (pg. 17)
In this light, making an economic authorization (the operation of tourist accommodation) dependent on a certificate issued in another field (urban planning) is more than legally unorthodox.
...

 

May 8, 2024

Document

Data

Eurostat - EU tourism getting closer to 2019 levels

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Graphique | Eurostat

  • The graph below, taken from Eurostat's Data Browser (see link below), illustrates the distribution by type of tourist accommodation in the European Union. In Belgium, tourist residences represent 52% of the market, well above the European average (25%).
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Statistics | Eurostat

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