Lien naar de oproep van de Europese Commissie
Lien naar de bijdrage van STR-Belgium
STR-Belgium is a non-profit association that defends the interests of private individuals and professional operators of non-hotel tourist accommodation in Belgium, with a particular focus on holiday rentals.
STR-Belgium welcomes the European Commission’s initiative to establish a European plan for affordable housing. STR-Belgium hopes that this plan will deliver 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 require better governance in defining their housing policies. While it is clear that, for electoral and/or opportunistic reasons — sometimes also linked to hotel lobbies — certain politicians prefer to forcibly shut down short-term rental operations (including sealing properties), even when these are operated by “best-in-class” actors, one may question the real effect of such actions beyond the media and sensational impact sought.
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 housing units in the Region (Statbel data – 2020) and around 4,975 non-hotel tourist accommodation units on average over the 2022–2024 period (including holiday rentals rented all or part of the year and rooms in private homes – visit.brussels data), housing used for short-term rental would represent, at the upper limit, only 1.05% of the Region’s housing stock. Some politicians, without much scientific justification, nevertheless claim that such short-term rentals account for 30% in certain tourist districts of cities. Beyond verifying this figure, it would also be useful for those same politicians to reasonably define acceptable ratios district by district. Indeed, even if one can logically understand the desire to spread tourism across cities, it may still make sense that there is a higher concentration of tourist accommodation in some areas than in others.
Today, however, and unfortunately, the caretaker government has made the unreasonable choice — in total contradiction with the evolution of travel preferences among global citizens (see Eurostat figures) — to define a ratio of “~0” across the territory of the 19 municipalities of the Region, without any distinction. This has led to a clandestine market of 95–98%, with only 96 registered holiday rentals 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 playing for time and eagerly awaiting the entry into force in May 2026 of the EU regulation on short-term rentals: at that moment, the largely clandestine market would be eliminated, drastically reducing the alternative and complementary supply to traditional hotels that short-term rentals represent — yet which is so essential for cities aiming at a competitive, innovative, and sustainable tourism market, benefiting global citizens whether they are tourists, residents, or economic actors.
The real questions will then be: what will be the actual impact in Brussels of removing these 5,000 short-term rentals on the housing issue? What will be the impact on urban economic dynamics (STR operators and associated services, restaurant and bar attendance, etc.)? And what will be the impact on consumers (tourists) — particularly the evolution of hotel room prices? It is indeed essential not to examine such a complex societal issue without a minimum of critical thinking, and to respect the proper sequence: data first… then decisions that are justified, proportionate, and non-discriminatory.
While 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, as an association defending a sector that is threatened and wrongly portrayed as the scapegoat for the structural housing problem, to react.
We would like to draw attention to several points at the intersection of permanent housing and short-term rental issues that must be taken into account when 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:
Labels to ensure the societal integration of short-term rentals into neighbourhoods. Importantly, unlike quotas, such labels should apply to all types of short-term rentals except home-sharing. Indeed, why should a resident renting out their main residence in its entirety 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, be defined at a systemic level with a rigorous multi-criteria analysis, and in compliance with EU rules, notably 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 the housing issue that identifies the elimination of short-term rentals as a structural solution. By contrast, 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 put in place over the past two decades to improve the situation, including ‘incentives for the private sector to build more affordable housing.’ However, it highlights numerous obstacles such as still insufficient funding and the complexity of delivering planning permits. Its recommendations to curb the crisis rely on one mantra: increase the supply of affordable housing where it is needed. This can be done through revising and streamlining permitting policies, supporting production via more flexible planning and zoning rules, as well as extending tax advantages from public actors to motivated investors and developers. Finally, the OECD suggests offering more flexibility to municipalities to build more and higher, for example in exchange for more social housing, implementing rent regulation, and ensuring a more even 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:
An impartial involvement of the academic community to clearly and unambiguously define district-by-district quota mechanisms, taking into account the multidimensional impacts mentioned above (housing, direct and indirect economic effects, etc.).
