On November 7, 2022, the European Commission (EC) published its proposal for a regulation on data collection and sharing for short-term accommodation rental services (proposal). The proposal includes data sharing and website design requirements for online platforms providing short-term accommodation rental services. It also prompts EU countries to create a harmonized registration process for hosts providing such services.

Government-Issued Registration Numbers

The proposal aims to harmonize transparency and data sharing requirements for online short-term rental platforms that are currently subject to diverging national and local rules. In particular, the proposal harmonizes the registration process through which hosts obtain a unique registration number per property that they intend to list on a short-term accommodation rental platform. To obtain this unique registration number, hosts must share data about themselves (such as their name, national identification number, and contact details) and their property (such as the address of the property, the type of property, and whether the unit is offered as a part or whole of the host’s primary or secondary residence) with the public authorities that allocate these numbers.

Platforms must display hosts’ government-issued unique registration numbers on every listing for short-term accommodation. This obligation complements the requirement of the new EU Digital Services Act to design online interfaces in a way that enables certain information to be displayed and illegal listings to be taken down.

The proposal also requires platforms to conduct random checks to verify whether a registration obligation applies to a host, and whether a host uses a valid registration number. Platforms must share the results of such checks with the relevant public authorities and the hosts concerned. Authorities could order platforms to remove listings that do not have a valid registration number.

Data Sharing Obligations

The proposal requires platforms for short-term rentals to share with public authorities, at a country level, the following data: the number of nights a unit was rented out, the number of guests per unit, the government-issued registration number of each unit listing on the platform, and the web address (URL) of the unit listings. Platforms would need to share this data on a monthly basis via automated processes (e.g., though an application programming interface (API)). Public authorities would be allowed to share the data in an aggregated and anonymized way with others such as researchers and statistical offices.

Micro and small platforms that do not reach a monthly average of 2,500 hosts in the EU would benefit from a lighter regime. They would need to share data less frequently (quarterly) and would not be obliged to use automated means to supply the data. These platforms would be allowed to report manually (e.g., via email).


The platform economy has upended the short-term accommodation rental sector. Across the EU, national economies have been affected in different ways. This led to a fragmentation of data-gathering initiatives by public authorities. The proposal offers a welcome harmonization. Also, the availability of anonymized aggregated data should—according to the proposal—benefit local communities and SMEs providing services like cleaning or property management. Aggregated data that could in the future be made available with sector-specific dataspaces could also offer business opportunities to data aggregators. For instance, these data aggregators could provide insights derived from the aggregated data to other service providers, such as restaurants or tourist guides.

For more information, please contact Laura de BoelCédric BurtonJindrich KloubBeau Buffier, or any member of the firm’s data protection and antitrust practices.