Does our crew accommodation count as a short term rental?

Why the length of the stay became a legal question

For years the only questions a booker asked about a crew apartment were how many beds, how close to site and how much. Regulation has quietly added another one, and it is the one that now decides whether a unit can be let to you at all: how many nights.

Regulation (EU) 2024/1028 has applied since 20 May 2026. Where a country or city runs a registration scheme, platforms must let hosts display a registration number, carry out reasonable checks on it, and transmit activity data such as nights booked and guest numbers to a national single digital entry point, normally every month. The Regulation does not cap anything by itself. What it does is make short term letting visible, which is the precondition for everything that follows.

Where the line is being drawn

Poland is the clearest example, and it matters because Poland is one of Europe's busiest project markets. The bill adopted by the Council of Ministers on 14 July 2026 and now before the Sejm treats the letting of a dwelling to a single customer for no more than 30 days as a hotel service. It creates a Central Register of Tourist Accommodation Facilities, requires a registration number in every listing, sets house rules and fire and safety requirements, and provides for administrative fines of up to PLN 50,000, roughly EUR 11,600. On 2 September 2026 the government restored two provisions that had been dropped: housing communities and cooperatives will be able to prohibit short term letting in their own building, and municipal councils will be able to designate zones where it is restricted or banned. Three confirmed breaches of safety or public order rules in six months and the property comes off the register, with re-registration only possible after a year.

The same length of stay logic already exists elsewhere in other clothing. In France a primary residence may be let as furnished tourist accommodation only for a capped number of nights a year, registration is required, and in Paris a second home cannot be let that way at all. Barcelona intends to stop renewing tourist apartment licences from 2028. In Edinburgh, unique short term listings fell by around 39% between 2019 and 2024 as licensing arrived, and occupancy in the longer stay sector there rose from 81% to 86%.

On 9 September 2026 the European Commission proposed the Affordable Housing Act, which gives authorities a common methodology for identifying areas under housing stress and clearer legal ground to restrict short term letting in them. It aims at commercial scale hosts holding several dwellings and lets people letting their own home alone. A further short term rental initiative is signalled for the fourth quarter of 2026.

Which side of the line is a crew on?

Mostly the regulated side. In our own aggregate booking data, the median stay is 15 nights, 64% of stays run under 30 nights and 82% under 90, across 91 cities in 15 countries [Bonjour Residences OS, September 2026]. That is the honest shape of mobilisation work: a fortnight of commissioning, a four week shutdown, a six week fit out. Almost all of it falls inside the definitions these rules use.

Two consequences follow. First, the unit your crew sleeps in has to be legitimately registered where registration applies, and you should be able to see the number. Second, that stock is the exact stock being reduced, which is why availability near a project site keeps getting worse even in markets where nothing was built or demolished.

The cheapest fix is the structure of the stay

Where the work allows it, the most effective compliance and availability tool is not a better search. It is a longer, differently structured stay. Past the point where a let is a lease or a contract with an owner or operator rather than a tourist booking, the registration regime, the building level bans and the municipal zoning restrictions stop applying to it. A single contract for eight weeks in one building is also the version an owner will reorganise capacity for, which a chain of nightly bookings is not.

The paperwork around the crew is tightening at the same time. The Commission's Fair Labour Mobility package of 15 September 2026 would digitalise the A1 posting document, give the European Labour Authority better risk assessment to target cross border inspections, and route posting declarations through one standard EU form. On a continent with 3.64 million posted workers, that means accommodation arrangements are more likely to be looked at, and looked at sooner.

What to ask before you book

• How many nights is this stay, and does that number put it inside the short term rental regime in this country or outside it?
• Is the property registered where registration applies, and can the registration number be shown?
• Who is the counterparty, a platform host or the owner or operator, and what is the contract?
• If the project overruns, can the stay be extended in the same units, or does the booking have to be rebuilt in a market that is now short?

The point is not that short stays are illegitimate. It is that a 15 night booking and a 15 week booking are now two different legal products, and only one of them is exposed to the wave of restrictions arriving across Europe. Deciding which one you are buying belongs at the start of the mobilisation plan, not in the week before the crew flies.