Short-term Letting in the City of Cape Town
This is a draft by-law, not law. The City of Cape Town published its draft Short-Term Letting By-Law, 2026 for public comment in August 2026, and comment closes on 5 October 2026. Quotations below are from the published draft. Where this article goes beyond what the draft says, it says so. General information, not legal, tax or rates advice.
Read the proposal: the full draft by-law (PDF) · the City’s executive summary (PDF) · how to comment before 5 October
If you let a property short-term anywhere in the City of Cape Town, this draft by-law is the thing to read this year. It does three separate things, and most coverage collapses them into one.
- It makes registration compulsory, and puts your registration number on every listing.
- It makes the City a recipient of your calendar data, continuously, from the platforms.
- It sets a 50% threshold that decides whether your property is rated as residential or commercial.
The third is the one that costs money. The first is the one that arrives first. This is the overview; the threshold has its own article because the maths deserves the room.
Who it applies to
Section 3 is broad, and deliberately so. It covers owners and operators of property listed on a booking platform, anyone who “manages, markets, offers, or makes available a property or part of a property for short-term letting… for reward,” and — this is the part people miss — any booking platform that “facilitates, enables, advertises, promotes or publishes listings.”
“Part of a property” matters. Letting one room is in scope. So is a cottage on the same erf — and because the erf is the unit, that cottage is counted against the whole property’s capacity, which is its own article.
And “booking platform” is defined widely enough to catch far more than Airbnb: “any online marketplace, mobile application or intermediary service that facilitates transactions between owners or operators and guests for accommodation services.” A direct-booking website that takes reservations is doing exactly that.
Registration, and the number on every listing
Section 4 is the operative one, and it is unusually specific about who must do what.
“No owner or operator may use, advertise, or list a property for short-term letting unless the property has been registered with the City and the City-issued registration number is displayed on all listings associated with the property.”
— s 4(2)
Note the order. Registration comes before advertising, not after your first booking. And the obligation attaches to all listings, not your main one.
The draft then loads a matching set of duties onto platforms:
- s 4(3) — the platform must let owners capture the registration data for each listing.
- s 4(5) — the platform must share that data with the City.
- s 4(6)–(7) — the City verifies it and issues a unique number per property, to both the platform and the owner.
- s 4(8) — “A booking platform must ensure that the City-issued registration number is clearly displayed on every listing.”
- s 4(9) — the platform must “keep and maintain accurate records of all registered properties listed on its platform and make such records available to the City.”
- s 4(10) — a platform “may not display or advertise any property (a) that is not registered with the City; or (b) where the unique registration number is not displayed.”
Read s 4(10) twice if you run your own booking site. It is not a duty to nag the owner. It is a duty not to publish.
Section 5 adds the other end: on transfer of ownership the City may cancel the registration and tell the platform, and the Municipal Valuer re-categorises the property. A number that came with the house is not yours.
What the City will be collecting
Section 7 lists the data the City will receive:
“(a) the physical address of the property…; (b) the municipal account number as reflected on the municipal account; (c) the availability data of each listing on a booking platform; (d) the occupancy data of each listing on a booking platform; and (e) any other data relevant to the implementation of this By-law.”
The City may also “determine the format and frequency” of that sharing, and s 13 allows it to contract directly with platforms to implement and monitor the by-law.
This changes the posture entirely. Your availability is not a number you will be asked to self-report at year end. It is a feed.
The 50% threshold
Section 8 is short and expensive:
“All properties that meet or do not exceed the 50% of total annual room nights threshold may be regarded as residential property… All properties that exceed the 50% of total annual room nights threshold will be regarded as commercial property and property rates will be levied accordingly.”
— s 8(2)–(3)
Two honest caveats, because they are load-bearing and the draft simply does not resolve them.
“Total annual room nights” is defined, but circularly. Section 1 gives it as “the maximum annual capacity of a property for short-term letting” — capacity, without saying how capacity is counted. Bedrooms × 365 is the common reading, and the arithmetic in the threshold article uses it, but the by-law does not say it.
Availability or occupancy is not specified. Section 7 collects both. Section 8 says which threshold, not which measure. A flat listed all year that sells thirty nights is at 100% on one reading and 8% on the other. Plan for the availability reading: it is the worse outcome, it is the one you control, and the data is being collected either way.
The rates consequence itself lives in the City’s Rates Policy, not in this by-law — the by-law only says rates “will be levied accordingly.”
Enforcement
- s 9 — no owner or operator may let contrary to the by-law; no platform may advertise or facilitate letting in contravention of it.
- s 10 — an authorised official may issue a compliance notice naming the provision contravened, the remedy, and the period to comply.
- s 11 — offences include advertising or listing contrary to the by-law, failing to display a valid registration number, and using a cancelled number. Penalty: “a fine or imprisonment of up to six months, or both.”
- s 12 — the City may also seek an interdict, in addition to criminal proceedings.
Section 11 applies to “any owner, operator or booking platform.” The exposure is shared.
Section 17 provides for transitional arrangements, so there should be a grace period — but its length is for the City Manager to announce, not something to plan around.
What to actually do before 5 October
- Comment. It is a draft. The two unresolved points above are exactly what public comment is for, and “maximum annual capacity” needing a definition of its own is worth a submission.
- Find your availability number. Not your occupancy — your availability, as the union across every channel over a rolling 365 days. Most hosts cannot produce it, which is the real problem.
- Get ready to hold a registration number per property and to show it everywhere the property is advertised, including your own site.
- Decide, deliberately, which side of 50% you want to be on. Crossing it is not illegal; being reclassified by accident is just expensive. If you are running a commercial operation, run it properly.
How Airflow handles it
Two pieces, and they map onto the two halves of the by-law.
The calendar half. Airflow’s letting-limit gauge measures availability as the union across every connected channel plus your own bookings and blocks, over a rolling 365 days, with Cape Town (draft 2026) as a preset alongside London’s 90 nights, Amsterdam’s 30 and Paris’s 90. It forecasts the date you cross rather than only telling you afterwards, and it produces a per-property statement that distinguishes days it actually observed from days reconstructed from your bookings. The mechanics are in the threshold article.
The registration half. A registration number belongs to the property, so it lives on the property — set it once in the resource’s settings and it appears wherever that property is published: its Airflow Stay listing, its direct-booking site, and the guest-facing pages. That is the shape s 4(2) and s 4(8) require, and it is the only shape that survives you adding a fourth sales channel.
If you would rather think about this as a general problem than a Cape Town one — night caps are spreading, and a night cap is an accounting problem, not a calendar problem. Cape Town is unusual only in attaching a rates bill rather than a fine.
Sources
- City of Cape Town, draft Short-Term Letting By-Law, 2026, published for public comment August 2026. Comment closes 5 October 2026.
- STBB, Unpacking the City of Cape Town’s proposed Short-Term Letting By-law.
Verify against the City’s own published draft before acting. Section numbers above refer to the August 2026 draft and may move before adoption.