Before introducing short-term rental restrictions, authorities should be able to explain what the local housing market would gain. Would affected properties become long-term homes? Would housing become more affordable? And what would the consequences be for households and businesses that depend on visitor spending?
These questions underpin the European Holiday Home Association’s preliminary position paper on the proposed Affordable Housing Act. EHHA is calling for a fundamental revision of the proposal, arguing that making restrictions easier to introduce does not, by itself, deliver more affordable homes.
Alongside its policy intervention, the association has launched #morethanastay, a campaign highlighting the relationships between hosts, guests and local communities.
The Affordable Housing Act remains a proposal under consideration by the European Parliament and the Council. Its provisions should therefore be distinguished from rules already in force.
Short-term rental restrictions need local evidence
EHHA’s central argument is that improving housing affordability requires a stronger focus on supply. It advocates new construction, bringing existing housing back into use and faster permitting, with restrictions serving as a targeted measure of last resort.
Before limiting short-term rentals, the association wants authorities to establish their actual impact in the area concerned. It also calls for an examination of whether properties leaving the short-term market would genuinely become available for long-term residential use.
EHHA places particular emphasis on mandatory use of the information generated through the EU’s short-term rental registration and data-sharing framework. Its position is that decisions should follow reliable local evidence.
The European Commission, meanwhile, explains that its proposal does not require cities to introduce restrictions. Authorities would have to substantiate a significant adverse effect of the activity concerned on housing affordability or availability. Housing pressure and short-term rental activity existing in the same area would not, on their own, be sufficient justification.
The disagreement therefore concerns the strength and practical operation of the safeguards, as well as the policy emphasis.
Who checks restrictions before businesses lose income?
A major EHHA concern is the proposed removal of the Services Directive notification obligation for covered short-term rental measures.
The association argues that this would weaken scrutiny before restrictions take effect. For a small host or property manager, challenging a measure in court can require substantial time and resources, while income may already have been lost.
EHHA also objects to the different treatment of existing and future restrictions. The Commission clarifies that measures adopted before the proposed Regulation enters into force would be excluded from the new framework. They would, however, remain subject to applicable EU law; exclusion would not establish that they are lawful.
For EHHA, this distinction risks maintaining uneven protection across destinations.
The association also seeks clearer safeguards for primary and secondary homes. Of particular relevance to professional property managers, it argues that any assessment of activity scale should apply at owner or beneficial-owner level, rather than aggregating properties managed on behalf of different clients.
EHHA links its intervention to the recent Smartflats judgment, calling for the principles of necessity and proportionality to be reflected effectively in the proposed legislation.
#morethanastay: The people behind the bookings
The #morethanastay campaign adds a human dimension to EHHA’s policy arguments.
Its stories connect short-term stays with people including a physiotherapist in Warsaw, a family food shop in Lecce, a newcomer to Amsterdam and a landscape gardener in Germany’s Eifel region.
The campaign aims to show that decisions about short-term rentals reach beyond individual listings. They can affect local services, businesses and people travelling for different reasons.
EHHA says it supports affordable housing and fair, workable rules for the sector. Its demand is that restrictions should be assessed against their likely housing benefits and wider consequences, rather than treated as a solution whose effectiveness can be assumed.