Licence, Night Cap or Zoning: How Fifteen Markets Regulate Short-Term Rentals

“Short-term rental regulation” gets discussed as if it were a single dial a market turns up or down. It is not. Across our fifteen verified markets, the common instrument is a licence or registration requirement. A fixed annual night cap is rarer than the regulatory discourse suggests, and when it exists it applies to a specific subset of stays, not to every rental in the market.

We maintain a regulatory tracker where every entry is verified by hand against official government sources. This comparison draws on the fifteen markets we have verified so far.

The short version: 14 of 15 require a licence or registration. Only 4 impose a fixed annual night cap, and those four caps do not mean the same thing.

Key findings

• A licence is the norm; a fixed cap is the exception. 14 of 15 markets require a licence, permit or registration. Only 4 set a fixed annual night cap.
• London is the only market with no licence requirement. Its binding constraint on a primary-residence host is a 90-night annual cap. No operational registration scheme was in force as of 2025.
• The four caps cover different scopes. London’s 90 nights apply to a primary residence let without planning permission. Paris’s 120 nights apply to a primary residence. Sydney’s 180 nights apply to non-hosted lettings in Greater Sydney. Toronto’s 180 nights apply to entire-unit rentals only. A bare number hides all of that.
• “None” in the cap column does not mean no limit. San Diego’s Tier 1 permit is restricted to a maximum of 20 days per calendar year. Washington DC’s Vacation Rental licence type is capped at 90 nights per year. “None” records the absence of a single across-the-board annual cap, not the absence of any constraint.
• Primary-residence rules appear across multiple markets, independently of night caps. Denver, Nashville (owner-occupied tier), Toronto, Vancouver and Washington DC all restrict short-term rental to the operator’s principal residence.
• 57 official sources verified across these 15 markets.

The fifteen markets, side by side

Market	Country	Licence or registration required	Fixed annual night cap	Official sources verified
Denver	United States	Yes	None	2
Edinburgh	United Kingdom	Yes	None	6
Honolulu	United States	Yes	None	2
London	United Kingdom	No	90	6
Miami	United States	Yes	None	8
Nashville	United States	Yes	None	5
New Orleans	United States	Yes	None	2
Paris	France	Yes	120	4
Porto	Portugal	Yes	None	3
San Diego	United States	Yes	None	2
Seattle	United States	Yes	None	2
Sydney	Australia	Yes	180	4
Toronto	Canada	Yes	180	3
Vancouver	Canada	Yes	None	5
Washington DC	United States	Yes	None	3

The “Fixed annual night cap” column is deliberately strict. “None” does not mean a market is unregulated, and it does not mean a host may let all year without limit. It means there is no single calendar-year night number that applies across the market. In several of these markets the binding rule is a licence condition, a zoning line or a tiered permit structure, not a night count.

A licence is the instrument most markets use

Fourteen markets require some form of licence, permit or registration before a host can legally operate. The architecture of that requirement varies considerably.

Edinburgh is the clearest case of a licence as hard enforcement. Scotland’s Short-Term Let licensing scheme is mandatory, and operating without a licence is a criminal offence carrying a fine of up to GBP 2,500. The licence comes in four types depending on whether the property is the operator’s own home, whether the operator is present or absent during guest stays, and whether it is a secondary letting. No annual night cap applies; the licence itself is the instrument of control.

Honolulu leans hardest on zoning. Short-term rentals are confined to resort-zoned areas and a set of apartment zones designated by City Council. The question there is less “how many nights” and more “is this address even eligible.”

New Orleans and Nashville both divide their permit systems between residential and commercial tiers. New Orleans separates a Non-Commercial Short Term Rental licence for residential properties from a Commercial Short Term Rental licence that requires a conditional use permit from the zoning authority. Nashville distinguishes Owner-Occupied permits (available in all zones, primary-residence required) from Not Owner-Occupied permits, which new applicants may only obtain in commercial and mixed-use zones. No annual night cap applies in either city.

Denver restricts short-term rental to the licensee’s primary residence and limits each person to one licence. A property that is not the operator’s primary residence is not eligible. No annual night cap applies.

Miami operates under a Florida state licence from the Department of Business and Professional Regulation. Florida statute (FS 509.032) preempts municipalities and counties from imposing duration or frequency restrictions on vacation rentals, so there is no locally imposed night cap. The licence requirement and applicable state taxes are set at the state level.

Seattle requires two licences under Seattle Municipal Code Chapter 6.600: a Business License Tax Certificate and an STR Regulatory Operator License. Most operators are limited to a maximum of two dwelling units, combining their primary residence and one secondary property. Renters may not obtain STR operator licences except for a narrow set of legacy units in the Downtown Urban Core.

Vancouver operates under two overlapping layers. The BC Short-Term Rental Accommodations Act, effective May 1, 2024 in communities of 10,000 or more including Vancouver, restricts STR to the host’s principal residence, with a limited allowance for one secondary suite or accessory dwelling unit on the same property. On top of that, the City of Vancouver requires a business licence, with the licence number displayed on all listings.

Paris and Porto both operate under national registration frameworks. In France, a national digital pre-registration platform became operational by May 20, 2026 (Decree 2026-196 of March 19, 2026); every operator must obtain a 13-character registration number displayed on all listings, and co-ownership bylaws must explicitly authorise STR use since November 2024. In Portugal, the Alojamento Local regime requires prior electronic notification via the Balcao Unico Eletronico to obtain an RNAL/RNT registration number before operating.

Washington DC is the one market in this set where the licence type determines whether a night cap applies. Hosts who are present on the premises during guest stays hold a Short-Term Rental licence, with no annual night cap. Hosts who are absent and give guests exclusive property access hold a Vacation Rental licence, which is capped at 90 nights per calendar year and 30 consecutive nights per stay. Both types restrict operation to the operator’s primary residence.

Sydney and Toronto both combine a registration or licence requirement with a fixed annual cap; they are covered in the next section.

San Diego requires a Short-Term Residential Occupancy licence under its STRO ordinance, but its tiered structure means the cap column shows “None”; that case is explained after the cap section below.

The four night caps are not the same number

Four markets set a fixed annual cap. The scope of each one differs.

London allows a primary residence to be let for up to 90 nights per calendar year without planning permission, under section 44 of the Deregulation Act 2015. Exceeding 90 nights constitutes a material change of use requiring planning permission from the relevant borough. London is also the only market in this set with no licence requirement: a national registration scheme is enabled in law under the Levelling-up and Regeneration Act 2023, but no operational scheme had been brought into force as of 2025.

Paris caps primary-residence lets at 120 nights per calendar year under Article L. 324-1-1 of the Code du tourisme, as amended by Loi 2024-1039 of November 19, 2024. Municipalities may reduce this to a minimum of 90 nights per year by reasoned resolution. Paris pairs its cap with mandatory national pre-registration. London and Paris both limit primary residences, but Paris has a registration requirement and London does not, and Paris’s cap stands at 120 rather than 90.

Sydney caps non-hosted short-term letting at 180 days per year across the Greater Sydney region under the NSW STRA framework effective November 1, 2021. “Non-hosted” means the operator is not on the premises during the guest stay. Hosted stays, where the operator is present, are not subject to the 180-day cap. Sydney combines the cap with a mandatory NSW STRA Register requiring annual renewal and fire-safety compliance.

Toronto also caps at 180, but the limit applies to entire-unit rentals, where the operator is absent and guests have exclusive access. Partial-unit rentals where the operator remains on site carry no annual night cap. Toronto also restricts operation to the operator’s principal residence and pairs the cap with a municipal registration requirement.

London and Paris both cap primary-residence lets, at different numbers. Sydney and Toronto both arrive at 180 for operator-absent configurations, but draw the scope differently: non-hosted in Greater Sydney versus entire-unit in Toronto. None of the four figures is interchangeable.

What “None” covers in constrained markets

San Diego’s “None” requires a note. The City’s STRO ordinance creates four tiers. Tier 1 (Part-Time) limits operators to a maximum of 20 days per calendar year without requiring the host to be present. Tiers 2, 3 and 4 do not impose a single annual night cap; their constraints come from host-presence rules and minimum-utilisation requirements. Because no single annual cap applies across the market, our methodology records “None.” The absence of one number does not mean the absence of limits.

Washington DC’s “None” reflects the licence-type split described above. The Short-Term Rental type imposes no annual night cap. The Vacation Rental type is capped at 90 nights per calendar year. One market, two licence types, two different cap situations; “None” records the absence of a single across-the-board cap.

What this means if you operate across markets

• Do not assume a night cap exists. In 11 of these 15 markets the binding control is a licence, a registration requirement or a zoning rule, not a night count.
• Read the cap’s scope, not just its number. Whether 180 nights applies to you in Sydney or Toronto depends on whether you are present during stays and whether the rental is a partial unit or an entire unit. London’s 90 and Paris’s 120 both hinge on primary-residence status.
• Primary-residence rules are a separate constraint from night caps. Several markets restrict STR to the operator’s principal residence independently of whether a night cap applies. Denver, Nashville (owner-occupied tier), Toronto, Vancouver and Washington DC all do this.
• Tax layers are a separate moving part. Several of these markets layer a local accommodation tax or levy on top of the licence requirement. Edinburgh introduced a Visitor Levy of 5% on the first five consecutive nights of a stay, effective July 24, 2026. Nashville operates a multi-component local occupancy tax. Rates and effective dates appear on each tracker page and change independently of licence conditions.

Limits of this data

We would rather you trust this comparison because we are clear about what it is and is not.

• This is a comparison of recorded rules, not of enforcement or of how operators actually behave. A market requiring a licence tells you nothing here about how many listings hold one.
• “None” in the night-cap column is a statement about the absence of a single fixed annual cap across the market, not about the absence of any limit. Tiered day thresholds, zoning restrictions and licence conditions all constrain how a property may be used.
• Each entry was verified as of its own date, shown on the relevant tracker page. Regulations change; a cap can be modified and a levy can take effect between our verification and your reading.
• Fifteen markets is the current floor, not a sample of the world. We add a market to this comparison only once we have verified it against official sources, which is why the count grows slowly.

Reproducibility

This report is mechanical. The comparison table and the coverage summary below are produced by our open script from the same verified tracker entries, so the same data lands on the same table every time. As we verify more markets, they enter this comparison automatically and the counts move with them.

Tracker coverage (verified markets)	Figure
Markets independently verified	15
Require a licence or registration	14 of 15
Impose a fixed annual night cap	4 of 15
Official sources verified across all markets	57

Every figure traces back to a verified tracker entry, and every tracker entry traces back to the official sources it was checked against.