Property portals, rentals and short-term lets

• Regulation (EU) 2024/1028 — data collection and sharing on short-term rentals
• Regulation (EU) 2022/2065 — DSA
• Regulation (EU) 2016/679 — GDPR, Article 27
• Directive 2011/83/EU — consumer rights

Who has to appoint one

Platforms outside the Union listing property or short-term rentals to users in the EU. The short-term rental Regulation adds registration-number verification and data sharing with national authorities, and the DSA adds trader traceability and notice-and-action duties.

Thresholds and exemptions

Small platforms get relief from some DSA duties but not from the legal representative. The short-term rental Regulation applies to online platforms in that sector regardless of size, with lighter data transmission duties for smaller ones.

What must appear on the label

Not physical. What must be shown is the host's registration number where the member state or municipality requires one, the trader or non-trader status of the host, the total price including mandatory fees, and the representative's identity in the privacy notice.

Marketplace fields

Cities across the Union operate registration schemes, and platforms have been fined for listing unregistered properties. The new Regulation harmonises the mechanics from May 2026 but does not remove the local rules themselves.

Documentation you must hold

Article 30 records covering host and guest data, the Article 27 designation, DSA trader verification and notice-and-action records, the arrangements for transmitting activity data to national single digital entry points, and tenant screening documentation where credit or background checks are performed.

Standards and testing

Not applicable, though tenant screening algorithms have been challenged as discriminatory and must be examined for that risk.

Language requirements

Listing information, terms and complaint procedures in the language of each market served.

When it applies

The DSA since February 2024. The short-term rental Regulation applies from 20 May 2026, with registration-number checks and monthly data transmission.

How long records are kept

Host and guest data per the transmission obligations and the contractual period. Tenant screening data must be minimised and deleted once the decision is made.

What happens if you do not comply

DSA penalties up to 6% of turnover, national fines under the short-term rental rules for listing unregistered properties, and GDPR fines for the processing. Cities have also obtained delisting orders directly.

Who enforces it

Digital Services Coordinators, national and municipal authorities for short-term rental registration, and data protection authorities.

Where the boundary lies

Tenant screening is the sharpest data issue: processing income, employment and credit data about prospective tenants requires a solid basis and, in several member states, is restricted by national housing law. Discrimination law applies independently of the GDPR.

Questions we are asked

Do we have to check host registration numbers?

From May 2026 the Regulation requires platforms to enable and verify registration numbers where the member state operates a scheme, and to transmit activity data monthly.

Is tenant screening lawful?

It depends on what is processed and on national housing law. Blanket credit and background checks without a specific justification have been found excessive.