In short: The first Edinburgh short-term let operators to hold 3-year licences are now into renewal. The renewal process has proved more substantive than the "light-touch" description suggested. Operators should not treat renewal as a formality, and should prepare for the process with the same seriousness as the original grant.
When Edinburgh's licensing scheme was launched, one of the more welcome features was the ability - in principle - for operators to hold a 3-year licence, on the basis that a light-touch renewal would follow. Three years on, the first cohort is now discovering what "light-touch renewal" means in practice, and it is not always what operators expected.
What renewal actually looks like
Three observations stand out from the renewals we have supported through the summer.
First, the Council is treating renewal as an opportunity to re-examine each unit against the current condition set, not simply against the conditions that applied when the licence was granted. Where conditions have been updated in the intervening three years - as several have - renewal effectively requires the operator to demonstrate compliance with the new position, not the old one. This is not the light-touch process operators were led to expect.
Second, the Council is more willing than expected to attach additional conditions on renewal. We have seen additional conditions imposed relating to waste management, key handovers, and, in a small number of cases, occupancy caps. Operators should not assume conditions will roll forward unchanged.
Third, the planning status question is now being raised more frequently at renewal. Where an operator does not hold planning permission or a Certificate of Lawfulness for the use, the Council is increasingly asking why not - and, in some cases, using the answer to that question to inform its consideration of the renewal application.
What operators should do
1. Do not treat renewal as a formality. Prepare with the same seriousness as the original application. 2. Read the current condition set carefully. Do not assume the conditions that applied to the original licence are the conditions that apply to the renewal. 3. Address the planning question in advance of renewal. If you do not hold a Certificate of Lawfulness or planning permission and the property qualifies for one, get the application under way before renewal is submitted. It is materially better to be able to answer the planning question with "yes" than with "not yet". 4. Do not leave the renewal to the last minute. Where a renewal is more substantive than the operator expected, having time to respond to Council questions is important.
What this means for the second cohort
The second cohort - the operators whose original 1-year licences were replaced with 3-year licences during 2024 - will begin coming up for renewal through late 2026 and into 2027. That cohort should learn from the experience of the first: prepare early, address planning status in advance, and do not assume renewal is a formality.
The trend, on the Council side, is unlikely to soften. The renewal process is a moment at which the Council can revisit its position on any given unit, and it is now demonstrating a willingness to do so.
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Ross Armstrong Head of Professional Services, STL Solutions
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