Short-term lets, Airbnb and the Universal opportunity: What does it mean for planning permission in Bedfordshire?
Kippen Ash | Planning Advice | November 2026
Some of you may have seen the proposed changes to the rules surrounding short-term holiday lets and Airbnb properties in England.
With the Government’s mandatory national registration scheme expected to come into effect in March 2027, there is understandably a lot of discussion about what this means for property owners, landlords and those considering entering the holiday accommodation market.
But there is another important question that shouldn’t get lost amongst the headlines:
Does using a property as a short-term holiday let actually require planning permission?
And, with the construction of the new Universal UK Resort underway in Bedfordshire, could there be opportunities for property owners to make better use of existing buildings and accommodation?
Let’s look at what is changing, when a change of use might be required and why understanding the planning position could be particularly important for anyone considering investing in property locally.
1. The Universal opportunity: Could Bedfordshire property owners benefit from the construction phase?
One major development that property owners and potential investors across Bedfordshire should be keeping an eye on is the new Universal UK Resort in Bedford Borough.
A project of this scale brings with it a substantial construction workforce, including contractors, specialist trades, engineers, project managers and other professionals who may need temporary accommodation close to the development while working on site.
The project's planning documentation anticipates a peak construction workforce of approximately 5,380 workers during winter 2029. Of these, the assessment estimates that between 1,080 and 1,535 workers could require temporary accommodation during the peak construction period.
Naturally, this raises interesting questions about the potential opportunities within the local accommodation market. GOV.UK
For property owners, landlords and investors, it may be worth exploring whether existing properties, larger residential buildings or suitable vacant premises could offer potential accommodation opportunities during this period.
However, it is important to understand that the project has specific arrangements in place to monitor the demand for local accommodation.
Under the approved workforce accommodation strategy, the use of serviced accommodation by construction workers will be monitored. If the agreed threshold of 535 serviced accommodation rooms being used by project workers within the core study area is reached, mitigation measures will be required. These could include the provision of dedicated temporary workforce accommodation.
Importantly, this is a monitoring and mitigation threshold, not a restriction on the number of properties that can offer accommodation locally. Nor does it guarantee that demand will translate into bookings for individual landlords or property owners. GOV.UK
This means there may be opportunities for existing property owners and accommodation providers, but demand should not be assumed or treated as guaranteed.
There are also important planning considerations. Not every property will necessarily be suitable, and the planning implications will depend on the proposed use, the nature and frequency of occupation, the scale of accommodation and the property's existing lawful use.
For example, occasionally letting an existing residential property may present very different planning considerations from operating a property continuously as commercial accommodation for a rotating construction workforce.
Similarly, converting a larger property or redundant building into dedicated workforce accommodation could require a more detailed planning assessment, particularly where the proposed use differs significantly from its existing lawful use.
It is also worth remembering that the opportunity does not necessarily end when construction is complete. Once operational, the resort is expected to create thousands of permanent jobs and attract millions of visitors annually. This could provide further opportunities for suitable accommodation providers, although the resort's own accommodation provision and the wider local market will also influence demand.
The opportunity is not simply about buying a property and putting it on Airbnb. It is about understanding the potential of existing buildings and properties, identifying viable uses and establishing what may be achievable through the planning system.
At Kippen Ash, we can help property owners, developers and prospective investors explore these possibilities, assess whether a change of use may be required and identify the appropriate planning route before committing to significant expenditure.
With a development of this scale taking place locally, now could be a good time to start exploring the possibilities and understanding what your property might be capable of accommodating.
2. What is changing for short-term lets?
The Government is introducing a mandatory national registration scheme for short-term lets in England, which is currently expected to begin in March 2027.
The intention is to create a register of short-term holiday accommodation, giving local authorities greater visibility of properties being used in this way and helping improve oversight of the sector.
Owners of qualifying properties will need to comply with the registration requirements once the scheme comes into force. The scheme is intended to make it easier to identify short-term lets and improve the information available to local authorities.
However, it is important to understand that registration is not the same as planning permission.
Registering a property does not automatically establish that its use is lawful under planning legislation. Equally, having planning permission does not remove the need to comply with any separate registration requirements once the scheme comes into force.
These are two separate regulatory considerations, and property owners need to be aware of both.
The current Government guidance, last updated on 2 October 2026, confirms that the registration scheme is not yet in force and is expected to begin in March 2027. GOV.UK
3. Do I need planning permission to operate an Airbnb or holiday let?
This is where things become a little more interesting.
Under the current planning system in England, there is no blanket requirement for every property being used as a short-term holiday let to obtain planning permission.
The key consideration is whether the change from its established residential use to short-term visitor accommodation amounts to a material change of use.
Planning legislation does not provide a simple numerical threshold for determining when this happens. Instead, it is a matter of fact and degree, assessed on the individual circumstances of each property.
In other words, simply advertising a property on Airbnb or another holiday accommodation platform does not automatically mean that planning permission is required.
The question is whether the nature and character of the property's use have changed sufficiently to constitute a material change of use.
This is an important distinction, particularly for homeowners who occasionally let out their property or a spare room.
A property continuing to function as somebody's home may present a very different planning situation from a property operating exclusively as commercial visitor accommodation.
The Government's planning consultation documents also recognise this distinction, explaining that occasional letting of a room or a whole home while the owner is away may be different from a property operating as a series of short-term lets. Ultimately, the individual circumstances still need to be considered. GOV.UK
4. When does a short-term let become a material change of use?
There is no magic number of nights that automatically triggers a change of use across England.
Instead, the local planning authority will consider the circumstances and characteristics of the use.
Some of the factors that may be relevant include:
Frequency of occupation: Is the property occasionally let out, perhaps when the owner is on holiday, or is it continuously available for paying guests throughout the year?
Turnover of guests: Are there frequent changes of occupants, with guests arriving and departing every few days?
Intensity of use: Does the property accommodate significantly more people or generate more activity than would normally be expected from a residential dwelling?
Impact on neighbours: Is there increased noise, disturbance, parking pressure or activity associated with the use?
Nature of the accommodation: Is the property still functioning as somebody's home, or has it effectively become commercial visitor accommodation?
Scale and layout: Is it a single room within an occupied family home, an entire dwelling or a separately functioning annexe capable of accommodating several guests?
No single factor will necessarily determine the outcome. It is the overall picture that matters.
For example, somebody renting out a spare bedroom occasionally through Airbnb while continuing to occupy the property as their main home is likely to present a very different planning situation from somebody purchasing a residential property specifically to operate it as a full-time holiday let.
Likewise, a property that is available for paying guests throughout the year, with frequent guest turnover and little or no residential occupation by the owner, may be more likely to raise questions about whether its use has materially changed.
The important thing is not to assume that all short-term lets are treated equally.
5. Is there a 90-night limit?
This is one of the biggest areas of confusion.
You may have seen references to the 90-night rule, which is often discussed alongside Airbnb and short-term letting.
However, this rule currently relates specifically to London.
Under the Greater London Council (General Powers) Act 1973, as amended by the Deregulation Act 2015, residential premises in London can generally be used for temporary sleeping accommodation for up to 90 nights in a calendar year without planning permission, provided the relevant statutory conditions are met.
One of those conditions is that the person providing the accommodation must be liable to pay council tax at the property.
Beyond the permitted 90 nights, planning permission is required.
Outside London, there is no equivalent national 90-night rule currently in force.
This means that property owners in Bedfordshire, Hertfordshire, Buckinghamshire and elsewhere in England should not assume that they automatically need planning permission after 90 nights.
Equally, they should not assume that they can operate a property as a full-time holiday let without planning permission simply because they are outside London.
The material change of use test still applies.
So what about the proposed national 90-night flexibility?
The Government has previously announced its intention to introduce greater flexibility for homeowners to let out their main or sole home for up to 90 nights a year without requiring planning permission.
However, this is part of the wider proposed planning reforms and should not be confused with the existing London provisions.
The proposed changes also include a new planning use class for short-term lets and associated permitted development rights, which would give local authorities greater control over the growth of short-term accommodation in areas where it is causing concern.
Until the relevant planning legislation is formally brought into force, property owners should not rely on these proposals as an existing right.
For anyone considering investing in a holiday let or operating an existing property, the current planning position remains the starting point. GOV.UK
6. Are councils actually taking action against short-term lets?
Yes, and this is something worth paying attention to.
Although there is no blanket national ban on short-term holiday lets, local planning authorities can investigate properties where they believe the use has moved away from ordinary residential occupation.
There are a number of reasons why this is attracting attention.
In areas experiencing pressure on the availability of residential housing, councils may be concerned about properties being removed from the longer-term housing market and converted into visitor accommodation.
There can also be concerns about the impact of frequent guest turnover on neighbouring properties, particularly where entire houses or larger accommodation units are being operated commercially.
One interesting example is the Planning Inspectorate appeal concerning Haymakers Barn in Westmorland and Furness, decided on 22 December 2025.
The council had issued an enforcement notice alleging an unauthorised material change of use involving a holiday-let annexe within a residential property.
The owners appealed, and the Inspector ultimately allowed the appeals and quashed the enforcement notice.
What makes this case particularly interesting is the Inspector's consideration of how the property actually functioned.
The annexe was used as holiday accommodation but was also used by the owners as part of their family home when it was not being let. The Inspector considered factors including the property's layout, its relationship with the main dwelling, the scale of the accommodation, guest turnover and the evidence of its actual use.
The Inspector concluded that, on the evidence presented, the character of the short-term holiday letting was not materially different from its use as a dwellinghouse.
However, this decision should not be interpreted as meaning that holiday letting is automatically lawful or that councils cannot take enforcement action.
The Inspector specifically recognised that a larger property capable of accommodating more guests could potentially amount to a material change of use. The decision also confirmed that further enforcement action could be possible if guest turnover or other circumstances changed sufficiently.
Importantly, the enforcement notice was quashed following consideration of the legal grounds of appeal, including the evidence that no material change of use had occurred in this particular case. It was not a blanket approval of holiday letting, nor did it establish a general exemption for annexes. acp.planninginspectorate.gov.uk
The case is useful because it demonstrates why local planning authorities must assess the actual nature and characteristics of a use rather than simply assuming that advertising a property as holiday accommodation automatically constitutes a breach of planning control.
For property owners, the key point is that enforcement action must be supported by evidence of a breach of planning control.
7. Where are councils most likely to be looking?
There is no single national list of areas where councils are actively pursuing short-term holiday lets. Enforcement activity is a local matter, and the level of attention will vary between authorities.
However, there are some circumstances where planning scrutiny is particularly relevant:
Popular tourist destinations: Areas where there is a high concentration of holiday accommodation and pressure on the availability of permanent housing.
Coastal and rural communities: Particularly where the conversion of residential properties into visitor accommodation could affect the character and sustainability of local communities.
Areas with housing shortages: Where local planning policies seek to protect existing residential accommodation.
Residential neighbourhoods: Where frequent guest turnover is generating complaints about noise, parking, waste or general disturbance.
Properties operating as commercial accommodation: Particularly where an entire dwelling has effectively become a business rather than continuing to function as a home.
This doesn't mean that councils in these areas will automatically refuse holiday let proposals. It means that the planning considerations may be more sensitive, and owners should understand the relevant local planning policies before proceeding.
For property owners in Bedfordshire and surrounding areas, it is worth remembering that the absence of a specific local restriction does not remove the need to consider whether a material change of use has occurred.
8. What about permitted development rights and proposed planning changes?
There has also been discussion about introducing a new planning use class specifically for short-term lets, alongside permitted development rights to allow certain changes between residential use and short-term visitor accommodation.
The Government announced its intention to introduce these measures in February 2024, with the aim of providing greater clarity and consistency while giving local authorities more control over the growth of short-term lets.
The proposals include:
A new planning use class for short-term lets that are not somebody's main or sole home.
Permitted development rights to allow certain changes between residential use and short-term visitor accommodation.
Powers for local planning authorities to remove those permitted development rights where there are justified local concerns.
Greater flexibility for homeowners to let out their main or sole home for up to 90 nights a year.
However, it is important not to confuse proposals with legislation that is already in force.
As things currently stand in November 2026, the proposed national planning changes have not been brought into force. The existing material change of use test therefore remains central to assessing whether planning permission is required.
Property owners should check the current planning position rather than relying on proposed future changes when making investment decisions. GOV.UK
9. What should you do if you're considering operating a holiday let or temporary accommodation?
If you are thinking about purchasing a property specifically to operate as a holiday let, converting an existing property or changing the way you currently let accommodation, it is worth considering the planning position before committing financially.
We would recommend:
Checking the property's existing lawful planning use and any relevant planning conditions.
Reviewing the planning history to establish whether there are any restrictions on holiday accommodation or independent use.
Considering how the property will operate in practice, including occupancy, frequency of bookings and whether it will remain somebody's home.
Reviewing the relevant local planning policies and any applicable Article 4 Directions.
Seeking advice from the local planning authority or a planning consultant if there is uncertainty about whether planning permission is required.
Where the position is unclear, it may be appropriate to consider applying for a Lawful Development Certificate to obtain formal confirmation of the lawfulness of an existing or proposed use, depending on the circumstances.
It is also important to remember that planning is only one part of the picture.
Registration, taxation, business rates, fire safety, gas and electrical safety, insurance and other regulatory requirements may also apply. Property owners should consider these separately before commencing operations.
10. So, do you need planning permission?
Ultimately, there is no one-size-fits-all answer.
An occasional letting of your own home may be perfectly acceptable without a change of use, whereas a property operating almost exclusively as commercial holiday or temporary accommodation could raise entirely different planning considerations.
The important thing is to establish what is actually happening at the property, how that use differs from its established residential use and whether that difference is significant enough to amount to a material change of use.
Our advice? Don't make assumptions based on what somebody else's property is doing, or what you have read online. Every property and its circumstances are different.
At Kippen Ash, we understand that navigating the planning system can sometimes feel complicated, particularly when legislation, guidance and proposed changes are being discussed at the same time.
Whether you are considering purchasing a property as a holiday let, exploring temporary workforce accommodation opportunities, converting an existing building or simply wanting to establish whether your current use requires planning permission, we can help you understand your options and identify the appropriate next steps.
If you're in doubt, get in touch. No question is too big or too small, and we'd much rather help you establish the planning position at the outset than find yourself dealing with an unexpected planning issue further down the line.
Kippen Ash – Making the planning process a little less complicated.
Further information and useful resources
For anyone wanting to explore the subject further, the following Government and planning resources provide a useful starting point:
GOV.UK – Letting out a self-catering holiday home in England: rules and regulations .
GOV.UK – Delivering a registration scheme for short-term lets .
GOV.UK – Introduction of a use class for short-term lets and associated permitted development rights .
Bedford Borough Council – Universal United Kingdom Resort .
Universal UK planning submission – Project Planning Statement .
Planning Inspectorate – Haymakers Barn appeal, reference APP/K0940/C/25/3373154 .