Finance and compliance

Do we need a registration number for the apartments our crew stays in?

Fan Zhang
·
August 31, 2026
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4
min read
Short answer

Since 20 May 2026, Regulation (EU) 2024/1028 requires online platforms to display and verify a registration number on short-stay listings in any Member State that operates a registration scheme, and to suspend listings that do not have one. Getting the number is the host's legal obligation, but the consequence of a missing one lands on your project: a suspended listing days before mobilisation. Bonjour Residences checks registration status before a contractor booking is confirmed, and books longer project stays through direct owner and operator contracts, where the short-stay regime often does not apply in the same way.

Short answer: if the accommodation is listed on a platform and sits in a country or city with a registration scheme, then yes, that property needs a valid registration number, and since 20 May 2026 the platform has to display and verify it. The obligation belongs to the host, not to you as the booker. The disruption, though, is entirely yours.

What changed on 20 May 2026

Regulation (EU) 2024/1028 started applying across the EU on 20 May 2026. It does not legalise or ban short-term rentals anywhere, and it does not create an EU-wide licence. What it does is build the plumbing: registration procedures must be online, hosts receive a unique registration number per property, platforms must display and verify that number, and platforms must send monthly listing-level activity data to a national Single Digital Entry Point. Authorities can order a non-compliant listing to be taken down.

In practice a listing without a valid number, in a country that requires one, cannot stay up. France uses a 13-digit Declaloc number, Spain the NRA, Italy the CIN, Portugal the RNAL, Greece the AMA. The numbers were always there in theory. Verification at platform level is the new part.

Why a construction booker should care about someone else's paperwork

Because enforcement removes beds from the market you were planning to use, and it removes them without warning. Paris lost 12,696 active Airbnb listings in the twelve months to May 2026, a 22.9 percent drop, driven by pre-deadline enforcement. That is not a compliance story for a project manager. That is supply.

The second effect is timing. Our own aggregate booking data shows a median lead time from enquiry to check-in of four days across 47 cities in 16 countries. Four days is not enough time to react when a listing is suspended and forty people are already travelling. The thinner the compliant platform stock in a project town, the more expensive a late scramble becomes.

Does the regime even apply to a three-month project stay?

Often not in the same way, and this is the part most bookers miss. Registration schemes are aimed at short-stay tourist letting. Many national and municipal rules define the regulated activity by stay length, by number of nights let per year, or by tourist use. A crew that occupies an apartment for eleven weeks under a direct contract with the owner or a professional operator is frequently outside the tourist-let definition altogether, and is instead a mid-term or residential letting with its own tenancy and tax treatment.

So the honest answer to the question is layered. If you book through a platform, the registration number matters and you should be able to see it in the listing. If you book the same building directly, on a contract written for a project stay, you are usually in a different regulatory box, with more security of tenure and, in our experience, better commercial terms for stays beyond a month.

The market underneath the platform

The wider numbers point the same way. Savills counted 86,911 serviced accommodation rooms across 26 European gateway cities in 2026, around 8 percent of total accommodation supply, while demand for longer stays has compounded at 5.9 percent a year since 2019 against 1.1 percent for hotels. HVS put occupancy at 81.9 percent in 2025 with average rate softening to 145 euros. Demand is growing faster than the visible, bookable, platform-listed supply, and regulation is trimming the informal end of that supply.

What is left is a market that is not searchable. Buildings owned by landlords who never list, operators who fill by relationship, apartment blocks that take a whole floor for a mobilisation and never appear on a platform at all. That is where most of our contractor stock sits. Our aggregate figures show a median stay of 19 nights and a mean of 52, which tells you how often a project runs long and why a booking has to be able to extend without renegotiating from scratch.

There is a second compliance layer people forget

If you provide the accommodation to posted workers, the conditions of that accommodation are a host-country employment term under Directive (EU) 2018/957, alongside allowances or reimbursement for travel, board and lodging. The European Commission's 2024 review found that twelve Member States have national provisions on accommodation conditions that apply to posted workers, while twelve do not legislate it and leave it to collective agreements. So the standard your crew is housed to is not only a welfare question. In half of the EU it is enforceable law in the country the work happens in.

What to actually do

  • If a listing is your fallback plan, check the registration number is displayed before you commit. Since 20 May 2026 its absence is a suspension risk, not a technicality.
  • For anything over about a month, ask for a direct contract instead of a platform booking. Different legal box, better terms, and it survives a project overrun.
  • Write the accommodation standard into the assignment paperwork if you are posting workers, because in half the EU the host country already has a view on it.

Tell us the headcount and the window, and we will come back with compliant options and the paperwork behind them.

Sources
  • European Commission, Regulation (EU) 2024/1028 on data collection and sharing relating to short-term accommodation rental services, applying from 20 May 2026.
  • AirROI, Paris short-term rental market analysis, 12 May 2026.
  • Savills, European extended-stay market report, April 2026.
  • HVS, European extended-stay performance review, 2026.
  • Directive (EU) 2018/957 amending Directive 96/71/EC, Article 3(1); European Commission, COM(2024) 320, 2024.
  • Bonjour Residences aggregate booking data, 47 cities in 16 countries, reviewed August 2026.
Last reviewed
August 31, 2026

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