Short-Term Let Licensing: Licence Renewals and Revision to Stl Policy
Argyll and Bute Council · 18 June 2025
Back to Planning, Protective Services and Licensing Committee — 18 June 2025 and its agenda
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ARGYLL AND BUTE COUNCIL PLANNING, PROTECTIVE SERVICES AND LICENSING DEVELOPMENT AND ECONOMIC GROWTH 18 JUNE 2025 SHORT-TERM LET LICENSING: LICENCE RENEWALS AND REVISION TO STL POLICY 1.0 EXECUTIVE SUMMARY 1.1 This report recommends that Committee considers amendments to the Councils Short-Term Let (‘STL’) Licensing Policy (‘the policy’) to reflect the renewal process with three-year licensing, the associated renewal fee, and recommend approval to Council. 1.2 The Councils current Short-term Let Policy revised in September 2024 reflected the challenges of determining first time applications for short-term lets across Argyll and Bute. Introduced in 2022 through Scottish Government legislation, work has been concentrated on developing an effective licensing system within Regulatory Services, to determine 3535 applications with the focus on determining all existing host applications by September 2025. However, the first tranche of renewal applications are expected from September 2025, and the Council requires to amend its Policy to reflect our renewal processes and agree a renewal fee. 1.3 The Council’s functions as licensing authority are funded directly by income raised from licence application fees. The fees are intended to fully recover the costs of delivering a licensing scheme. Renewal fees proposed will fund delivery of this three- year licensing scheme for the period 2026-29 1.4 It is recommended that Committee (i) considers and supports the introduction of a three-year renewal period for short-term let licences, the new renewal fees, and revisions to the Council’s Short-term Let Licensing Policy. (ii) recommend to Council approval of these proposals, as outlined in (i) above.
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ARGYLL AND BUTE COUNCIL PLANNING, PROTECTIVE SERVICES AND LICENSING COMMITTEE DEVELOPMENT AND ECONOMIC GROWTH 18 JUNE 2025 SHORT-TERM LET LICENSING: LICENCE RENEWALS AND REVISION TO STL POLICY 2.0 INTRODUCTION 2.1 The licensing scheme was brought in by the Scottish Government under the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022. 3.0 RECOMMENDATIONS 3.1 It is recommended that Committee (i) considers and supports the introduction of a three-year renewal period for short-term let licences, the new renewal fees, and revisions to the Council’s Short-term Let Licensing Policy. (ii) recommend to Council, approval of these proposals as outlined in (i) above. 4.0 DETAIL 4.1 The aim of the licensing scheme is to ensure short-term lets are safe, address issues faced by neighbours, to facilitate local authorities knowing and understanding what is happening in their area, and handling complaints effectively. It also aims to balance the economic and tourism benefits from short-term lets with the needs and concerns of local communities to ensure the people providing short-term lets are suitable 4.2 It’s been challenging introducing and delivering the new STL licensing scheme within Argyll and Bute given its large tourism sector. Our focus has been on determining 3535 first-time applications and as of the 27 May 2025, 2498 Short-term let licences have been issued. The remaining 668 existing host applications fall to be determined by the 30 September 2025 and there are 117 new applications being processed. Its also worth noting that there are on average 20 new applications made each month. Table 1 Detail Number Total number of applications received 3535 No of STL licences issued 2498 No of applications withdrawn/surrendered/invalid applications 150/41/61 No of existing host applications to be determined 668 Aim to determine all by 30 September 2025
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No of new applications to be determined 117 Note: Figures as of 27/05/2025 4.3 Whilst the majority of licences will fall for renewal between 2027/29, there are a small number of licences which fall to be renewed from June 2025. Accordingly, renewal procedures and processes have been developed and require approval by Council. The intention is: (i) Renewal applications will be considered in line with existing processes, with consultation taking place with Police Scotland, Scottish Fire & Rescue Service and internal Council services. Where objections are received and cannot be resolved, these will be referred to the Planning, Protective Services and Licensing Committee for determination in the normal manner. (ii) The renewal period will be for a three-year period, consistent with initial licences and the other civic government licences issued by the Council, unless there are circumstances which justify a shorter time period. This will commence from the date of expiry of the previous licence, NOT three years from the date of issue. (iii) When an application is made to renew a licence timeously, the existing licence will continue in effect until such time as a decision is made on the renewal application. It is the responsibility of the licence holder to ensure that their licence is renewed prior to its expiry date. (iv) Where an application for a licence renewal is submitted after the expiry of an existing licence, the licence will be treated as an initial licence (as opposed to a licence renewal application) and the operator will therefore be unlicensed until a new licence is issued. This is unless the application is made within the statutory grace period set out in Paragraph 8(5A) of Schedule 1 to the 1982 Act. It would be a criminal offence to continue to let the property without a licence being in place. (v) It is proposed that the renewal fee is the same as the new application fees as detailed in the table 2 below. This fee reflects the work involved in the checking, processing, and determination of a three year renewal application, associated necessary property inspections, considering objections, and for enhanced monitoring and enforcement of the scheme. If approved, the fee structure will thereafter be included in the annual setting of fees for all licence categories, as part of the Council’s annual budget process. 4.4 The revised Short-Term Let Licensing Policy (see Appendix 1) is provided for members’ consideration. This introduces a revised Section 8 Licence Duration and Renewal, detailing the Councils renewal processes and reflecting the proposals in 4.2 in more detail 4.5 Fees: It is proposed that the renewal fee is the same as the new application fees as detailed in the table 2 below, to provide the income levels for the Councils expenditure to deliver the licensing scheme for 2026-29. This fee reflects the work involved in the checking, processing, and determination of a three year renewal application, associated necessary property inspections, considering objections, and for enhanced monitoring and enforcement of the scheme. If approved, the fee
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structure will thereafter be included in the annual setting of fees for all licence categories, as part of the Council’s annual budget process. Table 2 Guest capacity applied for (including children under the age of 10) Home sharing or home letting licence Secondary letting licence New application Renewal New application Renewal Up to 4 269.15 269.15 376.35 376.35 5 to 8 376.35 376.35 538.30 538.30 9 to 12 591.90 591.90 807.50 807.50 13 to 20 753.90 753.90 1076.70 1076.70 21 and over 969.50 969.50 1345.85 1345.85 5.0 CONCLUSION 5.1 To support the short-term let sector to continue operating and providing safe accommodation to guests, the Council requires to have appropriate arrangements in place to receive and determine application for renewal of licences. The reports’ recommendations deliver these requirements. 6.0 IMPLICATIONS 6.1 Policy: Consistent with the Council’s Corporate Plan and statutory duty. 6.2 Financial: Licensing scheme is to be self-financing from income levels. 6.3 Legal: Meets Council’s mandatory duty under Civic Government (Scotland) Act 1982 (Licensing of Short-Term Lets) Order 2022. 6.4 HR: None. 6.5 Customer Service 6.6 Risk: Council’s legal duty will be met through revision of the Policy 6.7 Climate Change: Supports climate change and environment standards 6.8 Fairer Scotland Duty 6.9 Equalities - protected characteristics: No adverse impact on protected characteristics 6.10 Consumer Duty: 6.11 Island Communities: Licensing scheme will be consistently applied across the whole of Argyll and Bute 6.12 Children’s Rights and Wellbeing: Ensures that short-term lets offer safe and appropriate accommodation
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Kirsty Flanagan Executive Director with responsibility for Development and Economic Growth Policy Lead: Councillor Kieron Green 28/05/2025 For further information contact: Alan Morrison, Senior Manager- Regulatory Services and Building Standards (alan.morrison@argyll-bute.gov.uk) APPENDICES Appendix 1: Revised Short-term Let Licensing Policy (revised June 2025)