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Displaying the 30 latest comments.
Submitted | first-name | support | concern | top-concern | message |
|---|---|---|---|---|---|
2026-10-11 08:21:42 +02:00 | Ingrid | No I do not | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | |
2026-10-10 20:18:27 +02:00 | Anri | Yes I do | No concern, I Support the By-Law | ||
2026-10-10 09:00:39 +02:00 | Concerned | No I do not | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | |
2026-10-10 04:53:41 +02:00 | Donavan | No I do not | All of the above | Fair Competition: Aligning Dedicated Commercial Lets with Hotels | |
2026-10-09 07:51:56 +02:00 | Mark | No I do not | All of the above | Threat to Tourism Competitiveness, SMMEs & Informal Jobs | This is bullshit. You are revenue extracting from white households again. Try this in a township with their backyard rooms who are not ubder planning permission and you will be told where to go but you keep taxing whites and extractibg revenue. How about you derrgulate. Stop passing more useless laws. We are tired of your Bullshit DA. |
2026-10-08 23:15:45 +02:00 | Keith | No I do not | Consumer Impact: Higher Nightly Accommodation Rates & Reduced Choice | ||
2026-10-08 10:29:53 +02:00 | Ismail | No I do not | Threat to Supplemental Household Income & Rising Cost of Living | ||
2026-10-08 07:52:26 +02:00 | james curlewis | No I do not | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | How hard are the politicians taxed,you seem to be the real hyenas |
2026-10-07 21:42:01 +02:00 | Adrian | No I do not | All of the above | Threat to Tourism Competitiveness, SMMEs & Informal Jobs | I strongly oppose this proposed Bill. Flawed “Availability” Test: Taxing hosts based on open calendar days rather than actual income penalises owners whose properties sit empty off-peak. An empty flat listed online earns zero revenue yet gets hit with a commercial tax penalty. Punishing Household Survival: Middle-class families, retirees, and single-property owners rely on seasonal holiday letting to cover skyrocketing bond rates, electricity tariffs, and living costs. Inflated Prices for Guests & Tourists: Reclassifying rentals onto commercial rates increases operational costs by up to 135%. Hosts will pass these costs onto guests, making Cape Town less affordable for domestic South African families. Draconian Sanctions & POPIA Risks: Threatening property owners and tech platforms with 6 months in prison over administrative registration numbers is excessive. Automated data-sharing between global platforms and municipal databases raises personal privacy concerns under POPIA. “Slapping commercial property rates on holiday lets will simply result in higher prices at checkout. Domestic South African families looking for affordable beach holidays will be priced out, while small local businesses, restaurants, and transport operators will suffer if tourist spending decreases.” |
2026-10-07 11:56:50 +02:00 | Gerdia | Yes I do | No concern, I Support the By-Law | ||
2026-10-07 09:16:26 +02:00 | Jaime | No I do not | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | I do not support the draft Short-Term Letting By-law. It treats a listing as commercial activity even when the property is empty. Clause 4.5 of the Rates Policy and section 8 reclassify a property as Business and Commercial if it is listed as available for more than 50% of annual room-nights over a rolling 365 days. Availability is not occupancy or income. A flat open for the year but booked for a few peak weeks would still face commercial rates, often roughly double the residential tariff, including backdated bills. That misses the stated aim. Primary residences, spare rooms and granny flats used to cover bonds and pensions are not hotels. The by-law does not cap nights or return stock to long-term tenants; it mainly raises rates while hosts pass the cost to guests. Section 11’s fine or up to six months’ imprisonment for a missing registration number is disproportionate for an administrative omission, and mandatory platform sharing of addresses, municipal accounts and live calendars needs clear POPIA limits. If the City wants rate parity, tax actual commercial use, exempt genuine home-sharing, and use civil remedies, not criminal ones. Thank you |
2026-10-06 14:54:32 +02:00 | Alexi | No I do not | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | I am against State interference in controlling supplementary income derived from short term rentals |
2026-10-05 23:15:07 +02:00 | K | No I do not | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | ||
2026-10-05 23:01:28 +02:00 | Heike | No I do not | All of the above | Data Privacy Risks, POPIA Compliance & Mandatory Platform Sharing | What explicit legal and technical safeguards will the City implement to ensure platform data integrations comply with POPIA and prevent data breaches? POPIA Exposure: Transmitting sensitive host account details and live property occupancy calendars into municipal databases raises significant privacy and data-security risks under the Protection of Personal Information Act (POPIA). Third-Party Contractors: Section 13 allows the City to contract private third-party service providers to implement and monitor the system, raising concerns about who has access to host and property data. |
2026-10-05 21:06:01 +02:00 | Janelle | No I do not | Other | ||
2026-10-05 19:54:42 +02:00 | Sonia | Yes I do | No concern, I Support the By-Law | ||
2026-10-05 19:52:57 +02:00 | Alec | No I do not | All of the above | Fair Competition: Aligning Dedicated Commercial Lets with Hotels | Stop meddling with the business of society and fulfill your duties as required and determined by society. Fulfill the social contract. Remove yourself from business. |
2026-10-05 15:56:34 +02:00 | Carl | No I do not | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | ||
2026-10-05 15:36:37 +02:00 | Tiahnah-Leigh | Not fully | All of the above | Threat to Supplemental Household Income & Rising Cost of Living | Submission on the Draft Short-Term Letting By-Law, 2026 I am a Cape Town homeowner and Airbnb host, and I also co-host for other owners. I do not fully support the draft by-law. I agree that short-term letting needs regulation. Across the world, whole-property Airbnbs have pushed local residents out of the rental market, and Cape Town is not immune. But this by-law doesn't address that problem. It doesn't cap lets, restrict zones or encourage owners to return properties to long-term tenants. It moves holiday lets onto higher commercial rates, which looks like a revenue measure rather than a housing measure. This comes on top of a heavy burden on middle-class households. Electricity, rates, levies and municipal bills have risen sharply, alongside bond repayments, food and fuel. Cape Town is a well-run city, but residents pay a great deal for it. Many families rely on letting a room or part of their home to stay afloat. My concerns are: The test measures availability, not income. Rates are triggered by days a listing is open, not nights actually booked. A property can earn very little and still be charged commercial rates. Owners of a single property should be treated differently. An ordinary homeowner letting their own property should not carry the same burden as an investor running a portfolio of properties as full-time commercial lets. Regulation should target the real problem. If the aim is to protect long-term housing, the City should consider measures aimed at multi-property investors and non-resident owners, rather than taxing every host. Criminal penalties are excessive. Imprisonment for a registration omission is disproportionate. Civil penalties and compliance notices are more appropriate. I ask the City to rethink the approach and focus on investor-owned and non-resident-owned lets, rather than the households trying to cope with Cape Town's cost of living. |
2026-10-05 11:40:30 +02:00 | Dorothea | No I do not | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | An open calendar does not compare/indicates actual bookings of an accommodation. Further increasing rates will be passed on to the nightly rate and therefore increase the costs of accommodation for tourists in Cape Town. | |
2026-10-05 11:06:14 +02:00 | Corelius and Estelle | No I do not | Threat to Tourism Competitiveness, SMMEs & Informal Jobs | We own a residential property in Cape Town CBD that I let on a short-term basis. This is a side income, not a hotel or guesthouse business. I object to the draft Short-Term Letting By-law in its current form, and to the use of a 50% availability test to place properties of this scale on the same commercial rates as purpose-built accommodation. 1. Scale is not the same, so the rating consequence should not be the same A hotel or formal guesthouse is a purpose-built commercial operation: a single site, staff on payroll, commercial zoning in many cases, food and beverage, conferencing, and capital investment running into the tens or hundreds of millions. A host with one or a few flats has none of that. The asset is an ordinary residential unit, income is irregular, and the “business” is a listing, a cleaner and a set of keys. The 2026/27 property rates annexure nevertheless puts business and commercial property at a ratio of 1:2.41 to residential (rate-in-the-rand 0.016910 against 0.007010). GroundUp, using the City’s rates calculator, reported an inner-city property valued at R2.8 million at about R1,274 a month on residential rates and about R3,945 on commercial rates. That is the hotel rate applied to a flat. The draft does not distinguish a two-unit side activity from a 150-room hotel. Municipal rates are meant to track use and capacity to pay. A calendar threshold does not measure either. 1. The test taxes availability, not the scale of the operation The City’s FAQ defines the ratio as nights each bedroom is listed as available, divided by bedrooms times 365. Cross 50% of nights listed and the unit is commercial accommodation, whether it is booked or empty. Cape Town demand is seasonal. AirDNA’s August 2026 snapshot put average occupancy of active Cape Town listings at about 66% of the nights they were available. A small host leaves the calendar open through winter so peak-season bookings are possible. Under this rule, a flat that is actually let well under half the year can still be rated as a hotel. Occupancy, turnover and number of units would be better proxies for a commercial operation than nights the calendar was left open. 1. The cost is fixed; the income is not Commercial rates are payable whether the month is full or empty. Guest income is not. A small operator cannot spread a trebling of rates across a hotel’s room count, restaurant and conference revenue. The increase is passed into the nightly rate, which makes Cape Town less competitive, or it is absorbed by cutting cleaning, maintenance and casual local work. Neither outcome produces a long-term rental, and neither is comparable to the cost structure of a hotel. 1. The activity being priced as a hotel is a large part of visitor stay Cape Town tourism generated R24.5 billion in direct spend in 2025 and supported more than 106,000 jobs. Airbnb’s 2024 Cape Town impact report, covering 2023, stated about 700,000 guests, support for about 42,000 jobs, and a R14.4 billion GDP contribution. Those platform figures should be treated as the company’s own estimate, but the direction is clear: short-term letting is how a large share of visitors stay. Reporting based on Inside Airbnb put listings at about 26,300 in June 2025. Pushing small hosts to close calendars after 182 nights removes bed stock in the shoulder season. It does not convert those units into affordable housing, and it does not fund hotel-scale services that these properties do not provide. 1. Registration is written for a sector, not for a side holding The draft requires every listed property to register, display a City number, and have platforms share availability data. That machinery suits a regulated accommodation industry. Applied to a person with a few units, it is a compliance system whose only real output is a rates reclassification. Platforms that do not feed the City leave those listings invisible, so compliant small hosts carry the cost and non-compliant ones do not. 1. What I ask the City to change - Do not rate ordinary residential units as business and commercial merely because they are listed for more than half the year. - Define a commercial short-term operation by scale: for example a minimum number of units under one operator, or actual nights let and turnover above a stated level, closer to a guesthouse than to a side holding of one to a few properties. - If a threshold is kept, base it on nights actually let over a full seasonal cycle, not nights listed as available. - Keep small-scale letting on residential rates, with light registration if the City needs a record, rather than hotel rates and platform surveillance. - Publish an impact assessment of visitor spend, jobs and how many units would actually return to long-term rental before Council adopts the by-law, and do not implement rating changes from 1 July 2027 until that assessment and a revised draft have been through a further comment period. A level playing field with hotels is a reasonable aim for stock that is operated at hotel scale. This draft reaches that outcome by counting open nights on ordinary flats and then charging hotel rates. That is disproportionate to the investment, the staffing and the income of a small short-term letting holding. Names: Corelius Andries Visagie and Estelle Visagie Properties: Vanderbilt Development Contact: corrie.visagie@gmail.com, 0823356416 We are the registered owners. | |
2026-10-04 23:39:46 +02:00 | G | No I do not | All of the above | Revenue Generation vs. Solving the Inner-City Housing Squeeze | |
2026-10-04 22:55:58 +02:00 | W | No I do not | All of the above | Revenue Generation vs. Solving the Inner-City Housing Squeeze | Dear City of Cape Town, I wish to object to the proposed one-size-fits-all approach to short-term letting and the use of a 50% availability threshold. There is a fundamental difference between a resident lawfully letting part of their own home to supplement their income and a commercial operator running multiple accommodation units. These circumstances should not be treated in the same way. In my situation, I live in my home and let rooms for part of the year. This is not a commercial accommodation business; it is supplementary income. I have recently lost my life partner, and this income is now an important means of survival and of allowing me to remain in Cape Town and keep my home as a local resident. If the City limits short-term letting to 50% of availability, it makes little sense to impose commercial rates for the remaining 50% when the calendar is closed, there is no guest, no income and no commercial activity. The fairest basis is actual occupied and paid nights. The City should also be encouraging and supporting small resident-owned businesses, not creating barriers that favour larger commercial accommodation providers. Small hosts offer visitors something different: a more personal, local experience that brings tourists into our homes and neighbourhoods and spreads tourism spending into local businesses. This is also a valuable opportunity for ordinary Cape Town residents to generate income from their own property and remain in their communities, rather than forcing short-term accommodation increasingly towards large-scale commercial operations. Any regulation must be fair, proportionate and constitutionally sound. A blanket approach that fails to distinguish between a resident sharing their home and a commercial accommodation business does not achieve that. I am not seeking to avoid appropriate regulation or payment. I am asking that small, resident-owned short-term letting be recognised and treated differently, with a proportionate system based on actual activity and scale. Kind regards, |
2026-10-04 22:50:27 +02:00 | Shona | Not fully | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | ||
2026-10-04 18:47:54 +02:00 | Lolla | No I do not | Other | ||
2026-10-04 18:16:17 +02:00 | Lorraine | No I do not | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | I hereby submit my formal objection and comments regarding the proposed City of Cape Town Short-Term Letting By-law. I support sensible and proportionate regulation of short-term letting. I also recognise the City's legitimate interest in ensuring that properties operating as commercial accommodation comply with appropriate municipal requirements. However, I strongly object to a regulatory framework that effectively treats an individual owner of a private holiday home in the same manner as a hotel, guesthouse or large-scale commercial accommodation operation merely because the property is advertised for short- term letting. In its present form, the proposed framework risks creating a disproportionate financial and administrative burden on ordinary property owners while relying on a methodology that does not accurately measure the actual commercial use of a property. 1. THE 50% THRESHOLD IS NOT A MEASURE OF ACTUAL COMMERCIAL USE My principal objection concerns the proposed 50% threshold. The City's own FAQ makes it clear that the calculation is based on the number of nights a property is listed as available on a booking platform, rather than the number of nights for which the property is actually occupied or booked. This distinction is fundamental. A property can be listed as available for 365 days but be occupied for only a fraction of those days. Availability does not equal demand. Availability does not equal income. Availability does not equal commercial utilisation. Availability certainly should not automatically determine whether a privately owned residential property is treated as a commercial property for municipal-rating purposes. The proposed methodology therefore has the potential to produce a materially distorted picture of the actual economic use of a property. I request that the City reconsider the use of platform availability as the principal trigger for commercial rating. 2. THE PROPOSED SYSTEM CAN PENALISE OWNERS FOR TRYING TO OBTAIN BOOKINGS An owner who keeps a calendar open does so precisely because they want to receive bookings. Under the proposed methodology, however, keeping a property available for bookings may itself contribute to the property crossing the 50% threshold — even where the property receives comparatively few bookings. This creates an unintended and potentially perverse incentive. An owner could be financially disadvantaged simply for making the property available to tourists, rather than because the property is actually being operated at a level comparable with commercial accommodation. The City should not create a system in which the act of advertising a property can have a greater regulatory consequence than the actual number of nights for which tourists occupy it. 3. A PRIVATE HOLIDAY HOME IS NOT THE SAME AS A HOTEL OR GUESTHOUSE There is an important distinction between: - an individual who owns one holiday home; - a homeowner who occasionally lets their property; - a retiree or private individual supplementing income through short-term letting; - a professional property-management business; - a guesthouse; - a hotel; and - a large-scale commercial accommodation operator. These operations have fundamentally different business models, costs, staffing structures, levels of occupancy and impacts on municipal services. A one-property Airbnb host should not automatically be subjected to the same economic consequences as a commercial accommodation establishment simply because an online booking calendar is open. The final regulatory framework should expressly recognise these differences. 4. THE RATING CONSEQUENCE IS DISPROPORTIONATE The issue is particularly serious because the proposed classification is not merely administrative. The City's 2026/27 Draft Rates Policy provides for Business and Commercial properties to be charged at a rate ratio of approximately 2.41 times the residential rate. That represents a potentially substantial increase in municipal rates. A property owner could therefore face a major increase in annual municipal costs based on a calculation of listing availability, rather than actual occupancy or actual revenue. This is disproportionate. If the City believes that a property is operating as commercial accommodation to such an extent that commercial rates are justified, the determination should be based on evidence that demonstrates genuine commercial utilisation. The City should not effectively impose a substantial additional financial liability based primarily on the number of nights that an online calendar happens to show as available. 5. ACTUAL OCCUPANCY AND REVENUE SHOULD BE CONSIDERED I request that the City investigate a more balanced methodology that takes account of factors such as: - actual occupied nights; - actual short-term letting revenue; - percentage of the year actually occupied by short-term guests; - whether the property is the owner's primary residence; - whether the owner personally occupies the property for part of the year; - the number of properties owned and operated by the host; - whether the property is operated as a dedicated commercial accommodation business; and - the extent to which the property is genuinely available to the short-term letting market. A single percentage based on listing availability is too crude to determine the economic character of a property. 6. OWNER USE MUST BE PROPERLY RECOGNISED Holiday homes are frequently used by their owners and families. Owners may block dates for: - personal holidays; - family visits; - maintenance; - repairs; - renovations; - emergencies; - seasonal closure; - preparation between bookings; and - periods during which the owner simply does not wish to accept guests. The fact that an owner makes the property available on a platform does not mean that the property has ceased to be a private residential asset. The regulatory framework should recognise the legitimate private use of holiday properties. 7. THE CITY MUST AVOID UNINTENDED CONSEQUENCES The proposed system could encourage some owners to reduce their advertised availability, withdraw from short-term letting or potentially leave properties vacant during periods when they might otherwise accommodate tourists. That could have consequences for Cape Town's tourism accommodation supply. Short-term letting also supports a wider local economic and community ecosystem, as well as subsidiary services or secondary services including: - cleaners; - gardeners; - maintenance contractors; - plumbers and electricians; - laundry services; - property managers; - restaurants; - attractions; - transport providers; and - other tourism-related businesses; Regulation should address genuine problems without unnecessarily undermining this economic activity. 8. REGISTRATION IS ACCEPTABLE ONLY IF IT IS SIMPLE, PROPORTIONATE AND LOW-COST I do not object in principle to a registration system. However, registration should not become a de facto licensing regime for ordinary homeowners. The process should be: - simple; - inexpensive; - predominantly electronic; - quick to administer; - transparent; - accessible to individual owners; and - accompanied by clear written guidance. The City should also make a clear distinction between registration and commercial property classification. Registration of a property should not, by itself, mean that the property is regarded as a commercial property for rating purposes. 9. DATA COLLECTION REQUIRES STRICT LIMITATIONS The proposed sharing of information by booking platforms, owners and operators raises legitimate privacy and data-governance concerns. The City should clearly identify: 1. precisely what information will be collected; 2. why each category of information is required; 3. how the information will be verified; 4. who will have access to it; 5. how long it will be retained; 6. whether it will be shared with other entities; 7. how it will be protected; and 8. what rights owners have to challenge inaccurate information. | |
2026-10-04 16:16:02 +02:00 | Gillian | Not fully | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) | ||
2026-10-04 15:04:49 +02:00 | Tamara | No I do not | Threat to Supplemental Household Income & Rising Cost of Living | ||
2026-10-04 08:43:39 +02:00 | Katleho | No I do not | All of the above | Consumer Impact: Higher Nightly Accommodation Rates & Reduced Choice | |
2026-10-03 16:15:37 +02:00 | Trish | Not fully | Listed Availability vs. Actual Booked Occupancy (Flawed Tariff Test) |
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- Level Playing Field:
Traditional hotels, B&Bs, and registered guesthouses pay commercial rates and utility tariffs. Dedicated full-time Airbnbs operating as commercial businesses should contribute equal municipal rates. - Infrastructure Contribution:
High-density tourist rentals place heavier loads on municipal roads, water, waste, and security infrastructure in tourist hubs. Commercial rates ensure fair municipal cost recovery. - Consumer Protection:
A verified municipal registry helps eliminate online rental scams and fake listings, giving holidaymakers confidence in legitimate accommodation.
- Level Playing Field:
“Mandatory municipal registration protects tourists from fake listings and accommodation scams. Displaying an official City registration number guarantees the property is legitimate and traceable.”
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- Flawed “Availability” Test:
Taxing hosts based on open calendar days rather than actual income penalises owners whose properties sit empty off-peak. An empty flat listed online earns zero revenue yet gets hit with a commercial tax penalty. - Punishing Household Survival:
Middle-class families, retirees, and single-property owners rely on seasonal holiday letting to cover skyrocketing bond rates, electricity tariffs, and living costs. - Inflated Prices for Guests & Tourists:
Reclassifying rentals onto commercial rates increases operational costs by up to 135%. Hosts will pass these costs onto guests, making Cape Town less affordable for domestic South African families. - Draconian Sanctions & POPIA Risks:
Threatening property owners and tech platforms with 6 months in prison over administrative registration numbers is excessive. Automated data-sharing between global platforms and municipal databases raises personal privacy concerns under POPIA.
- Flawed “Availability” Test:
“Slapping commercial property rates on holiday lets will simply result in higher prices at checkout. Domestic South African families looking for affordable beach holidays will be priced out, while small local businesses, restaurants, and transport operators will suffer if tourist spending decreases.”