Cape Town has published a draft Short-Term Letting By-law. If it passes as written, properties that are available for short-term letting more than half the year get reclassified as commercial, whether or not they were ever booked.
Anyone can comment. Below is a letter you can copy, change and send. It takes about five minutes.
Use the button below. It copies the whole thing.
Cut what does not apply. Add your own occupancy figures or circumstances. A letter in your own words carries more weight than fifty identical ones.
Paste it into an email to STL@capetown.gov.za, or use the City's online comment form. Keep a copy of what you send.
Comment on the draft Short-Term Letting By-law, 2026
I am the owner of a short-term rental property within the City of Cape Town municipal area. I submit this comment in terms of section 17 of the Local Government: Municipal Systems Act, 2000.
I am not opposed to the regulation of short-term letting. I support registration, I support the City holding accurate data, and I have no objection to displaying a registration number on my listings. My objection concerns one thing only: the measure used to classify a property as commercial.
A property may be listed for most of the year and still trade far below commercial occupancy, because demand in Cape Town is seasonal. Being available to accept a booking is not the same as receiving one. An availability test rates a property on theoretical capacity rather than actual commercial activity, and treats a quiet year exactly like a full one.
Section 7(1)(d) of the draft already requires booking platforms to share occupancy data with the City. The more accurate measure will already be in the City's hands. I ask that section 8 be amended to classify on actual occupancy over a rolling twelve-month period.
The City's public materials are inconsistent. The Have Your Say page refers to property used for short-term letting for more than 50% of annual room-night capacity. The FAQ refers to property available for more than 50%. Section 8 says neither. Used and available are different tests, and the difference decides whether an owner is reclassified. That must be settled expressly in the by-law, and settled as occupancy.
A hotel facing higher rates can add rooms or spread the cost across more keys. I cannot add bedrooms without land-use approval. A commercial rating therefore applies a commercial cost to a fixed residential revenue base, on a valuation that reflects a residential dwelling rather than a commercial asset.
If classification turns on availability, the rational response is for owners to block half the calendar. That withdraws accommodation during the quieter months, when the City is working to grow off-peak visitor numbers, and returns no unit to the long-term rental market. An occupancy test does not create that incentive.
[OPTIONAL: add your own detail here. Your actual occupancy over the past twelve months, why the property is not viable as a long-term rental, who you employ, or what this rates increase would mean for you.]
I ask that section 8 be amended accordingly. Thank you for the opportunity to comment.
Yours faithfully
[FULL NAME] | [EMAIL] | [CONTACT NUMBER]
Nothing has passed. This is a draft, out for comment. The wording can still change, which is the entire reason the comment window exists.
Nothing changes this season. The City has confirmed that any change to property rating categories only takes effect from 1 July 2027, and the draft provides for a grace period on registration.
Registration is not the problem. I think a registration system is fair and overdue. The problem is one word in one section, and that word is still up for debate.