comments2

2026-09-01 08:11:41 +02:00

Kirsten

No I do not

All of the above

Threat to Tourism Competitiveness, SMMEs & Informal Jobs

2026-09-01 04:49:09 +02:00

EM

No I do not

All of the above

Threat to Supplemental Household Income & Rising Cost of Living

2026-08-31 22:06:17 +02:00

John

No I do not

All of the above

Fair Competition: Aligning Dedicated Commercial Lets with Hotels

2026-08-31 15:18:32 +02:00

Nicola

No I do not

All of the above

Threat to Supplemental Household Income & Rising Cost of Living

2026-08-31 12:34:35 +02:00

Paulette

Yes I do

No concern, I Support the By-Law

I am a resident in a residential estate on the West Coast. I bought in a residential area and residential estate not in a holiday resort. I find that all properties directly surrounding me operating guesthouses impacts my safety, peace and quiet and living conditions. The municipality should control this.

2026-08-31 11:54:24 +02:00

Tiaan

Not fully

All of the above

Threat to Tourism Competitiveness, SMMEs & Informal Jobs

I do agree that some changes are needed to allow for more balancing between commercial and non-commercial letting.
The majority of these proposed changes seems to be stemming from squeezing more money out of already cash strapped citizens.

2026-08-31 11:53:56 +02:00

Antoinette

No I do not

All of the above

Threat to Supplemental Household Income & Rising Cost of Living

2026-08-31 09:47:25 +02:00

Mark

No I do not

Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test)

I object to the proposed Short-Term Letting By-Law, 2026, in its current form. The 50% rolling-availability test is unfair and impractical: it measures advertised availability rather than actual occupancy or income, meaning a homeowner in a lower-demand area could be reclassified as "commercial" for keeping rooms listed most of the year to secure only modest bookings, while a property in a high-demand area achieving far greater occupancy on fewer listed days escapes the threshold entirely. This fails to distinguish a genuine owner-occupied primary residence — where a homeowner is simply trying to offset the City's steeply rising rates and taxes by letting spare rooms — from a property run purely as a commercial tourist business. The rolling 365-day calculation also risks keeping a property classified (and rated) as commercial for months after letting has stopped, with no clear, prompt mechanism to revert once deregistered, and no transparent process for homeowners to access or challenge the platform data the City relies on before retrospective commercial rates are imposed. I urge the City to base classification on actual occupancy rather than availability, to account for regional demand differences, and to ensure rates reflect current rather than historic use.

2026-08-31 09:45:26 +02:00

Willem

No I do not

Threat to Tourism Competitiveness, SMMEs & Informal Jobs

2026-08-31 08:25:43 +02:00

Gary

No I do not

All of the above

Consumer Impact: Higher Nightly Accommodation Rates & Reduced Choice

Why punish people who buy apartments to supplement their income and have a place to go for their own holidays instead of spending huge sums on hotel accommodation. Surely i have a choice to buy a place, let it out to supplement the cost of the place and use it when i go on my own holiday there. These municipalities and government departments who want additional income because they need to steal funds for their own benefits. It's a disgrace. It is regulated and that is all that should be required. BBBE Businesses can pop up anywhere they like included b&b's and they are exempt from these laws.
It is total nonsense.

2026-08-30 17:21:31 +02:00

Bruce

No I do not

All of the above

Threat to Supplemental Household Income & Rising Cost of Living

Simply put, in my opinion, I think that this is stupid. Although I live in Gauteng, the government would not waste any time in implementing this everywhere. This is driven purely by political greed! The moment a part of the private sector economy starts doing well with something, politicians realise that they are missing out (because they have no personal vested interest in their employment efforts), and then they want in on the money - again and again - since 1994! Try and prove me wrong on that! For Heaven's sake, the one sector in our economy that is doing well, is tourism and now you want to come and bugger it up (still saying it politely) with legislation that is going to cripple Air B&B's to the point that it won't be feasible to run them and consequently, tourists will need hotels. It is actually pitiful that I have to explain this argument to you when personally, I find it blatantly obvious!

2026-08-30 15:30:07 +02:00

Sergio

No I do not

Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test)

Bad for tourism as well as investment in Cape Town

2026-08-30 15:27:58 +02:00

Dorothea

No I do not

Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test)

Availability versus actual booked occupancy.
Also this initiative is bad for attracting tourists to Cape Town.

2026-08-30 13:04:01 +02:00

deborah

No I do not

Threat to Supplemental Household Income & Rising Cost of Living

Personal Comments on the Proposed Short-Term Letting By-Law

I support the fair and effective regulation of genuinely commercial short-term letting businesses. However, having considered the proposed Short-Term Letting By-law, I have a number of concerns about whether the proposed approach is fair, proportionate and practical, particularly for homeowners who live permanently in their properties and use spare rooms or accommodation to supplement their income.

My concern is that the proposed system may unintentionally treat genuine primary residences in the same way as properties that have been purchased and operated primarily as commercial tourist accommodation.

Primary residences should be distinguished from commercial accommodation businesses

In my view, the most important consideration should be the dominant use and character of the property.

A homeowner does not cease using a property as their primary residence simply because they earn some income from it. Many people conduct income-producing activities from their homes without the property consequently being regarded as a commercial property.

The City's own documentation appears to recognise that primary residences used to supplement an owner's income should continue to be supported. Yet the proposed 50% test could result in a homeowner who lives permanently in a four-bedroom home, but makes three spare bedrooms available for short-term guests, being classified as commercial.

I believe there needs to be a clear distinction between a genuine owner-occupied primary residence generating supplementary income and a property that is predominantly operated as a commercial tourist accommodation business.

The 50% availability test concerns me

One of my biggest concerns is that the proposed formula appears to measure availability rather than actual bookings or occupancy.

These are very different things.

A homeowner may need to advertise accommodation for most of the year simply to achieve a relatively small number of bookings. Keeping a room available online does not mean that it is occupied, generating income or operating at a high level of commercial activity.

For example, two homeowners could each have two rooms available:

One lives in a lower-demand area and keeps the rooms advertised for 365 days but only manages to obtain 60 nights of bookings.

Another lives in a high-demand tourist area, advertises for only 150 nights and achieves 140 booked nights, potentially generating substantially more income.

Yet it appears that the first homeowner could be more likely to cross the City's proposed commercial threshold simply because the rooms were available for longer.

To me, that does not provide an accurate measure of commercial activity.

It is particularly difficult to understand the reasoning behind this when booking platforms are apparently going to provide the City with both availability and actual occupancy data. If occupancy information is available, I believe actual use should carry substantially more weight than the number of days that accommodation happens to be advertised.

The impact will not be equal across Cape Town

I am also concerned that a single availability threshold could produce very different outcomes depending on where a property is situated.

Properties in seasonal or lower-demand areas may need to remain advertised throughout the year to obtain relatively few bookings, whereas properties in high-demand tourist areas may achieve substantially greater occupancy and income despite being available for fewer days.

The proposed formula could therefore have the unintended consequence of penalising a relatively modest short-term letting operation more severely than a much more successful one.

Rooms in someone's home should not automatically be treated as housing removed from the rental market

I also question the assumption that short-term letting of spare rooms within an owner-occupied home necessarily removes accommodation from Cape Town's long-term rental market.

There is an important difference between an entire investment property being used for tourist accommodation and a homeowner occasionally or seasonally letting unused rooms within their own home.

If short-term letting those rooms becomes uneconomical, many homeowners may simply stop offering them rather than convert them into permanent long-term tenancies, which involve very different obligations, occupation rights and risks.

Commercial rates should reflect current use

I am also concerned about the proposed rolling 365-day calculation.

As I understand it, a property that crosses the 50% threshold could remain commercially classified for some time even after the owner has stopped short-term letting altogether. The original comments illustrate that a property previously advertised continuously could theoretically remain above the threshold for approximately six months after the activity ceased.

That seems fundamentally unfair.

If an owner stops short-term letting and deregisters the property, I believe there should be a clear and prompt mechanism for the property to return to its appropriate residential rating category.

Homeowners must be able to challenge the City's information

Another concern is the proposed reliance on historical data supplied directly by booking platforms.

Most ordinary homeowners do not keep monthly screenshots or records of their Airbnb calendars. Availability changes constantly as dates are opened, blocked, booked or cancelled.

If the City subsequently determines that a property crossed the 50% threshold months earlier, how is an ordinary homeowner expected to prove that the City's calculation is incorrect?

This becomes particularly concerning if a supplementary valuation can result in retrospective commercial-rate charges from the date on which the City believes the threshold was crossed.

In my view, homeowners should have access to the information relied upon by the City and be given a reasonable opportunity to challenge that information before commercial rates and potentially significant retrospective charges are imposed.

A more balanced approach

I recognise the City's right and responsibility to regulate short-term letting and to distinguish genuine commercial tourist-accommodation businesses from ordinary residential properties.

My concern is not with reasonable regulation. It is with using a single mathematical availability test that may not accurately reflect the actual occupancy, income, intensity of use or residential character of a property. The submission itself identifies this risk, particularly for ordinary homeowners in seasonal or weaker markets.

I would therefore urge the City to reconsider the proposed approach and develop a system that:

clearly distinguishes genuine owner-occupied primary residences from properties predominantly operated as commercial accommodation businesses;
places greater emphasis on actual occupancy and actual use, rather than advertised availability;
recognises differences between seasonal, lower-demand and high-demand areas;
ensures that property rating classifications reflect current use rather than historic activity; and
provides homeowners with transparent information and a fair opportunity to challenge a proposed commercial classification before retrospective commercial charges are imposed.

I believe this would still allow the City to regulate genuinely commercial short-term letting effectively, while avoiding unintended and potentially unfair consequences for ordinary homeowners who use spare accommodation within their primary residence to supplement their income.

2026-08-30 10:17:50 +02:00

Carla

No I do not

All of the above

Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test)