Nearly every private-rented duty is drawn on a tenancy that is someone's only or main home, so a holiday let to paying guests sits outside deposit protection, Right to Rent, the EICR and alarm regulations and the minimum EPC band. What applies: gas safety, a whole-premises fire risk assessment, guest records, planning, and a national register expected from March 2027.
By Stevie Hayes · Updated 19 October 2026 · Figures checked against legislation.gov.uk and GOV.UK on 19 October 2026 · How we verify · Report a problem with this page · Statutory penalties are maximums; councils and courts decide the amount.
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| Fact | Position | Since / status | Source |
|---|---|---|---|
| What a short-term let is | Accommodation provided "other than the guest's only or principal residence", for payment, in the course of a trade or business | LURA 2023 s.228(2) | Levelling-up and Regeneration Act 2023 s.228 |
| National register | Mandatory scheme for England "expected to begin in March 2027"; not yet in force | GOV.UK, 2 October 2026 | GOV.UK: Letting out a self-catering holiday home in England (updated 2 October 2026) |
| Gas safety | Annual check and record apply: HSE lists "rented holiday accommodation such as chalets, cottages, flats" | HSE: Gas safety, landlords and letting agents | |
| Fire risk assessment | The responsible person "must make a suitable and sufficient assessment of the risks" and record it; an annual review is usual | RRO 2005 art 9 | Regulatory Reform (Fire Safety) Order 2005 |
| Deposit protection | Does not apply: a tenancy deposit is one paid "in relation to an assured tenancy", and a holiday letting is not assured | Housing Act 2004 s.212 (tenancy deposits) | |
| Right to Rent | Does not apply: "for residential use" means occupied "as their only or main residence" | Immigration Act 2014 s.20 (residential tenancy agreement) | |
| EPC | Needed only if let for under 31 days at a time, 4 months or more in any 12, and the guest pays the energy | GOV.UK: A guide to energy performance certificates for the marketing, sale and let of dwellings | |
| Greater London planning | Up to 90 nights a year as temporary sleeping accommodation is not a change of use while the host pays the council tax | Deregulation Act 2015 s.44 | Deregulation Act 2015 s.44 (London, 90 nights) |
Almost every duty on a private landlord in England is written around a tenancy that is the occupier's only or main residence. A short-term let is the opposite: the law's own definition, in section 228 of the Levelling-up and Regeneration Act 2023, is a dwelling "provided by a person ('the host') to another person ('the guest') for use by the guest as accommodation other than the guest's only or principal residence, in return for payment … and in the course of a trade or business carried on by the host".
That is why so much of the landlord rulebook falls away for a holiday let, and why a different, smaller set of duties takes its place. This guide covers England only. It describes the law; it is not advice on a particular property.
The annual gas safety check and record are unchanged. HSE's landlord guidance says the duties "apply to a wide range of accommodation, occupied under a lease or licence, which includes … rented holiday accommodation such as chalets, cottages, flats, caravans and narrow boats on inland waterways". GOV.UK's self-catering guidance says you "must follow" it.
The Regulatory Reform (Fire Safety) Order 2005 does not apply to "domestic premises" (article 6), but the Home Office guide Making your small paying guest accommodation safe from fire is clear that "premises with short-term, temporary paying guests staying are unlikely to be occupied as a private dwelling". Once the Order applies, article 9 requires the responsible person to "make a suitable and sufficient assessment of the risks", and the guide says you must "carry out a suitable and sufficient fire risk assessment of your premises and … record your findings", review it "regularly", and that "an annual review is usually appropriate, but you must also conduct a review following any significant change to the premises, or an incident such as a fire". The guide covers single premises for up to 10 guests with no more than four first-floor bedrooms; larger or more complex properties use the sleeping-accommodation guide it links to.
The 2020 Regulations do not bind a guest let, but GOV.UK says you "must follow the HSE guidance on electrical safety" and the PRS electrical guidance. A current electrical installation condition report is the standard way to show the installation is safe; it is evidence of the duty, not a five-year statutory certificate.
GOV.UK's EPC guide: "Holiday lets may not need an EPC. An EPC will only be required for a property rented out as a furnished holiday let … where the building is occupied for the purposes of a holiday as a result of a short term letting arrangement of less than 31 days to each tenant, and is rented out for a combined total of 4 months or more in any 12 month period, and if the occupier is responsible for meeting the energy costs for the property." Read the full passage; there is no minimum band for a guest let.
The Immigration (Hotel Records) Order 1972 applies to "any hotel or other premises, whether furnished or unfurnished, where lodging or sleeping accommodation is provided for reward". Every guest aged 16 or over must give their full name and nationality on arrival, guests the Order classes as aliens also give passport details and their next destination, and the keeper must keep "for a period of at least 12 months a record in writing of the date of arrival of every such person and of all information given".
Planning. GOV.UK: "Your local planning authority will decide whether you need planning permission." In Greater London, section 44 of the Deregulation Act 2015 inserted section 25A into the Greater London Council (General Powers) Act 1973: using a home as temporary sleeping accommodation "does not involve a material change of use" if the nights in the calendar year do "not exceed ninety" and the person providing it "was liable to pay council tax" for the premises. The proposed C5 use class for short-term lets has not been brought into force in England.
Business rates. GOV.UK: a property in England is valued for business rates as self-catering accommodation if you are "letting it for short periods commercially for 28 nights or less", it "was available to let for short periods commercially for at least 140 nights in the last 12 months", it "was actually let for at least 70 nights in the last 12 months", and you "plan to make it available … for at least 140 nights in the next 12 months".
Tax. GOV.UK: "The government abolished the Furnished Holiday Let (FHL) tax regime on 6 April 2025." Income is now taxed under the usual residential landlord rules.
GOV.UK's self-catering guidance, updated 2 October 2026, says: "The UK government is introducing a mandatory national registration scheme for short-term lets in England. It is expected to begin in March 2027." The power is section 228 of the 2023 Act, which says the Secretary of State "must by regulations make provision requiring or permitting the registration of specified short-term rental properties in England". As at 19 October 2026 no regulations have been made, so the scheme is not yet in force and nothing is required of a host today. The registration guide tracks it.
For each guest property, hold four things together: the current gas safety record, a dated fire risk assessment with its review date, the EPC or a note of why one is not needed under the four-month test, and the guest register. Check the planning position with the council once, and keep the nights-let count for business rates. Nothing else from the long-tenancy rulebook applies until the property becomes someone's home, at which point every duty in the landlord guides does.
Government changes that bear on this duty. Where the status says in force the rule already applies; everything else is not yet law for private landlords. Dates are quoted as the government has published them, checked on 15 October 2026.
| Change | Status today | Published timing | Sensible preparation |
|---|---|---|---|
| A mandatory national registration scheme for short-term lets in England (holiday lets and other guest accommodation) | policy decision, regulations not yet made | GOV.UK (updated 2 October 2026): "expected to begin in March 2027"; the enabling power is section 228 of the Levelling-up and Regeneration Act 2023 and no regulations have been made | Keep the gas safety record, the fire risk assessment and (where one is needed) the EPC for each guest property together with its address and your contact details; the 2023 consultation proposed those as the core of an entry. Source |
No. A statutory tenancy deposit is one paid in relation to an assured tenancy (Housing Act 2004 s.212(8)), and a holiday letting is not an assured tenancy. A booking deposit is governed by your contract.
No. The check applies to an agreement for residential use, which means occupation as the person's only or main residence (Immigration Act 2014 s.20(4)). Guest records under the 1972 Order still apply.
The 2020 Regulations' five-year cycle binds only a tenancy that is the occupier's only or main residence. The duty to keep the installation safe remains, and a current EICR is the standard evidence of it.
Only if it is let for less than 31 days at a time, for 4 months or more in any 12-month period, and the guest pays the energy costs (GOV.UK EPC guide). There is no minimum band for a guest let.
Yes, once paying guests stay and the property is not occupied as a private dwelling. The Fire Safety Order 2005 requires a suitable and sufficient assessment, recorded, and the Home Office guide says an annual review is usually appropriate.
Up to 90 nights in a calendar year without it being a material change of use, provided the person providing the accommodation is liable for the council tax (Greater London Council (General Powers) Act 1973 s.25A, inserted by the Deregulation Act 2015). Beyond that, planning permission is a question for the council.
ComplyWithMe keeps the gas safety record and EPC date for every property and reminds you before each one lapses, so the guest-let file is never reconstructed after the event.
Keep the four records togetherFrom the ComplyWithMe news feed: enforcement decisions and legislation changes, each linked to its official source.
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