THE STATE OF SHORT-TERM RENTAL REGULATION IN CANADA

THE STATE OF SHORT-TERM RENTAL

REGULATION IN CANADA

A COMPARATIVE ANALYSIS OF 25 MUNICIPALITIES

Anna I. Cameron and Dr. Lindsay M. Tedds

Department of Economics, University of Calgary

Prepared for The City of Calgary

Updated October 2023

This research paper was produced as part of the City of Calgary–Urban Alliance Agreement made

effective on 12 January 2023 (Research Services File Number 1060024).The City of Calgary is

collaborating with researchers at the University of Calgary (UCalgary), under the Urban Alliance

partnership, on a multi-year study of Calgary’s short-term rental market. The goals of the study are

to build a comprehensive evidence base on Calgary’s STR market (including impacts, challenges,

and opportunities), and to use this information to recommend a tailor-made STR policy framework

for Calgary that can be adapted as market conditions change. Engagement with Calgarians and

interested parties is an important component of the Short-Term Rental Study. The authors thank

the City of Calgary for funding this work.

3 
 
TABLE OF CONTENTS 
INTRODUCTION ................................................................................................................................................... 4 
SECTION 1: UNDERSTANDING STR POLICY ........................................................................................................ 6 
THE POLICY TOOLBOX .......................................................................................................................................... 6 
A FRAMEWORK FOR STR POLICY ........................................................................................................................ 7 
SECTION 2: A BIRD’S-EYE VIEW OF STR POLICY IN CANADA .............................................................................. 9 
MUNICIPAL POWERS AND THE CONSTITUTIONAL CONTEXT ............................................................................. 9 
STR POLICY IN 25 CANADIAN MUNICIPALITIES .................................................................................................. 9 
SECTION 3: POLICY GOALS, DEFINITIONS, AND PROHIBITIONS ....................................................................... 13 
POLICY GOALS .................................................................................................................................................... 13 
DEFINITIONS AND PROHIBITIONS ..................................................................................................................... 18 
SPATIAL RULES, QUOTAS, AND MORATORIUMS ............................................................................................... 19 
SECTION 4: LICENSING SYSTEMS AND OPERATIONAL AND SAFETY STANDARDS .......................................... 24 
LICENCE TYPES ................................................................................................................................................... 24 
APPLICATIONS, OPERATIONAL RULES, AND GUEST SAFETY STANDARDS ..................................................... 27 
EXTENDING REGISTRATION FRAMEWORKS ..................................................................................................... 28 
SECTION 5: TAXATION ....................................................................................................................................... 32 
SALES TAXES ....................................................................................................................................................... 32 
PROVINCIAL TAXES ON TOURIST ACCOMMODATION ....................................................................................... 33 
MUNICIPAL TAXES .............................................................................................................................................. 35 
SECTION 6: COMPLIANCE AND ENFORCEMENT ............................................................................................... 38 
SOFT STRATEGIES .............................................................................................................................................. 38 
LICENCE-ORIENTED MEASURES ........................................................................................................................ 38 
TRADITIONAL ENFORCEMENT: COMPLAINTS, AUDITS, AND INSPECTIONS .................................................... 39 
PLATFORM ENGAGEMENT ................................................................................................................................. 39 
SECTION 7: BRINGING IT TOGETHER ................................................................................................................ 43 
A TYPOLOGY OF CANADIAN RESPONSES .......................................................................................................... 43 
PROMISING PRACTICES ..................................................................................................................................... 45 
GAPS AND OPPORTUNTIES ................................................................................................................................ 46 
CONCLUDING THOUGHTS ................................................................................................................................. 48 
REFERENCES .................................................................................................................................................... 50 
REFERENCED LEGISLATION AND BYLAWS ....................................................................................................... 55 
 

INTRODUCTION

The emergence and continued growth of the short-term rental market has produced many

tensions in communities around the world.

Over the past decade, digital peer-to-peer accommodation platforms have expanded and

transformed the practice of home sharing internationally, producing not only a distinct STR market,

but also a marked change in how we travel and share space. However, the rise of platform-driven

home sharing has been contentious, with the growing STR market garnering dichotomous

characterizations (Dolnicar 2017; Guttentag 2015; Tedds et al. 2021). That is, while it is lauded as

a source of economic benefit and social innovation (Finck and Ranchordàs 2016; Sigala and

Dolnicar 2017), and is celebrated for its responsiveness to consumer preferences and needs

(Guttentag et al. 2018), the market is also viewed as an unwelcome agitator by the hospitality

industry (Benner 2017; Zervas, Proserpio, and Byers 2017), a driver of increased noise and

nuisance in neighbourhoods (Gurran and Phibbs 2017), and a contributor to rising gentrification

(Wachsmuth and Weisler 2018), housing unaffordability (Barron, Kung, and Proserpio 2021; Li,

Kim, and Srinivasan 2022), and over-tourism (Cocola-Gant and Gago 2019).

These tensions are both a consequence of and exacerbated by the fact that much of the STR

activity unfolding in urban areas today challenges notions of home, community, and economy. In

doing so, the STR market encourages new configurations of use and ownership, and actively

contributes to the rearticulation of patterns of urban interaction and development (Davidson and

Infranca 2015). The implications for urban policy, planning, and governance are wide-reaching. For

example, some scholars describe the present iteration of the STR phenomenon as a form of

disruptive innovation, as it alters existing regulatory and planning practices, complicates liability,

and outpaces legislation (Guttentag 2015; Interian 2016). It is therefore unsurprising that the STR

market and its attendant tensions, pressures, and challenges have sparked a proliferation of policy

responses in recent years – most often at the local level – where authorities are seen to be on the

front lines of STR activity and its impacts.

Governments have struggled to regulate short-term rentals effectively.

Effective management of the STR market has been an enduring challenge. Not only has the

platform economy more broadly caught planning scholars and practitioners “on the back foot” (Kim

2019, 261), but its novel structure, activity, and effects also confound standard regulatory

approaches. For one, STR activity does not always map neatly to traditional frameworks and

processes; instead, interactions and effects can occupy grey areas in terms of land use, economic

undertakings, and legality (Johal and Zon 2015; Tedds et al. 2021; Zale 2016), requiring the

delineation of new definitions, categories of activity and use, and most importantly, policy and

regulatory approaches. Authorities also report significant enforcement challenges, since detection

of STR operations can be difficult, local governments may not have sufficient resources and

capacity to address the nature and scale of market activity, and the comprehensive data needed

for effective enforcement are held by platforms (Colomb and Moreira de Souza 2023; Ferreri and

Sanyal 2018; Gurran and Phibbs 2017; Leshinsky and Schatz 2018). Finally, the policy and

governance issues raised by the STR market implicate several orders of government and are multi-

faceted, requiring coordination across a range of planning, policy, and legal sub-fields on matters of

property rights, land use, consumer protection, taxation, health and safety, competition, community

planning, and more (Vith et al. 2019).

Most cities in Canada are currently grappling with short-term rental policy, whether by

introducing regulations for the first time or by making changes to existing rules.

These tensions and challenges also apply to Canada’s STR market, which has grown considerably

in recent years. This growth has been met with a significant policy push: as of 2023, major cities in

most Canadian provinces, along with many smaller municipalities and towns, had adopted STR

regulations of some variety. Research on STR policy in the Canadian context is fairly limited,

however, with most scholarship maintaining a focus on major urban destinations in Europe and the

United States (Guttentag 2019). As policymakers across Canada continue to grapple with the STR

phenomenon, a strengthened evidence base regarding both the current state and nature of STR

regulation in Canada, as well as gaps, challenges, and promising avenues for reform, will be crucial

to devising effective and equitable policy and governance responses.

This report builds on growing interest in and movement on short-term rental policy in

Canada and is organized around two objectives.

The report is divided into seven sections. Section 1 — Understanding STR Policy — provides a broad

overview of STR policy aims and approaches, and sets out a useful way of thinking about the range

of strategies, policies, laws, and regulations that make up the instrument mix (or policy toolbox)

available to governments for managing the STR market. In Section 2 — A Bird’s-Eye View of STR

Policy in Canada — we introduce the 25 municipalities examined in the report and provide high-

level information about the presence or absence of regulations in these jurisdictions. Sections 3

through 6 compare STR policy in Canadian municipalities across four categories: policy goals,

A handful of policy reports (Jamasi 2017; Jamison and Swanson 2021) have examined Canadian regulations, but

there is no peer-reviewed research on the topic. Canadian research is largely focused on pricing (Gibbs et al. 2018);

tourism sector impacts (Guttentag et al. 2018; Sovani and Jayawardena 2017); spatial trends in listings and housing

implications (Combs, Kerrigan, and Wachsmuth 2020); and links to gentrification and financialization (Grisdale 2019).

To assess the first major wave of STR market policy in Canada through a

comparative ‘stock-taking’ of approaches adopted in 25 municipalities.

To draw comparisons and distinctions across responses to inform a discussion

about trends, policy considerations, and wise practices—in Canada and beyond.

definitions, and prohibitions; licensing systems and standards; taxation; and compliance and

enforcement strategies. In Section 7 — Bringing It Together — we synthesize the results of our

analysis, discussing promising or wise practices, gaps, and opportunities.

1. UNDERSTANDING STR POLICY

THE POLICY TOOLBOX

Experts have identified a broad array of policy, planning, legal, and regulatory measures and tools –

which we refer to collectively as the STR policy toolbox – from which authorities draw to piece

together management approaches for the STR market.

These tools and instruments span a

number of frameworks: zoning and land use planning (e.g., use classifications, spatial restrictions,

parking rules, etc.); tourist accommodation legislation and business licensing (e.g., permits and/or

registration, imposition of operational, safety, and insurance standards); and taxation (e.g.,

accommodation taxes, etc.). Compliance and enforcement measures – from soft mechanisms

involving public awareness campaigns and educational materials, to proactive audits and

inspections – also constitute a key element of STR policy.

Policy tools are used to manage STR activity in five key ways (Colomb and Moreira de Souza

2021)—what we view as policy strategies. These strategies include impacting and controlling the

existence, visibility, and quality of STRs; influencing the overall quantity and geographical

distribution of STRs; managing the distinction and balance between different types of STR

operations; influencing STR platform practices; and taxing STR activity appropriately. These

strategies can be thought of as aligning with or advancing one or more of the following broader

policy goals:

→ managing local impacts (e.g., availability of rental housing ) and preserving neighbourhoods

→ upholding operational and safety standards, while advancing consumer protection

→ recovering community-level costs of STR operations; and

→ fostering high compliance.

Table 1 (p. 7) summarizes the connections among policy goals, strategies, measures and tools, and

the frameworks through which they can be introduced.

The scholarship that has shaped our understanding of STR policy and spans case studies (e.g., Ferreri and Sanyal

2018; Grimmer, Vorobjovas-Pinta, and Massey 2019; Lee 2016; Valentin 2020; Verdouw and Eccleston 2023),

comparative papers (e.g., Colomb and Moreira de Souza 2021; Dredge et al. 2016; Furukawa and Onuki 2019;

Hübscher and Kallert 2022; Jamasi 2017; Nieuwland and van Melik 2020; von Briel and Dolnicar 2020), and general

regulatory analyses (e.g., Finck and Ranchordàs 2016; Gurran and Phibbs 2017; Interian 2016; Jefferson-Jones 2015;

Leshinsky and Schatz 2018; Miller 2016).

TABLE 1: POLICY MEASURES BY GOAL, STRATEGY, AND RELEVANT FRAMEWORK

Policy Goal

Strategies

Example Measures and Tools

Relevant Frameworks

Manage local impacts

and preserve

neighbourhoods

Influence quantity,

spatial distribution of

STRs

Achieve balance

across STR types

Tiered licensing

Full or targeted prohibitions

Annual night caps

Licence quotas or moratoriums

Parking rules

Zonal/density-based restrictions

Zoning/Land Use Bylaw

Tourist Accommodation

Legislation/Regulations

STR/Business Licence Bylaw

Uphold operational and

safety standards;

advance consumer

protection

Impact/control

existence and quality

of STRs

Permit/registration system for

operators

Pre-licence inspections

Floor and safety plans

Informational requirements

Insurance requirements

STR/Business Licence Bylaw

Tourist Accommodation

Legislation/Regulations

Zoning/Land Use Bylaw

Recover community-level

costs

Tax STR activity

Accommodation tax

Broadening purposes towards

which tax revenues can be applied

(e.g., housing)

Tax Legislation/Regulations

Foster high compliance

Control visibility of

STRs

Encourage platform

practices

Audits

Public education campaigns

Registration databases

Requiring platforms to share data,

support enforcement (listing

removal, grey-outs, licence review)

Data Sharing Agreement or

Memorandum of Understanding

Tourist Accommodation

Legislation/Regulations

STR/Business Licence Bylaw

Note: Frameworks in bold are those over which Canadian municipalities generally have authority.

A FRAMEWORK FOR STR POLICY

A growing body of regulatory scholarship concerned with the STR market also addresses key

principles and priorities for designing policy frameworks – that is, in selecting from the policy

toolbox – with a focus on developing considered approaches attuned to local dynamics and

associated strategies; building a strong foundation through clear definitions and prohibitions;

prioritizing enforcement; and engaging platforms.

On the first point, scholars emphasize that there is no one-size-fits-all approach to regulation, and

that processes should differ by jurisdiction, particularly given the distinct consequences

interventions are likely to have (Gurran and Phibbs 2017; Nieuwland and van Melik 2018). To

ensure localized responses, jurisdictions can study community impacts (Major 2016) and

undertake policy mapping exercises (Dredge et al. 2016); these approaches can help authorities to

both understand market effects and complexities, as well as link actions and interventions to

specific impacts (Gottlieb 2013). Such information can also support targeted responses, such as

neighbourhood-level limits on use (Crommelin, Troy, Martin, and Parkinson 2018; Pearce 2016).

Others suggest aligning objectives and management with broader initiatives, such as tourism

strategies and destination planning (Gurran 2018), comprehensive community plans and goals

(Gottlieb 2013), and housing strategies (Crommelin et al. 2018).

Second, jurisdictions should, at the outset of strategy development and tool selection, establish

clear definitions and concepts (Dredge et al. 2016), distinguish between or among operator types

(Wegmann and Jiao 2017), and clarify and define use classifications for STR unit types within

planning frameworks (Crommelin et al. 2018; Pearce 2016).

Meaningful enforcement is another priority (Gurran 2018), and can be achieved by introducing

registration requirements that enable authorities to track compliance (Crommelin et al. 2018); by

resourcing dedicated enforcement staff (Leshinsky and Schatz 2018; Wegmann and Jiao 2017) or

forming a STR-specific group within administration (Allen 2017); and by undertaking targeted

enforcement (Major 2016). Some also argue that compliance rates may be improved by avoiding

overly burdensome regulatory schemes (Guttentag 2015; Major 2016), particularly as confusing

requirements spanning multiple frameworks and regulatory bodies can undermine voluntary

compliance on the part of operators (Leshinsky and Schatz 2018).

Finally, frameworks should impose greater obligations on platforms (Colomb and Moreira de Souza

2021; Finck and Ranchordàs 2016; Leshinsky and Schatz 2018; Pearce 2016). This could involve

agreements that require platforms to impose online controls or nudges (Guttentag 2015), including

sharing information about requirements with prospective operators, creating mandatory licence

fields, and deactivating listings after a night cap is met. Platform collaboration can also support

access to data on listing and

operator types, patterns of use,

and the nature of violations,

thereby enabling adjustment

as the market changes.

The adjacent diagram depicts a

multi-dimensional

understanding of STR policy,

which builds on the principles

and priorities discussed above,

and takes into consideration

the range of policy tools

available to authorities for

regulating STR activity. These

dimensions can be imagined as interlocking processes that can, when enacted together, support

comprehensive and strategic management of the STR market. This visual also reflects the

knowledge that, in practice, various components of STR policy are interdependent and mutually-

reinforcing. Later in the report, we’ll use these dimensions to structure our comparative analysis.

2. A BIRD’S-EYE VIEW OF STR POLICY IN CANADA

MUNICIPAL POWERS AND THE CONSTITUTIONAL CONTEXT

Though policymaking on the topic of the STR market has primarily taken place at the local level in

Canada, these efforts unfold within – and are likewise constrained by – the structures of Canada’s

federal arrangements. This not only means that all orders of government in have some role to play

in STR policy, but also that municipalities, given the constitutional division of powers, are limited in

what form their role can take. We need to be aware of these relationships and constraints when

examining the actions of local governments and thinking about new strategies and approaches.

One reason for examining the federal context is that a range of provincial, territorial, and federal

laws also apply to STRs, and therefore complement municipal rules within what can be viewed as

multi-level governance structures (even if they are not explicitly coordinated as such). These include

provincial legislation and regulations that establish and enforce licensing systems and operating

standards for tourist accommodation (including STRs), and federal and provincial/territorial taxes,

such as income, sales, and accommodation taxes, which apply to STR transactions. An

understanding of these frameworks and their interaction with local policies is necessary to piece

together an accurate picture of how the STR market is managed in Canada.

The federal context also reflects particular constitutional arrangements, which have the effect of

limiting how governments of different orders can contribute to policymaking. Specifically, Canada’s

constitution establishes municipalities as an area of provincial legislative competence, meaning

that local governments have legal authority over such areas as land-use, business licensing, and

taxation only to the extent that these powers have been devolved to them through provincial

statutes. These arrangements between provincial/territorial and municipal governments vary

considerably by province/territory and by municipal government (based on differences in size, role,

and function), and are often reflected in city charters. This feature of Canadian federalism

complicates the comparability of regulatory approaches, both within the Canadian context and

especially when looking at measures adopted internationally.

STR POLICY IN 25 CANADIAN MUNICIPALITIES

In this report, we compare STR management efforts in 25 Canadian municipalities across the four

dimensions of STR policy frameworks outlined in Section 1. We selected jurisdictions on the basis

of geographic and contextual representation, in an aim to represent not only the whole of Canada,

but also a range of urban contexts – from bustling metropolises like Toronto, to growing mid-sized

cities like Halifax, to mountain and resort towns that fuel domestic and international tourism. As a

result, our review includes all thirteen provincial/territorial capitals, plus the Canadian capital of

Ottawa; six municipalities that are not capitals, but which are the largest metropolitan centre in the

province; and five travel destinations of various kinds (e.g., mountain towns, summer vacation

hubs, tourist centres). Table 2 (p. 10) provides an overview of the presence and absence of STR

policies, including taxes, in the municipalities examined in the report. We supplement this with a

visual depiction of the evolution of STR policy in Canada over the past decade (Table 3; pp. 11-12).

TABLE 2: SNAPSHOT OF STR POLICIES IN CANADIAN JURISDICTIONS

Province/territory

Capital city

Large city

Tourist destination

BRITISH COLUMBIA▲

Victoria

Vancouver

Tofino

Kelowna

Whistler

ALBERTA▲

Edmonton

Calgary

Banff

SASKATCHEWAN

Regina

Saskatoon

MANITOBA

Winnipeg

Churchill ▲

ONTARIO

Ottawa▲

Hamilton▲

Niagara-on-the-Lake▲

Toronto▲

QUÉBEC▲

Québec City

Montréal

NEW BRUNSWICK

Fredericton▲

NOVA SCOTIA

Halifax▲

PRINCE EDWARD ISLAND

Charlottetown▲

NEWFOUNDLAND & LABRADOR

St. John’s▲

Legend

YUKON

Whitehorse

Accommodation Tax

▲

NORTHWEST TERRITORIES

Yellowknife

Measures in Force

NUNAVUT

Iqaluit

Measures Expected

Note: In British Columbia, the province oversees tax legislation; however, revenue is received and allocated locally.

As of September 2023, all municipalities in our review, with the exception of Whitehorse and

Winnipeg, had some form of STR policy in place — whether a tax, land-use rules, or a licensing

scheme — either locally or at the provincial/territorial level. Notably, four provinces — Quebec, Nova,

Scotia, Prince Edward Island, and Newfoundland — have adopted licensing systems for tourist

accommodation, including STRs.

Saskatoon and Winnipeg are the only provincial municipalities in

which an accommodation tax is not currently applied to STR bookings. In Winnipeg, Council has

approved a regulatory framework for STRs, which includes a licensing system and the extension of

the existing Accommodation Tax to STR bookings (City of Winnipeg 2023), and bylaw development

is underway (Unger 2023). In Hamilton, a licensing system will be launched in December 2023 and

enforced starting in January 2024 (City of Hamilton 2023).

This report does not consider legislation proposed recently in British Columbia through the Short-Term Rentals

Accommodations Act. For information, see https://www2.gov.bc.ca/gov/content/housing-tenancy/short-term-rentals.

TABLE 3: EVOLUTION OF STR POLICY IN CANADIAN JURISDICTIONS

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

proposed

Kelowna

Tofino

Vancouver

Victoria

Whistler

ALBERTA

Banff

moratorium

Calgary

amendments in force Jan’24

Edmonton

SASK.

Regina

Saskatoon

MANITOBA

Churchill

Winnipeg

Legend

licensing

zoning

ONTARIO

taxation

Hamilton

amendment

forthcoming

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

Niagara-on-

the-Lake

Ottawa

Toronto

QUÉBEC

Montréal

Several boroughs, which have authority over zoning, have introduced rules for STRs

Québec City

Fredericton

Only applies to tourist accommodation with 6+ rooms

Nova Scotia

Halifax

rental registry

PEI

Charlottetown

St. John’s

YUKON

Whitehorse

NWT

Yellowknife

NUNAVUT

Iqaluit

3. POLICY GOALS, DEFINITIONS, AND PROHIBITIONS

Effective policy frameworks for the STR market rest on the articulation of guiding principles,

objectives, and/or policy intent, as well as the establishment of clear definitions pertaining to the

market. Once these fundamental aspects have been determined, authorities can work to outline

operation types and market actors, as well as set dwelling-specific, use-based, and spatial

restrictions that advance principles and goals. Together, these decisions create a foundation from

which effective licensing, management, and enforcement can be pursued: they establish the

bounds of permissible activity given stated policy objectives and within the context of local

strategies, constituent policies, and the bylaws designed to enact them.

POLICY GOALS

Governments articulate policy goals in a number of ways. At the local level, city councils (or

individual councillors) can raise items for study and reform in response to emerging issues and

municipal goals, and often outline policy objectives at the same time. Policy rationale is often also

articulated through guiding principles or objectives for regulatory development put forward by

Administration in reports to Council. Municipalities also develop community plans, which establish a

vision, set out policies, guide the planning and regulatory strategies pursued within a jurisdiction,

and provide justification for the use of tools, such as zoning and business licensing. Depending on

the jurisdiction, these plans can specify direct policy actions on granular issues including STR

reform. Other strategic documents, such as housing strategies, can communicate clear policy

objectives and actions in a similar way.

Understanding the policy rationale and objectives guiding STR reform is useful when comparing

approaches across jurisdictions, as it can help link regulatory responses to key issues in the

market, as well as broader local dynamics. Such information can support comparisons across

jurisdictions, particularly in terms of establishing wise practices that account for local differences in

capacity, instrument availability, economic context, housing issues, and more. It can also support

assessments of the effectiveness and suitability of existing regulatory approaches: that is,

understanding policy intent is vital when assessing whether regulations are achieving their purpose.

In Table 4 (pp. 14-16), we summarize the core objectives informing STR policy in the 25

jurisdictions in our review. To establish a sense of policy intent and identify guiding objectives for

STR policies adopted in the jurisdictions in this review, we examined Community/Official Plans,

Council policies, staff reports to Council on STR reform, and housing strategies. Overall, this review

indicates that curtailing or preventing housing market impacts – particularly in the long-term rental

market – is a key policy objective for many jurisdictions, with over half of municipalities indicating

this as a policy objective in some way. Other common objectives include limiting impacts on

communities and neighbours (including in terms of noise and nuisance), ensuring ample tourist

accommodation to support local markets, and enabling primary residence STR income as a stream

of income for residents.

TABLE 4: OBJECTIVES DRIVING STR POLICY IN CANADA

Policy intent

Kelowna

Guiding Principles - Regulation: Protect LTR housing supply. Prevent negative impacts on neighbours. Ensure equity among STR providers. (City of Kelowna 2018)

Community Plan: Objective 4.14. Protect rental stock in Urban Centres / Policy 4.14.3 STRs: Ensure STR limits impact on LTR supply. Objective 5.13. Protect rental housing stock

(Core Area) / Policy 5.13.3. STRs: Ensure STRs do not negatively impact LTR supply. Objective 6.10. Prioritize construction of purpose-built rental housing (The Gateway) / Policy

6.10.5. STRs: Ensure STR limits impact on the LTR supply.

Housing Strategy: Actions - Update regulations to protect rental stock from impacts of STRs: Develop policy & regulations regarding STRs to address impacts to the rental market.

Tofino

Community Plan: Future Land Use: Restrict development of commercial accommodation, including STRs. Housing Policies: Discourage STRs in residential zones. Monitor vacation

rentals to ensure no negative impact on LTR stock, existing neighbours/neighbourhoods. (Corporation of the District of Tofino 2021)

Vancouver

Regulatory Goals: Bring STR industry into regulatory framework. Ensure PR requirement is met to protect LTR stock. Improve building, fire safety. Encourage neighbourhood fit.

Optimize enforcement & ensure regulatory equity. Increase public understanding of noncompliance repercussions. Harmonize compliance. Recover costs in long-term [Staff Report

to Council (City of Vancouver 2017)]

Housing Strategy: Ensure existing housing is serving people who currently or intend to live and work in Vancouver. Key Actions: Implement Short-Term Rental regulations to protect

long-term renters while also enabling homeowners and renters to make supplemental income from their principal residence.

Victoria

Housing Strategy: Goal One: Focus on Renters – STR Policy Review - Review the STR policy and proactive enforcement efforts and consider opportunities for directing program

revenue to affordable housing.

Whistler

Council Policy: Guiding Principles: Protect VA bed base; maintain warm beds; support visitor experience service quality; provide range of accomm types, arrangements; support

efficient property management, operations, maintenance & reinvestment; provide clarity & certainty regarding use requirements & rental agreements; remove RMOW from property

mgmt; prohibit nightly rentals in res. areas. Res. Accomm.: Maintain & reinforce zoning restrictions, business regs to prohibit TA use; Maximize use of res. properties to support

employee housing; Implement reg. changes that will facilitate active enforcement; Work with property mgmt companies, platforms, service providers to support zoning & business

regs; Enforce against illegal rentals using available tools & leg. powers. Amend business regs to prohibit marketing of illegal rentals, adopt available adjud. processes; Recognize &

maintain B&B, pension zoned properties within res. areas, but do not support new. Amend zoning for B&Bs to have onsite manager. (Resort Municipality of Whistler 2017)

Community Plan: Visitor Accommodation - "VA and tourist capacities have achieved a healthy balance. Nightly and TA have not displaced residential uses and housing in Whistler's

residential neighbourhoods. Goal - 5.5.l Maintain appropriate supply and variety of VA to support Whistler's sustainable year-round tourism economy. 5.5.1.3. Policy - Balance the

VA supply with Whistler's resort community capacity and growth management principles; 5.5.1.8. Policy - Actively enforce against illegal VA use of residential properties.

Banff

Land Use Bylaw purpose: To provide for orderly, economic, beneficial, & environmentally sensitive development of Town given objectives to: Maintain Town as part of World

Heritage Site; serve as a centre for accommodation & other goods & services for Park visitors; serve as centre for widest possible range of interpretive & orientation services to

Park visitors; maintain & enhance community character complementary to surrounding natural environment; provide comfortable living community for persons who need to reside

in the Town.

Calgary

Regulatory Goals: To ensure appropriate level of safety and regulatory oversight – business licence, land use, and safety code (fire and building) requirements, as well as bylaw

education and compliance measures – commensurate with scale and purpose [STR Scoping Report (City of Calgary 2018)].

Edmon

ton

Regulatory Goals: Edmonton’s short-term rental regulations aim to enhance livability in the city by streamlining rules for short-term rental operations while balancing the industry’s

interests with those of neighbourhoods and other businesses.

Regina

Regulatory Goals: Allow residents to rent out all/part of home on short-term basis; increase inspections for health & safety imposed by other legislation. Encourage compliance,

reduce enforcement costs by minimizing barrier, focusing enforcement on secondary properties. Address concerns about nuisance in neighbourhoods (City of Regina 2020)

Community Plan: Major Institutional Areas - 7.19 Encourage related housing, services and amenities, including hotels or short-term accommodations, to locate near or adjacent to

major institutional areas.

Saskatoon

Regulatory Goals: To update existing land use & licensing regulations to ensure they remain relevant to changing industry by amending standards in line with the scale of business

operation, while minimizing land use conflict, impact on residential characteristics of neighbourhoods, rental housing availability [Admin Report (City of Saskatoon 2022b)]

Niagara

-on-the-Lake

Regulatory Goals: To deliver on strategy to deliver Smart and Balanced Growth with emphasis on the accommodation industry. To ensure that the growth of STAs is well managed;

that licensing application process is clear, easy to understand, simple to process; that STAs contribute to a prosperous and diversified sector; that STAs contribute to town

infrastructure, add value to the industry and that the sector benefits not only the rental owners but residents as a whole:

• Ensure that traditional residential neighbourhoods are not turned into tourist areas to the detriment of long-time residents • Ensure any regulation of STRs does not negatively

affect property values (and property tax revenue)• Ensure homes are not turned into pseudo hotels or “party houses”• Minimize public safety risks and noise, trash and parking

problems often associated with STRs without creating additional work for Enforcement Officers or Niagara Regional Police department • Give permanent residents option to

occasionally utilize their properties to generate extra income from STRs as long as all of the above mentioned policy objectives are met and subject to all local by-laws• Any by-law

must be clear, precise, simple to understand and address these goals and objectives

Official Plan: STAs important part of cultural landscape, tourism infrastructure, economy of Town; will be regulated through zoning bylaw, site plan approval, licensing bylaw; must

not negatively impact agricultural production, remove land from production; STA in/near cultural heritage resources could contribute to conservation of character & provide

financial support for ongoing maintenance of heritage attributes. (Town of Niagara-on-the-Lake 2019)

Ottawa

Regulatory Goals: Maintain quality and character of neighbourhoods by mitigating nuisance, other negative effects; protect long-term housing availability and affordability for

residents [Staff Report – Short-Term Rental By-Law (City of Ottawa 2021)]

Official Plan: 4.2 Housing - 4.2.2 Maximize the ability to provide affordable housing throughout the city: In approving development, the City will […] strictly control the diversion of

LTR units and residential land to dedicated STR use, including through online sharing economy platforms that enable dwelling units to be rented to the travelling public.

Toronto

Regulatory Goals: Ensure safety for consumers and neighbours and promote quality of life in neighbourhoods; prevent decrease of availability and affordability of rental housing;

promote tourism by supporting innovation in the accommodations sector; ensure tourist accommodation providers have equitable regulations and tax requirements; allow

residents to occasionally rent their own homes for short periods; ensure rules and regulations are clear for residents, property owners and platforms [Staff Report (City of Toronto

2016)]

Montréal

Regulatory Goals (Province): 2021 Modernization: Reduce red tape, costs for operators. Simplify rules for better understanding and compliance. Support and equip municipalities

and Revenu Québec with the supervision of tourist accommodation. 2023 Amendments: Prohibit digital platforms from listing STRs without registration numbers or the expiry date

of the registration certificate, strengthen compliance with Act and Regulations; support Revenu Québec in the fight against illegal accommodation and municipalities in the

application of their regulations. Objectives: Remove from digital platforms listings with no registration number or number that is false, inaccurate, suspended or cancelled; Ensure

the validity of registration numbers displayed on listings on digital platforms; Enable customers to know whether the rented STR is registered and in accordance with municipal

regulations.

QC City

Regulatory Goals (City): Preserve historic & tourist districts, preserve quality of life for residents; remain attractive destination for visitors; provide diverse accommodation that

meets visitor expectations (STRs can be part of solution); consider perspectives of all stakeholders; provide feasible regulations that can be monitored, to facilitate compliance

[Guidelines - Tourist Accommodation Working Group]

Regulatory Goals (Province): Same as above (Montréal)

Halifax

Regulatory Goals (Province): Extend registration requirements to all operations (including those in a primary residence). The intent is to “help create a level playing field for

operators,” and to “provide clearer data about STRS, help municipalities identify short-term rentals in their communities to improve enforcement of bylaws.” [Rationale for recent

amendments (Tourism Nova Scotia 2022)]

Regional Plan: While STRs can provide unique opportunities for tourism, they can also have impact on LTR market if unregulated. HRM intends to provide consistent approach to

regulation of STRs throughout municipality to protect housing supply while still providing opportunities for tourist accommodations. HRM shall, through applicable land use by-laws,

establish special provisions to permit STRs in residential zones, where the STRs are located within the operator’s primary residence; and in zones where commercial tourist

accommodation uses are permitted (Halifax Regional Municipality 2022)

Charlottetown

Regulatory Goals (Province): Safety, cleanliness, education & prevention measures. Program protects consumers & PEI’s reputation as quality destination (Tourism PEI 2023)

Regulatory Goals (City): The proposed regulatory framework has been designed to provide opportunities for residents to benefit from the STR economy while establishing

appropriate measures that minimize the negative consequences of STR activities that impact housing, generate nuisances, and disrupt community harmony. The concerns of

ensuring the health and safety, consumer protection and the economic and social well-being of the municipality have been the focus of these proposed regulations.

Official Plan: Sustaining Neighbourhoods: Objective: support provision of suitable commercial & institutional needs, employment opps., community-based services, public

amenities. Policy: ensure STR in res. area restricted to operator’s PR, be of scale compatible with character of the surrounding neighbourhood. Supporting Home Occupations:

Objective: support creation, operation of B&B & tourist homes in all residential zones. Policy: require all operators of B&B & tourist homes be registered & licensed by Province &

City. [(Department of Planning & Heritage 2022)].

St. Johns

Regulatory Goals (Province): “For quite some time now, our tourism and hospitality stakeholders have been calling for a more level playing field between licensed and unlicensed

accommodations. While the new Act and regulations alone will not address all issues, it is an important step forward. The Department of Tourism, Culture, Arts and Recreation will

now be aware of all operators offering overnight accommodations, and will have the ability to provide regulation, improving our visitor experience.” (Government of Newfoundland

and Labrador 2023)

Yellow

knife

Regulatory Goals: The City needs an approach that maximizes the benefits of STR while managing impacts on neighbourhoods and providers of licensed accommodations.

Iqaluit

General Plan: While STRs can provide economic and tourism opportunities for the City and income for residents, they can also remove housing stock from the market, and impact

full-time residents. Policies: STRs shall be permitted in all residential zones and commercial zones where a dwelling unit is permitted; the use of any dwelling unit as a full-time STR

shall not be permitted, except for a STR contained in a secondary suite; the Zoning Bylaw will define STRs and contain provisions to ensure they do not create a nuisance [General

Plan (The Corporation of the City of Iqaluit 2020)]

TABLE 5: STR DEFINTIONS IN CANADIAN POLICY FRAMEWORKS

Definitions

Kelowna

STR Accommodation: The use of a dwelling unit or one or more sleeping units within a dwelling unit for temporary overnight accommodation for a period of 29 days or

less [Zoning Bylaw]

Tofino

STR: Use of a dwelling to provide tourist accommodation: that is, the commercial provision of temporary overnight accommodation to the traveling public for a period of

less than 1 month [Zoning Bylaw]

Vancouver

STR Accommodation: Temporary accommodation in a dwelling unit, or in a bedroom or bedrooms in a dwelling unit, but does not include temporary accommodation in

any Bed and Breakfast Accommodation or any Hotel [Zoning Bylaw]

Victoria

STR: Renting of a dwelling, or any part, for a period of less than 30 days - includes vacation rentals [Short-Term Rental Regulation Bylaw]

Whistler

Vacation rental business: Providing accommodation to paying guests in a dwelling unit, but does not include the rental of dwelling units for residential purposes for a

month or more under a residential tenancy agreement pursuant to the Residential Tenancy Act [Tourist Accommodation Rental Bylaw]

Banff

B&B Home: the single detached dwelling of an owner […], who is an eligible resident of Banff National Park, resides therein as principal residence, containing at least 1

bedroom for exclusive use and containing accessory guest accommodation in rooms for the purposes of supplying temporary living accommodation to the public, for a

fee. [Land Use Bylaw]

Calgary

STR: business of providing temporary accommodation for compensation, in a dwelling unit / portion of a dwelling unit for periods of up to 30 consecutive days [Business

Licence Bylaw]

Edmonton

Residential Rental Accommodation (Short-Term): Business that provides temporary lodging on premises where persons may rent all/part of a residential property for 30

consecutive days or less, including B&Bs, lodging arranged through home-sharing services [Business Licence Bylaw]

Regina

Short Term Accommodation: temporary accommodation in a unit/room/rooms in a unit, for a fee for a period of less than 30 days but does not include emergency

shelters operated by non-profits/ government institutions. [Short Term Accommodation Licensing Bylaw]

Saskatoon

Homestay: dwelling within principal residence of the host, in which rental accommodations are provided to guests for tenancies of less than 30 days.

STR property: dwelling that is not primary residence of host [Business Licence Bylaw]

Churchill

STR: renting out of a principal residence for a period to which the Residential Tenancies Act does not apply [Accommodation Provider Licensing Bylaw]

Niagara-on-the-

Lake

STR: use of a building for overnight guest lodging for a period of not more than 28 days and includes Bed and Breakfast Establishment, Cottage Rentals, Villas, Country

Inns, and Vacation Apartments [Bylaw for the Licencing, Regulating and Governing of Short-Term Rentals]

Ottawa

STR: transient accommodation in whole/part of residential unit for a period of less than 30 consecutive nights, and: marketed or brokered by a STR platform; not a

rooming house or hotel; includes B&B, cottage rental, Dedicated STR [Short-Term Rental Bylaw]

Toronto

STR: All/part of a dwelling unit used to provide sleeping accommodation for any rental period less than 28 consecutive days in exchange for payment; includes bed and

breakfasts, but not hotels or motels. [Licensing Bylaw]

Quebec

tourist accommodation: establishment in which at least one accommodation unit, such as a bed, room, suite, apartment, house, cottage, ready-to-camp unit or

campsite, is offered for rent to tourists, in return for payment, for a period not exceeding 31 days.

principal residence: establishments that offer, following a single reservation, accommodation in the principal residence of the natural person who operates the

establishment for one person or one group of related persons at a time.

general tourist accommodation: establishments other than principal residence establishments and youth tourist accommodation establishments that offer

accommodation in the form of one or more types of accommodation units, such as hotels, bed and breakfasts, tourist homes, cottages and outfitters [Tourist

Accommodation Act]

Montréal

commercial tourist home: establishment where accommodation is offered to the travelling public in a furnished residence with a kitchen, excluding accommodation

offered by a person in their home.

collaborative tourist home: establishment where accommodation is offered to the travelling public by a person in their home. [these definitions are established by

boroughs, and thus vary (the above is set out in the Urban Planning Bylaw for Le Plateau-Mont-Royal)]

Québec City

commercial tourist accommodation: rental of tourist accommodation to the public for payment for a duration of 31 consecutive days or less (not in a principal residence

– same class as hotels)

collaborative tourist accommodation: rental by an occupant of an entire residence, main room, or bedroom therein to tourists for a period of 31 consecutive days or

less.

Fredericton

STR Accommodation: A dwelling unit use in whole or in part to provide sleeping accommodation for a period of less than 28 days [Zoning Bylaw]

Nova Scotia

STR: Provision of roofed accommodation to single party or group, for payment or compensation, for a period of 28 days or less [Tourist Accommodations Registration

Act]

Halifax

Short-term rentals are dwelling units rented out by property owners or tenants that provide temporary overnight accommodation. Short-term rentals may be offered as a

rental of an entire dwelling unit, or in the form of a short-term bedroom rental, where individual bedrooms are rented out separately. This form of short-term rental is

often associated with bed and breakfasts, but can also include less formal types of tourist accommodation such as lodging houses [Regional Plan]

Prince Edward

Island

Tourist establishment: an establishment that provides temporary accommodation for a guest for a continuous period of < 1 month; includes building, structure, place in

which accommodation or lodging, with or without food, is furnished for price to travellers (cabin, cottage, housekeep. unit, hotel, lodge, motel, inn, hostel, B&B, resort,

travel trailer, vehicle park, houseboat, camping cabin, campground [Tourism Industry Act]

Charlottetown

STR: The rental of an entire dwelling unit or a portion of a dwelling unit that serves as the operator/host’s principal residence for a period of less than 28 consecutive

days and defined as a permitted use by way of a Tourist Home.

Tourist Home: Temporary accommodations for travelers or transients within a Principal Residence of the operator/host that is not a company or corporation for the

exclusive use of one (1) guest and their party of guests, such as a Short-term rental lodging but a Bed & Breakfast, Hostel, and Hotel are separate uses and separately

defined [Zoning & Development Bylaw]

Newfoundland

and Labrador

Short term rental: the provision of an accommodation for compensation to an individual or group of individuals for overnight lodging for a period of 30 days or less

[Tourist Accommodations Act]

Yellowknife

STR Accommodation: the business of providing temporary accommodation for compensation in a dwelling unit where persons may rent a portion or all of the premises

for 30 consecutive days or less [Business Licence Bylaw]

Iqaluit

STR: all or part of a dwelling unit used to provide sleeping accommodations for any rental period that is less than 30 consecutive days in exchange for payment and

includes a bed and breakfast but does not include a boarding house, hotel or shelter [Zoning Bylaw]

DEFINITIONS AND PROHIBITIONS

Once policy intent has been established, policymakers turn to zoning and licensing bylaws – and in

some cases, a bylaw or legislation specific to tourist accommodation or the STR market – to set

basic definitions (Table 5; pp. 16-17) and place limits on the scope, nature, and operation of STR

activity in line with set objectives (Table 6; pp. 22-23). Land-use designations and zoning, for

example, are tools used by local authorities to draw bounds around and manage the types, extent,

and spatial dimensions of land use in a given community and include stipulations regarding

building types and characteristics (e.g., size, height, external character, etc.), as well as the uses

that can be carried out within them. In the STR context, zoning is often used to preserve community

character, as well as limit the negative local impacts of STR activity, such as reductions in long-term

rental (e.g., by preventing commercialized STR operations in residential areas). Licensing bylaws

can also contain similar provisions, such as those which impose moratoriums on the granting of

new licences if vacancy rates fall below a certain level.

Most jurisdictions we reviewed have established residency-base rules, whereby restrictions are

placed on STR operations based on whether the unit is a principal residence or a secondary or

investment property. The restriction of STR operations to a host’s principal residence is one of the

primary mechanisms used by authorities to address community- and housing-level impacts of the

STR market, based on the rationale that commercialization of the market leads to the depletion of

long-term housing stock. Seven jurisdictions in our review (Vancouver, Victoria, Banff, Ottawa,

Toronto, Charlottetown, and Iqaluit) impose a firm restriction on commercial or secondary property

STRs, requiring that all operations take place in the permanent residence of the host.

However, in

all of these jurisdictions, one is permitted to operate an STR in an accessory or secondary dwelling,

provided that either the host occupies and is present in the principal dwelling on the property

(Banff, Charlottetown, and Iqaluit) or the dwelling serves as the host’s principal residence

(Vancouver, Victoria, Ottawa, Toronto). In other jurisdictions, such as Fredericton, principal

residence STRs are the only form of STR use permitted in residential zones.

Some jurisdictions also impose an additional layer of rules pertaining to entire-unit STR operations.

In particular, Banff prohibits entire-unit operations altogether—even if the host is simply out of town

and wishes to rent out their home. In Tofino, an STR can only be operated on a lot with two dwelling

units (i.e., a single detached home, secondary suite thereof, or caretaker’s cottage), and a

permanent resident must be present in the dwelling that is not an STR (though the Zoning Bylaw

contains an exception for townhouses in the CD(EL) zone, which can host up to five guests in the

absence of the resident. In several additional jurisdictions, entire-unit operations are restricted

In Victoria and Ottawa, regulations account for non-compliant operations that were previously authorized under former

rules, in some cases allowing such properties to operate STRs under legally non-conforming status. Further, in Ottawa

one is permitted to obtain a second licence for a cottage-based STR.

based on use type and zone, and are also subject to an annual night cap. We discuss these

elements below, in relation to spatial rules.

Finally, STR operations are permitted in most legal dwelling types, including single-detached homes,

apartments, duplexes, townhouses, and accessory units (e.g., basement, secondary, garden, and

laneway suites). However, several notable restrictions exist across jurisdictions. These include

explicit prohibitions in community/affordable housing (Vancouver and Ottawa); employee housing

(Whistler and Banff); apartments or multi-family dwellings (Tofino, Banff, and Charlottetown);

duplexes and townhouses (Tofino and Whistler), two-family dwellings (Tofino); secondary suites

(Kelowna); accessory and auxiliary dwellings (Kelowna, Tofino, Whistler, and Ottawa); buildings that

house a group home (Kelowna, Fredericton); and all buildings that are not occupied as a single-

detached dwelling for a minimum of four years (Niagara-on-the-Lake), with an exception for

vacation apartments. Further, regulations in some jurisdictions make specific mention of

prohibitions in a vehicle (Yellowknife, Toronto, Ottawa, Regina, Vancouver, Tofino, and Kelowna),

tent or temporary structure (Regina, Kelowna, and Tofino), and trailer (Regina and Ottawa). Overall,

it is notable that the majority of dwelling-based restrictions exist in those jurisdictions which are

smaller in size, have economies centred around tourism, and thus face particular challenges in

balancing visitor accommodation with resident quality of life and access to housing for the local

workforce.

SPATIAL RULES, QUOTAS, AND MORATORIUMS

In addition to the above restrictions, authorities impose zone- and site-based rules, licence-based

limits, and quantitative restrictions to mitigate the local effects of STR activity. This includes the

express prohibition of STRs—or at least certain types, such as secondary property STRs—in areas

with particular zoning (e.g., in residential areas); the designation of exception zones (e.g., a main

commercial street, plaza, or particular site) in which primary use STRs are permitted; the institution

of quotas and moratoriums; and the imposition of annual night caps on entire-unit rentals (as noted

above). These rules are also set out in Table 6.

In terms of spatial rules, notable jurisdictions in our analysis are Kelowna, Montréal, Québec City,

and Whistler. In Kelowna, the Zoning Bylaw was amended to only permit STR operations as a

secondary use within a dwelling unit: that is, as secondary to the applicant using the dwelling

primarily (more than 240 days per year) as a residence. However, the Bylaw also includes an

exception for dwellings located in areas designed to accommodate higher levels of tourist activity,

such as those zoned for high-rise apartment housing and hospital and health support services, as

well as tourist commercial use (e.g., comprehensive resort developments). In such areas, it is

permissible to operate a primary use STR, though on some sites, such operations are subject to an

annual night cap, given rules that require the unit to serve as long-term accommodation (either for

a month-to-month tenant or the owner) six months per year. Similar rules exist in several Montreal

boroughs, including Ville Marie, Plateau-Mont-Royal, and Rosemont-La-Petite-Patrie, where urban

planning bylaws have been amended to restrict the operation of what are deemed “commercial

tourist homes” (i.e., primary use STRs or “general tourist accommodation” in the provincial

framework) such that they are not permissible, save for in select commercial districts,

and even

then, not within a certain distance from existing tourist homes.

In Québec City, commercial tourist

homes are classed as a c10 use—the same category as hotels—and each borough has established

certain areas in which this use is either authorized or a conditional use (Ville de Québec 2022).

Whistler’s Zoning and Parking Bylaw and Tourist Accommodation Registration Bylaw carry out the

objectives of the Council Policy on Tourist Accommodation, balancing the housing and quality of life

needs of local residents and workers, with the demands of a tourism-centric (and outdoor sport

driven) economy. Part of this requires maintaining ample and attractive accommodation for

tourists, athletes, and workers. As a result, land use designations strictly prohibit tourist

accommodation operations in most residential areas, limiting nearly all such operations to

designated tourist accommodation zones. There is one exception, however, which permits in select

residential zones the use of townhouses and detached residences as temporary accommodation

for 10 guests or fewer.

Very few jurisdictions in Canada impose quantitative restrictions, such as quotas and night caps, on

STR operations. Only four municipalities—Kelowna, Toronto, Québec City, and Iqaluit—have placed

limits on bookable nights, beyond the effective limits that exist in some jurisdictions as a result of

primary residence requirements. Further, when compared to international jurisdictions that also

impose such restrictions, the 180-night limits in Iqaluit and Toronto are generous, with cities such

as San Francisco and London capping the bookable nights at 90 days for entire-unit listings, and

Amsterdam limiting such bookings to 30 days (Pforr et al. 2021, 124). Banff is the only municipality

in which there is a firm STR quota, with the Banff Land Use Bylaw establishing a cap of 65 on the

number of STR licences, which are then allocated across residential districts (Schedule D).

However, other jurisdictions have found ways to introduce flexibility into quota-like approaches to

allow for adjustments in the face of emerging issues and shifting market dynamics. In Regina and

Saskatoon, for example, licensing bylaws include particular provisions for secondary property STRs

that place a moratorium on the granting of new licences if the city’s vacancy rate falls below three

per cent, and which do not allow more than 35 per cent of the dwelling units in a multi-dwelling

structure to be primary use STRs.

Development Permits and Approvals

In general, development permits are either waived or not required for STR operations across

jurisdictions in our analysis. However, in Banff, Saskatoon, Edmonton, Montréal, Québec City,

Commercial tourist homes are limited to Plaza St-Hubert (Rosemont-La-Petite-Patrie), parts of St-Laurent and St-Denis

(Plateau-Mont-Royal), and Ste-Catherine between St-Mathieu and Rue Atateken (Ville Marie).

In Ville-Marie, for example, such STRs must be 250 metres apart.

Ottawa, and Halifax—dependent on the zone and STR use type—STRs are, instead of being

outlawed outright, deemed a discretionary or conditional use, and thus require approval through a

development permit process prior to licensing and registration can be completed.

Banff is an outlier in our review, given the requirement that all STR operations obtain a

development permit prior to being approved for operation. This involves the applicant submitting

proof of ownership or owner consent; a property and unit description; floor and site plans; photos;

and information regarding any proposed signs. In Saskatoon, discretionary use approvals are

necessary for primary use STRs in certain zones. Here, the application requirements are similar to

those that exist in Banff. Development officers reviewing applications consider the suitability of the

proposed use in terms of conformity with the Community Plan, as well as a number of STR-specific

metrics, such as the suitability of the proposed use in the location, impact on the character of the

neighbourhood, and the cumulative impact of other discretionary uses on residential

characteristics. In Edmonton, a development permit for a major home-based business is required

for live-in hosts who wish to operate an STR with more than two sleeping units. If proposed in a

zone in which the operation is a permitted use, the application involves submitting information on

the proposed business, expected visits per week, and a site plan noting the scale of the proposed

operation. If a discretionary use, a traffic impact assessment is also required. These applications

can be denied if the use is deemed to be disruptive of residential character. Rules are similar in

Halifax for STR bedroom operations: if one wishes to offer several rooms for rent in one’s primary

residence while serving as a live-in host, one must obtain a development permit. In Montréal and

Québec City, zoning rules are implemented at the borough level, and in some cases, those wishing

to operate a primary use STR may need to obtain an occupancy permit prior to being granted a

provincial licence. In Victoria, assessments are only conducted for property owners seeking to gain

legal non-conforming status.

Finally, in Banff, Saskatoon and Edmonton some or all STR application approvals are subject to

community feedback. When submitting a development permit request related to the operation of

an STR in Banff, prospective STR operators must notify the public by posting a sign on the property

for a minimum of three weeks, and in reviewing the application, authorities may consider the

opinions of adjacent landowners. As part of the review process in Saskatoon, the Community

Services Department provides written notice of the application to owners of property within 75

metres of the subject site, as well as the local community association in the area, inviting

comments for 21 days (City of Saskatoon 2022a). In Edmonton, applicants must provide all

properties located within 60 metres of the dwelling written notification of permit approval, inviting

neighbours to raise objections to the operation.

TABLE 6: STR PROHIBITIONS AND RESTRICTIONS

Only permitted in

principal residence

Entire-unit STRs

prohibited

Annual cap on

bookings

Prohibited dwellings

Zoning prohibitions

Quota or moratorium

Development permit

and assessment

Kelowna

Yes

*exception: select

areas in tourist, health

zones

Yes: effective cap of 125

nights on entire-unit

listings in areas where

non-PR STRs prohibited

secondary suite, carriage

house, vehicle, tent,

accessory bldg, group

home, lodging house

non-PR STRs are

prohibited outside of

select areas in tourist

and health zones

Tofino

*note: must be on lot

with 2 dwellings, one of

which is host’s PR

No BUT resident must be

present in other dwelling

*exception (CD(EL)): can

rent townhouse to 5 guests

in absence of resident

dwelling with >3 sleeping

units, 2- & multi-family

dwelling, accessory

building, vehicle, tent

prohibited use in several

res. & comm. districts

Vancouver

Yes

garage, studio, SRO,

Rental 100, vehicle, unit

in prohibited buildings

registry

conditional use in most

res. (RS, RT, RM, FM),

comm.(C), historic (HA)

districts

exempt from

development permit

requirement

Victoria

Yes

*exception: legal non-

conforming status

Yes host must be live-in,

max 2 bdrms can be rented

*exception: entire unit can

be rented “occasionally”

secondary or garden

suite that is not a

principal residence

----

*exception: assessment

required legal non-

conforming status

Whistler

employee housing,

apartment, auxiliary unit,

detached dwelling, most

duplexes & townhouses

prohibited in res. zones

*exception (some res.

zones); townhouses can

be rented to ≤10 guests

when unoccupied

Banff

Yes

Yes: Host must be “live-in.”

Only permitted in a room,

suite, or accessory unit of

the property.

prohibited if not a room,

suite, or accessory unit of

a single-detached home

prohibited outside

residential districts

Quota: 65 licences across

11 districts

Proximity: New STR

cannot be within 75m of

existing

Current moratorium

Yes (all applications):

App: floor & site plan;

property, unit desc. &

photos; owner consent

Process: host notifies

public (sign); inspection;

adjacent owners notified

+ decision in newspaper.

Calgary

----

Edmonton

major home-based

business (more than 2

sleeping units & live-in

host) discretionary use in

some zones

Yes (live-in host & >2

sleeping units):

App: bus. description &

visits/week; site plan

[permitted use] + traffic

impact assess. [disc. use]

can be denied on basis of

disrupting character

Regina

temporary structure,

vehicle, recreational

trailer or structure, illegal

accessory building

permitted use in all

residential and mixed-use

zones

Quota: max 35% units in

multi-unit bldg. can have

non-PR licence

Moratorium on non-PR

licences if vacancy <3%

Only permitted in

principal residence

Entire-unit STRs

prohibited

Annual cap on

bookings

Prohibited dwellings

Zoning prohibitions

Quota or moratorium

Development permit

and assessment

Saskatoon

Non-PR STR is a

discretionary use in many

residential districts

Quota: max 35% units in

multi-unit bldg. can have

non-PR licence

Moratorium on non-PR

licences if vacancy <3%

Yes (disc. use non-PR,)

App: property info, site

plan, parking. Consider

location, character. Notify

owners within 75m

Churchill

Niagara

OTL

*exception: Country

Inns, B&Bs must be in

principal residence

*exception: Country Inns,

B&Bs, can only be rented as

bedrooms in a principal

residence

non-single-detached

dwelling occupied for min

4 years *exception:

vacation apartments

must front onto public

road or Niagara Parkway;

Country Inn permitted by

site-specific zoning bylaw

amendment only

Ottawa

Yes

*exception: cottage or

Dedicated STR

(grandfathered)

vehicle, trailer, accessory

bldg, community housing,

coach house /secondary

dwelling that is not a PR

prohibited in subzones

AG4-AG8; areas where

B&B is prohibited

Toronto

Yes

Yes: 180-night cap on

entire-unit rentals

vehicle, accessory

dwelling that is not a PR

prohibited in some

commercial zones

Montréal

Varies by borough,

zoning, and specific

location

must be above ground

non-PR STR prohibited in

some areas in some

boroughs. cannot be

adjacent to bar, theatre,

dance hall, reception hall

Proximity: In some

boroughs, must be 150m

between non-PR STRs.

Yes: occupancy permit

required for non-PR STR

in some boroughs

Québec

City

Varies by borough,

zoning, and specific

location

Yes: 90-night cap on

collaborative (i.e., PR)

STRs

Non-PR STR (classed c10

–hotel) prohibited in

areas of each borough

Yes: may need permit for

some non-PR STRs,

depending on borough

Freder

icton

Yes

*exception: commercial

zones that permit

hotel/motel

*in res. zone: in single-

detached dwelling, max 3

rooms can be used for STR

dwelling that contains

group home, childcare

centre, home occupation

Prohibited in non-PR

dwellings in res. zones

Halifax

Secondary or backyard

suite if not a primary

residence

Non-PR STRs only

allowed in some zones

(commercial)

Yes (short-term bedroom

rental, commercial STR)

Charlotte

town

Yes

Secondary/garden suite

(if host not in principal

dwelling), apartment

Prohibited outside

residential zones [R-1L,

R-1S, R-2, R-2S, R-3, R-4]

----

St.

Johns

N/A

Yellow-

knife

vehicle

permitted in all

residential, commercial

mixed-use zones

----

Development permit may

be required; unclear

Iqaluit

Yes

*exception: sec.suite

accessory to host’s PR

Yes: 180-night cap on

entire-unit STR

4. LICENSING SYSTEMS AND OPERATIONAL AND

SAFETY STANDARDS

Registration and licensing frameworks rest on and operate according to the foundation set through

the determination of definitions, use types, and spatial and locational restrictions outlined in the

previous section. These frameworks require authorities to establish licence categories (which are

often linked to use type and/or unit characteristics), operational restrictions, requirements related

to guest management, safety, and experience, as well as a process for registration. Given the

elements of these frameworks—which can include restrictions on the number of units per dwelling

and guests per room; prohibitions of overlapping bookings; parking requirements; safety rules (e.g.,

means of egress, window and secondary lock requirements), and provisions related to advertising,

record keeping, and guest information—they draw on aspects of business licensing and zoning.

Licensing and registration serve two important management purposes. First, licensing is the first

step in supporting compliance with use restrictions, zoning, noise, and other community rules, as

well as operational standards. Second, licensing provides authorities a way to keep track of the

type and extent of STR activity that is being undertaken. This is particularly true when platforms are

also required to obtain a licence and must adhere to data sharing agreements. Gaining access to

comprehensive data on registered STRs, nights booked, income generated, and other metrics can

drive regulatory responsiveness and effectiveness, particularly if the data is used to support

ongoing efforts to adapt frameworks to be more exacting and flexible in the face of shifting market

dynamics. Table 6 outlines the components of the registration frameworks.

LICENCE TYPES

STR operators in the majority of jurisdictions in our review are subject to a licence framework, all of

which include registration requirements and various licence fees (Table 7; p. 25). In municipalities

with regulatory frameworks, authorities have either enacted STR-specific bylaws, or updated

existing business licence bylaws to reflect STR operations. Further, in five cases—Québec City,

Montréal, Halifax, Charlottetown, and St. John’s—the municipality is located in a provincial

jurisdiction with a tourist accommodation framework that oversees the licensing of all STR

operations conducted in the province, and thus has not established a separate licensing system.

Overall, the licence types established through these frameworks follow three approaches: broad

(i.e., a single licence category and cost); use-based (i.e., distinctions based on primary or secondary

use STR and cost); and unit-based (i.e., distinctions based on dwelling characteristics and cost).

However, Charlottetown intends to introduce a licensing system in the future (Department of Planning & Heritage

2022), and Halifax requires that those operating STRs participate in the municipality’s rental registry (Halifax Regional

Municipality 2022).

TABLE 7: LICENCE TYPES AND FEES

Jurisdiction

Licence Types

Fees

Kelowna

Minor STR Licence: principal residence

$345/year + $25 fee

Major STR Licence: secondary property

$750/year + $25 fee

Tofino

Business Licence (Class 9)

$494.70/year (1 sleeping unit) +$163.20/add. unit

$72 processing fee

Vancouver

STR Business Licence (operator)

$109/year

$66 application fee

Victoria

STR Licence: Principal residence

$150

STR Licence: Legally non-conforming use

$1,500

Whistler

Tourist Accommodation Business Licence

$190/year+$25/unit

$25 application fee

Banff

Business Licence

$190/year

+$47.47/pillow

Calgary

Business Licence – Tier 1: 1-4 rooms

$100

Business Licence – Tier 2: 5+ rooms

$172 ($131 renew)

*non-resident fee of +$785)

Edmonton

Tier 2 Business Licence: Residential Rental

Accommodation Short-Term

$95/year or $180/2 years

*non-resident +$460/year or $920/2 years

Regina

Residential STR Licence: Principal Residence

$100/year

Residential STR Licence: Secondary Property

$300/year

Saskatoon

Commercial Business Licence: Homestay

$125/year ($85 renew)

Commercial Business Licence: STR Property

$125/year ($85 renew)

Churchill

Business Licence

$75/year

Niagara-OTL

Short-Term Rental Licence

$274/room (4 year licence)

Ottawa

Host Permit

$53 permit + $57 admin (2 year)

Property Manager Registration

$143 registration + $57 admin (1 year)

Platform Registration

Tier 1 (<100 listings): $1,000 + $57 admin (3 years)

Tier 2 (101-500): $2,500 + $57 admin (3 years)

Tier 3 (>500): $5,000 + $57 admin (3 years)

Toronto

STR Operator Registration

$53.22/year

STR Company Licence

One-time fee of $5,321.85 + ongoing fee of $1.06 for

every STR night booked through the company

Montreal

QC – Principal Residence

$50/year

QC – General Tourist

$145/year

Quebec City

QC –Principal Residence

$50/year

QC –General Tourist

$145/year

Halifax

Nova Scotia Host Registration: 1-4 bedrooms

$50/year

Nova Scotia Host Registration : 5+ bedrooms

$150/year

Nova Socita Platform Registration

$500/year

Charlottetown

Tourist Home Operator Licence: 1-4 unit

dwelling

$155/year

Tourist Home Operator Licence: 5+ unit

dwelling

$250/year

+$6.50/unit

St. John’s

NL Tourist Accommodation Registration

No fee; not required for principal residence STR

Yellowknife

STR Business Licence

$200/year

Iqaluit

Class 4 Business Licence:

$100

In Vancouver, Edmonton, Churchill, Toronto, Yellowknife, and Iqaluit, authorities have introduced a

broad approach to licensing, meaning that there is only one licence type and fee level. In three of

these jurisdictions (Vancouver, Toronto, and Iqaluit) STRs are generally limited to a primary

residence. Fees in these jurisdictions are around $100 per year (or less), with Yellowknife

($200/year) serving as an outlier. In Vancouver, an operator may only hold one licence, while in

Edmonton and Iqaluit, one must have a separate licence for each dwelling one wishes to operate as

an STR.

In Kelowna, Victoria, Regina, Saskatoon, Ottawa, and the Province of Québec, licensing frameworks

distinguish between STR types, with a focus on differentiating between primary residence listings

and other operations. In these cases, with the exception of Saskatoon and Ottawa,

the cost of

operating an STR in a dwelling that is not a primary residence is higher—sometimes significantly

so—which can be taken as an attempt to discourage widespread participation in the practice,

without limiting small-scale operators. For example, the difference between a PR and non-PR STR

licence is roughly $400 in Kelowna, $200 in Regina, and $95 in Québec. Further, if one wishes to

obtain legally non-conforming use status in Victoria, the licence cost is $1,500. In these

jurisdictions, a separate licence is required for each premises.

In the remaining jurisdictions of Tofino, Whistler, Banff, Calgary, Niagara-on-the-Lake, Nova Scotia,

and Prince Edward Island licence frameworks make distinctions—particularly in fee amounts and

inspection rules—based on the number of rooms offered or units available. In Calgary and PEI, for

example, authorities have established a tiered licence, with a higher fee (and attendant inspection

requirements) for dwellings with more than four rooms. In Tofino, Whistler, Banff, and Niagara-on-

the-Lake, additional guests (Banff) or STR units (Niagara-on-the-Lake, Tofino, Whistler) increase a

base licence fee by an incremental amount (i.e., by guest or by room). This approach imposes a

higher cost and additional stipulations on larger-scale operations, defined by the number of rooms

available to rent.

Finally, in Calgary and Edmonton, non-residents are charged substantially higher annual fees,

while one must be an eligible resident to qualify for a licence in Banff.

Overall, while there is

considerable variation in fees charged for hosts, most fees are under $300/annually, and those

that are higher apply to non-principal residences and to hosts who are not residents of the

jurisdiction in which they are operating.

Ottawa is the only jurisdiction that has rules specific to cottage owners. Though operating an STR outside of one’s

primary residence is generally prohibited, an exception has been made to allow individuals to use their cottage as an

STR. As a result, an individual can hold two STR licences: one for a primary residence and another for a cottage.

In Calgary, non-residents pay an additional $785 (Business Licence Bylaw, Schedule B), and in Edmonton, the

Business Licence Fee Schedule (City of Edmonton 2022a) stipulates that non-residents pay an extra $180.

Banff Land Use Bylaw, s 2.3.3.

APPLICATIONS, OPERATIONAL RULES, AND GUEST SAFETY STANDARDS

Application Process

Acquiring and maintaining a licence is contingent upon compliance with a range of operational

standards and limits, guest experience rules, and associated safety measures, which are set out in

Table 8 (pp. 30-31). These standards are applied through licence application and registration

processes, and further upheld through compliance and enforcement efforts (which we discuss in

Section 6).

With the exception of STR hosts in Fredericton—where the municipality regulates STRs through a

zoning bylaw, but does not oversee a licensing or registration framework—all individuals or entities

wishing to operate an STR in the jurisdictions in our review must first undergo an application

process, during which adherence to zoning rules is confirmed, and operators are asked to show

proof of compliance with and/or attest to knowledge of operational and safety requirements, as

well as community standards, including those outlined in noise and waste bylaws. In this sense,

licensing frameworks not only set out rules, but also reinforce relevant provisions under other

bylaws.

The most common stipulation across jurisdictions in our review is the requirement to submit proof

of ownership or owner permission (if a renter), as well as other relevant permissions (e.g., Strata,

condo, or co-operative permission, if the unit is located in such a building). From here, many

jurisdictions also require a plan outlining compliance with bylaws, and specifically, rules related to

building safety, guest management, and neighbourhood effects, as well as information about

operation type, type of building, and numbers of rooms offered. All jurisdictions, with the exception

of Calgary, Victoria, and Regina, require submission of some or all of these documents, at least in

certain application cases (i.e., when a development permit is required), with particularly detailed

and onerous processes for all applicants in Banff, Edmonton, Jasper, Kelowna, Niagara-on-the-

Lake, Saskatoon, and Ottawa, and some applicants in Iqaluit, Montréal, and Québec (depending on

use type and zoning rules).

In Kelowna, for example, a prospective operator must, in addition to completing a business licence

application, submit a floor plan of the premises indicating location of fire extinguishers, smoke

alarms, and fire exits, as well as sleeping units, types of bed, and location of sofa beds; a parking

plan; a self-evaluation safety audit and attestation; a signed good neighbour agreement; and proof

of strata and/or owner consent (if applicable). In Edmonton, a notable requirement is the creation

of an operational plan, in which the prospective operator must detail the type of STR and property,

guest maximums, the bedrooms and bathrooms available to guests, procedures for guest check-in

and check-out, and a plan for dealing with noise, nuisance, parking, and waste management. This

is then reviewed by City staff, who are expected to work with the applicant to produce a sufficient

plan; a licence is not granted until this process has been completed (City of Edmonton 2022b). In

Quebec, the declaration of the tourist accommodation establishment’s accommodation offering

(required for general tourist accommodation, or non-PR STR only) must include information on the

accessibility of the unit to individuals with disabilities and the possibility of bringing a companion

animal.

In municipalities in which STR operators are subject to regulations at two orders of government (i.e.,

in Charlottetown, Halifax, Montréal, and Québec City, where the province has introduced a

registration framework), the requirement typically exists within the provincial frameworks for

applicants to present proof of compliance with municipal rules (particularly zoning/land-use bylaws)

prior to being granted a licence. In the Québec context, this is a fillable notice of compliance, which

must be signed by the relevant municipal authority and submitted with the application.

Finally, in some jurisdictions, proof of insurance and stipulated inspections must be provided as

part of the application process. Insurance rules exist in Québec (proof of $2 million insurance),

Ottawa ($1 million), and Niagara-on-the-Lake ($2 million with the Town as an added insured); fire

inspections are required in Whistler (if in a commercial area), Calgary (if more than 5 bedrooms in

STR), and Regina (for a secondary property only); and broader property and safety inspections are

necessary in Niagara-on-the-Lake and Charlottetown.

Operational Rules and Guest Safety Standards

Common operational rules across jurisdictions we reviewed include a limit on the maximum

number of rooms that can be offered for rent in one dwelling, guest limits (usually tied to the

number of rooms and maximum occupancy standards), the prohibition of overlapping bookings

(i.e., renting more than one sleeping unit to different parties at a time); stipulations regarding unit

size; parking requirements; and prohibitions against serving food and alcohol. Few notable

restrictions emerge from our analysis, save from the express prohibition of hosting weddings and

similar commercial activity on an STR property in Niagara-on-the-Lake.

In terms of guest safety and experience measures, most jurisdictions stipulate displaying the STR

licence in a visible place in the unit; ensuring that there is either an on-site operator or a designated

responsible person with whom communication can be made and issues attended to (usually within

two hours of contact); providing guests with relevant documents, such as good neighbour guides

and information on local bylaws and services; and posting fire safety and evacuation plans within

the dwelling. In addition, Toronto has included language and provisions related to accessibility and

discrimination in its licensing framework, noting human rights legislation regarding discrimination

and the provision that one cannot refuse service to a person with a disability or a service animal.

Also notable are the requirement in Banff for the STR unit to offer guests access to indoor and

outdoor amenity spaces and a common area, and stipulations in Prince Edward Island’s legislation

regarding amenity standards for all rental units, including particular, lighting, equipment, furniture,

linen, towels, and drinkware (as examples).

EXTENDING REGISTRATION FRAMEWORKS

Finally, as noted in Table 7 (p. 25), a small number of Canadian municipalities have adapted

regulatory frameworks to account for the central role of platforms, in addition to the growing

presence of property managers. Requiring the registration of platforms and property managers not

only reflects a more sophisticated understanding of the STR market, but it is also a way for local

authorities to gain more nuanced and comprehensive information on the type of STR activity

unfolding in their jurisdiction. In three cities in our review—Vancouver, Ottawa, and Whistler—

property managers are required to obtain a permit or licence in order to carry out management

activities, while Toronto and Ottawa mandate the licensing and registration of platforms. Nova

Scotia and PEI have also introduced registration, as well as data collection, storage, and sharing

provisions, for platforms.

In Toronto, short-term rental companies—that is, any company (e.g., Airbnb, Booking.com) that

facilitates or brokers STR reservations online and receives payment for this service—wishing to

operate in the city must follow a licence application process that includes the submission of an

application form and a signed plan for use, retention, and disclosure of operator and guest

information (referred to by the City as a Data Sharing Agreement, or DSA). Platforms are further

required to pay a registration fee of $5,000 and an ongoing fee of $1 for every STR night booked

through the company; such licences must be renewed on an annual basis, but there is no renewal

fee. Ottawa also requires the registration of STR platforms with the City. The registration fee

structure follows a three-tiered model, in which Tier 1 platforms are those with fewer than 100

listings and must pay a $1,000 fee, Tier 2 platforms are those with 101-500 listings and must pay

a $2,500 fee, and Tier 3 platforms are those with more than 500 listings and must pay a $5,000

fee; all platforms must also remit a $57 administration fee. Registration expires after three years.

Prior to registration, the platform applicant must reach an agreement with the City regarding the

collection, use, disclosure, and retention of information on STR hosts and guests using its platform.

In Nova Scotia and Prince Edward Island, platform operators must also register and keep a record

of all concluded transactions, the name and registration number of the host, number of nights

rented, and the total and nightly price charged. We discuss these measures further in Section 6.

TABLE 8: APPLICATION REQUIREMENTS, OPERATIONAL RULES, AND GUEST SAFETY STANDARDS

Application requirements

Inspections

Operational rules

Guest experience and safety

Kelowna

Online or in person application; Ownership proof/permission of

owner/strata; Good Neighbour Agreement; Self-evaluation safety

audit and attestation; Floor plan: fire safety, sleeping units, beds.

Parking & fire evacuation plan; Must notify neighbours (all

adjacent properties)

Self-evaluation safety

audit and attestation

(annual)

Rooms: max 3 sleeping units in

single/2/multi-dwelling housing /

max 2 in 3/4/multi-dwelling housing

# of guests:

No overlapping bookings

Parking: PR must have 2 spaces with stall size requirements

Safety: Posted floor plan + fire and safety evacuation plan in

each sleeping unit and at exit; copy of Good Guest Guide;

display licence in entryway; ensure 24hr/day contact, within 2

hours

Tofino

Signed application form; Proof of permanent residence/owner

consent; Nature and description of business; Floor plan outlining

location, type of bedrooms, sofa beds.

----

Rooms: max 3 bedrooms

# of guests: max 6 guests; sleeping

capacity further based on number of

beds provided.

Parking: min 1 onsite space

Safety and Guest Info: on-site operator or manager available to

respond in 2 hours; display licence on premises; provide

Respectful Neighbourliness Brochure

Vancouver

Online application; Proof of ownership; Written consent of owner

(if renter); Written consent of strata (if applicable); Attestation of

compliance w/ safety requirements, bylaws.

alarms, extinguishers,

detectors tested

annually; written

record; attestation of

compliance

Rooms: must adhere to max

occupancy standards

# of guests: max 2 adults/bedroom

No overlapping bookings

Parking: no stipulations

Safety: contact name & #; fire safety plan at all exits and

entrances; interconnected smoke alarms on each floor & in

each bedroom; fire extinguisher on each floor

Victoria

Online/mailed application form; proof of ownership or owner

consent; written strata consent (if applicable);evidence of principal

residency in dwelling; Designated responsible person; information

about property management (if applicable).

----

Rooms: max 2 bedrooms

Number of guests: max 2 adults per

bedroom

No liquor may be provided

Safety: A designated responsible person must be able to attend

at the premises within two hours

Whistler

Online application

Owner authorization form (if not registered owner)

Fire Inspection - $125

[only if in commercial

area]

Parking: 0.75/guest room and 1 space/sleeping unit; 1

space/55 m

of floor area to max 2 spaces per unit

Banff

Online application

Proof of Development Permit

Dev. Permit

$1,500 + $100/room

Rooms: 2 guest rooms max (4 in

some districts); cannot have kitchen

Unit size: min 9.0 m

Below grade

units/limited light discouraged

Parking: one stall per guest room

Amenities: Must offer indoor and outdoor amenity space,

common area

Safety: Must post business licence on premises

Calgary

Online application

Fire Inspection (Tier 2):

$104

Number of guests: max 2 adults per

room

No overlapping bookings

Safety: Room must have 1+ egress windows (+2-storey

apartments with existing fire safety standards exempt); must

post an emergency contact person and number that can be

reached 24 hrs

Edmonton

Online application; approved Operational Plan (STR and property

type; max # of guests; # of bedrooms, bathrooms for guests;

check-in/out procedures; plan for noise, nuisance; parking, waste

mgmt; development permit (if live-in host with >2 bedrooms)

AHS is notified as to

application, and can

follow up re:

compliance

Safety: Provide in unit the operator phone number, information

guide

Regina

Online application; Address, name of owner & applicant, proof of

PR; proof of owner permission (if applicable); name of platform

used; listing URL; If PR STR: names of adults who reside at unit; If

in multi-unit dwelling, # of units in dwelling; proof of fire inspection

Fire Inspection (for

secondary property)-

$95

Parking: 0.5 stalls, in addition to dwelling requirement

Safety and Guest Info: emergency contact name and number;

display licence in conspicuous place; adhere to fire safety

standards (Regina Fire Bylaw)

Saskatoon

Online application; written permission of property owner (if not

owned by host) and/or condo corp (if applicable); signed

declaration of host that property complies with life and safety

requirements; parking information, website links to listings

Proof of approved discretionary use (if applicable).

Attestation of self-

inspection through

host declaration

# of guests: max 6 in 1-unit dwelling

(both), max 3 in secondary suite

(both); 2 in each unit of semi-

detached, 2-unit, townhouse, or

multi-unit dwelling (homestay)

Parking: 1 space per dwelling unit (STR property); 1 space + 1

for visitors (homestay) – except in M4 district

Safety and Guest Info: emergency contact name and number;

display licence in prominent place at premises

Churchill

Filled application form.

Detailed site plan and floor plan.

Proof of fire insurance and inspection.

Fire inspection

Safety and Guest Info must test smoke detectors, fire

extinguishers yearly; keep outside entries well-lit; at least 1 fire

extinguisher, detectors in hall & storage; ensure bedroom have

2 exits, 1 fire escape, 2 sources of lighting, smoke, heat

detectors, posted escape routes, emergency procedures

Application requirements

Inspections

Operational rules

Guest experience and safety

Niagara

-OTL

Filled application form; site and floor plans drawn to scale,

including location of building on property with setbacks,

location/dimension of parking; location/dimensions of outdoor

amenity area; proof of $2 million insurance (with Town added

insured); list of vehicles used/stored on site (B&B, Country Inn)

Proof of pre-licence inspection

Safety Inspection (fire,

building code; zoning;

electrical, etc)

Number of guests: max 2 per

bedroom, plus 2 persons

Restrictions: no weddings or similar

commercial activity may be hosted

at STR

Parking: 1 space/room (villa); one space for the rental (vacation

rental);

Safety and Guest Info: provide copy of licence, relevant bylaws,

floor plans showing exits, copy of renter’s code of conduct, good

neighbour agreement, contact info of responsible person

Ottawa

Filled application form; proof of ownership/lease + consent from

owner/condo board/co-operative, as needed + principal residency;

floor plan with sq footage, # of bedrooms; proof of $1 million

insurance; signed declaration re bylaw compliance.

----

Number of guests: max 2 per

sleeping room

Rooms: 4 in dwelling unit or mobile

home; 8 in oversize/non-conforming

Safety and Guest Info: provide guest with onsite contact and

details, information package electronically at time of booking

and in unit about noise, parking, smoking/vaping regs, fire

safety, emergency services, permit copy

Toronto

Online registration; description of parts of the property to be used

for STR, type of building in which STR is located; name, telephone

of emergency contact available 24hr; demonstration of primary

residency on property; attestation to compliance with fire code

----

Rooms: max 3 bedrooms

Safety and Guest Info: emergency contact; 911 info; diagram of

bldg. exits

Rights-based language: notes Ontario Human Rights Code re

discrimination; cannot refuse service to PWD, service animal

Montréal

Online application; property title/rental contract; owner permission

(if renter); declaration of offering, physical description, accessibility

measures, period of operation over year (only for non-PR); interior

and exterior photos (as on platform); signed notice of compliance

with municipal bylaws; proof of $2 million insurance

----

No overlapping bookings (PR-STR)

Must display registration certificate in public view at main

entrance (unless multi-unit dwelling – in which case must be

displayed at the main entrance to unit); send certificate to

platform on which STR is listed.

Québec

City

Online application; property title/rental contract; owner permission

(if renter); declaration of offering, physical description, accessibility

measures, period of operation over year (only for non-PR); interior

and exterior photos (as on platform); signed notice of compliance

with municipal bylaws; proof of $2 million insurance

----

No overlapping bookings

Rooms: if PR-STR, only one bedroom

can be rented at a time

Must display registration certificate in public view at main

entrance (unless multi-unit dwelling – in which case must be

displayed at the main entrance to unit); send certificate to

platform on which STR is listed.

Freder

icton

----

Rooms: no more than 3 rooms can

be used

----

Halifax

Online registration; address of STR location; type of

accommodation offered, # of bedrooms available for rent; whether

it is the operator’s primary residence; proof of conformity with

municipal bylaws; HRM residential rental registry participation

----

*depends on land-use bylaw for

area: for Regional Centre

Rooms: no more than 3 bedrooms

can be rented at same time

----

Charlottetown

Filled application; floorplan; proof of annual inspection (water test

results depending on water source); proof of municipal approval

(zoning)

Annual property

inspection

($180/year)

Parking: 1 spot/3 rooms + 1 for operator

Amenities: range of requirements related to provision of linens,

supplies, cleaning and laundering frequency

Safety and Guest Info: display licence in unit where register is

kept; competent attendant on hand daily (or number provided to

call) to assist guests

St. John

Online application (portal): name of operator, address, description

of STR, units offered, number of bedrooms offered. Several

provincial and municipal licences/permits may be required:

application includes attestation of conformity with requirements .

----

Yellowknife

Completed application form; proof of ownership/owner consent

Type of building and intended operation (i.e., entire-unit, principal

residence STR); number of rooms offered; guests per night (max)

Platform on which listing will be posted; proof of development

permit may be required.

----

Parking: no additional parking required

Safety and Guest Info: post in conspicuous place in unit licence

and emergency contact name and number

Iqaluit

Completed application form.

Owner consent if a rental.

----

Number of guests: max 6

Safety and Guest Info: post licence in conspicuous place on

premises

5. TAXATION

Taxation is a management tool about which stakeholders in the traditional hospitality industry have

been vocal since the emergence and expansion of the STR market. Calling for the extension of

existing tourist accommodation and sales taxes to STR operations, hotel associations have argued

that without such equalizing measures, STR operators benefit from an uneven playing field that

gives them unfair competitive advantage over traditional accommodation providers, such as hotels,

motels, and bed and breakfasts, which have to collect and remit tax on accommodation sold (Hotel

Association of Canada 2018, 7; Vigliotti 2019).

Today, tax requirements are a standard component of most STR frameworks in Canada. Sales taxes

(e.g., GST, HST, PST, and QST, or some combination thereof, depending on the province or territory)

represent a significant revenue raising tool for Canadian governments at the federal and provincial

levels, and are often levied on the cost of accommodation. Taxes that pertain solely to the purchase

of accommodation, such as tourism levies, are often introduced alongside sales taxes as a more

direct way of recouping the costs that result from increased tourist activity at the local level,

particularly in terms of pressure on or need for additional infrastructure, amenities, and facilities. In

many cases, revenues raised through the accommodation tax must be allocated to support tourist

infrastructure, maintain services for guests, and market the destination.

Table 9 (p. 37) provides an overview of the range of sales and accommodation taxes levied on STR

operations in the 25 jurisdictions in our review, indicating order of government, tax name and rate,

details regarding applicability, collection, and remittance, and rules governing revenue allocation.

Since taxation powers are generally reserved for the provincial and federal governments in Canada,

the majority of our discussion of STR-related taxation pertains to provincial frameworks, over which

municipalities have no authority. In some cases, however, provincial governments have devolved to

the municipality the power to levy an accommodation tax, with general stipulations as to how

revenues are to be allocated.

SALES TAXES

In Canadian jurisdictions, sales taxes (i.e., GST/HST, PST, QST) are charged on STR transactions.

Certain jurisdictions have remittance agreements with Airbnb, whereby platforms can register to

collect and remit tax on behalf of operators to remove the burden for hosts (as we discuss below,

this is also the case with tourist accommodation taxes). For example, in Saskatchewan, online

accommodation platforms are now required to register as vendors for the purpose of collecting and

remitting the six per cent PST on all transactions made through their platforms (Saskatchewan

Ministry of Finance 2021). Further, in 2021 Québec adopted changes which required the collection

of QST on all STR bookings, even if the owner is not registered for the QST (Gouvernement du

Québec 2021). As a result, those renting an STR in Québec through a platform such as Airbnb will

be charged QST automatically, irrespective of whether the host is a small supplier. Finally, in 2018,

the Government of British Columbia entered into a tax collection and remittance agreement Airbnb.

More recently, in 2022, changes to the Provincial Sales Tax Act were adopted, requiring online

accommodation platforms to register to collect and remit the eight per cent PST on the booking

services they provide, as well as on the sale of accommodation (on behalf of hosts).

In addition,

the province has noted its intention to use the PST revenues collected on STR bookings to improve

housing affordability (Ministry of Finance 2018).

PROVINCIAL TAXES ON TOURIST ACCOMMODATION

Alberta Tourism Levy

In Alberta, the Province has not devolved to the municipality responsibility for taxing tourist

accommodation and allocating the revenues generated through such a tax. As a result, the

Government of Alberta oversees the administration of the Tourism Levy Act. In April 2021, changes

to the Tourism Levy Act

came into effect, extending the application of the four per cent tourism

levy on the purchase price of accommodation to STR operations (though during the pandemic there

was a pause on remitting the levy). In budget documents, the government has indicated that this

extension was pursued as a way of leveling the playing field and ensuring competitive fairness

among temporary accommodation providers (Alberta Treasury Board and Finance 2020, 175). The

2022 Budget indicated that the government would be pursing legislative changes in 2022 to

require platforms to collect and remit the levy (Alberta Treasury Board and Finance 2022, 179).

Such changes were adopted through legislative amendments in 2022.

It is unclear how revenues raised through the levy are allocated. When the levy was introduced in

2005, the government of the day suggested that all revenue generated by the levy would be used

for tourism marketing and development (Alberta Hotel & Lodging Association 2016). The 2020

budget noted that mechanisms to increase funding for tourism initiatives, including a full allocation

of the tourism levy to the Ministry responsible for tourism, would be considered with improvements

to the economic picture (Alberta Treasury Board and Finance 2020, 35). There was no mention of a

change in Budgets 2022 and 2023 and there remains no transparency in terms of revenue

allocation criteria.

British Columbia Municipal and Regional District Tax (MRDT) on Accommodation

In Kelowna, Victoria, Vancouver, Tofino, and Whistler, STR bookings are subject to a Municipal and

Regional District Tax of three per cent.

Introduced in 1987, the original purpose of the provincial

program was to raise revenue for local tourism marketing, programs, and projects. The 2018

changes to the Provincial Sales Tax Act that enabled online accommodation platforms to register to

Provincial Sales Tax Act, SBC 2021, c 35, s 179.3

Tourism Levy Act 2000, RSA 2000, c T-5.5,

Bill 2, Financial Statutes Amendment Act, 2022

B.C. Reg 93/2013, Schedule 1

collect and remit PST on behalf of hosts also apply to the collection of MRDT.

In 2018, amendments were made to the Designated Accommodation Area Tax Regulation to

enable revenues raised through the MRDT to also be used to fund local affordable housing

initiatives.

In light of this change, the Resort Municipality of Whistler has, since 2019, allocated

100 per cent of its portion of MRDT revenues raised through online accommodation providers to

support the Cheakamus Crossing Phase II affordable housing project (Resort Municipality of

Whistler 2021). Further, the City of Kelowna earmarks all MRDT revenues from online STR bookings

for affordable housing initiatives such as the Housing Opportunities Reserve Fund (City of Kelowna

2020, 3), which supports land acquisition for affordable housing as well as a rental housing grant

program. Destination Greater Victoria, the City of Victoria, and the Hotel Association of Greater

Victoria have identified the City’s Housing Reserve Fund as the most appropriate envelope for

MRDT revenues collected through online accommodation platforms; as a result, 100 per cent of

such revenues allocated to the City of Victoria to include in this fund (Destination Greater Victoria

2021, 45). In Vancouver, however, Tourism Vancouver has historically opposed the apportionment

of any MRDT revenues for affordable housing (City of Vancouver 2019, 15).

B.C.’s MRDT program is unique in Canada, and represents a promising strategy in the face of

concerns about the local impacts of STR activity. In particular, the approach balances or offsets the

community-level effects of STR market growth without banning or placing severe restrictions on STR

operations, and in a way that directly addresses the area of concern. As a result, it is a strong

complement to local restrictions in the province, many of which are aimed at preserving local

housing stock through primary residence restrictions and zoning rules that limit more

commercialized activity to designated commercial, tourist, and health districts. Recently, the MRDT

program has been expanded to support event-specific needs. Announced in January 2023, the City

of Vancouver will levy an additional 2.5 per cent Major Events MRDT on STR sales to help cover

costs of hosing the FIFA 2026 World Cup; this will apply in addition to the eight percent PST and

three per cent MRDT (B.C. Ministry of Finance 2023) The Major Events MRDT will be in effect from

February 2023–Jan 2030.

Québec Tax on Lodging

In 2016, the Act respecting the Québec sales tax was amended to require that those operating

STRs collect and remit a 3.5 per cent tax on lodging.

The tax applies in 21 tourism regions in

Québec,

and revenues raised through the tax are allocated to a tourism partnership fund, which

was created in 1996 to support the promotion and development of tourism in the province

B.C. Reg. 93/2013, s 5(1)(b)

Act respecting the Québec sales tax, RSQ 2018, c T-0.1, s 541.24.(2.1)

The tax does not apply in the Nunavik tourism region.

(Ministère de Finances Québec 2017). Further, in 2017, the Government of Québec entered into a

tax remittance agreement with Airbnb, making it possible for the platform to collect and remit the

tax on lodging on behalf of hosts offering accommodation on its platform (Revenu Québec 2017).

MUNICIPAL TAXES

Charlottetown Tourism Accommodation Levy

Since 2011, the City of Charlottetown has imposed a three per cent tourism accommodation levy

on the purchase price of accommodation,

and this levy was extended to STR operations in

2020.

As per the Municipal Government Act, the levy must be used to promote the municipality as

a tourist destination,

including through the payment of a grant to an organization tasked with

tourism promotion.

Churchill Accommodation Tax Levy

In accordance with the Municipal Taxation and Funding Act, the Government of Manitoba approved

the Town of Churchill’s Accommodation Tax Levy Bylaw in 2017, enabling Churchill to impose a tax

on the purchase of accommodation of short duration.

The six per cent tax applies to the purchase

price of accommodation provided for a continuous period of 60 nights or less,

and must be

remitted by the operator with a statement of revenue and tax collected on a quarterly basis.

Revenues are allocated across three reserve funds to support community enhancement and

tourism initiatives (40%), waste management (30%), and utility operations (30%).

Halifax Regional Municipality (HRM) Marketing Levy

Since 2023, HRM has imposed a three per cent marketing levy on STR accommodation. The levy is

applied to the total revenue for the sale of a room or unit, plus any other fees for services offered

(e.g., cleaning, administrative, etc.), before sales tax is applied. Revenues raised through the levy

can only be used to support the tourism industry, including by partially funding the operations of

Discover Halifax and by funding events through the Special Events Reserve Grant Program.

Municipal Accommodation Tax: Hamilton, Toronto, Ottawa, and Niagara-on-the-Lake

In 2017, Ontario passed legislative amendments to the Municipal Act (and City of Toronto Act) to

City of Charlottetown, bylaw no 2019-TAL-1, Tourism Accommodation Bylaw (2019), s 3.1

Ibid, s 4.2

Municipal Government Act, RSPEI 1988, c M- 12. 1, Division 2, s 161(5)

Ibid, s 161(6)

Town of Churchill, bylaw No 774/2015, Accommodation Tax Levy By-law (2017)

Ibid, s 3.1

Ibid, s 5.1

Ibid, s 3.6

provide municipalities the legislative authority to implement a Municipal Accommodation Tax (MAT).

To replace funds previously generated through destination marketing programs, require

municipalities that decide to adopt a MAT to provide a minimum contribution to local bodies (e.g.,

Ottawa Tourism) for the exclusive purpose of promoting tourism.

In 2018, both Toronto and Ottawa introduced a MAT of four per cent. In 2023, Toronto passed

bylaw amendments to increase the accommodation tax rate to six per cent. In both cases, the MAT

applies to hotel and short-term rental accommodation. Given the delayed implementation of

Toronto’s STR regulations (as a result of the Zoning Bylaw being appealed at the Local Planning

Appeal Tribunal immediately after adoption), MAT collection and remittance was not fully enforced

until January 2021. In Ottawa, collection and remittance of MAT by STR operators was required

from the outset (despite regulatory reform for STRs being enacted in 2021). In June 2022, Niagara-

on-the-Lake Council approved a bylaw to enable the collection of MAT, starting July 1, 2022

(Niagara-on-the-Lake 2022). It is expected that the MAT will be set at two per cent initially (and then

increase to three per cent in 2024 and four per cent in 2025) and only apply to STR properties with

more than five bedrooms (The Corporation of the Town of Niagara-on-the-Lake 2022).

Toronto allows for STR companies to sign a Voluntary Collection Agreement with the City of Toronto

to be able to collect and remit the MAT on behalf of operators. However, in such cases an operator

must still file a quarterly MAT report through an online submission portal. In Ottawa, Airbnb has

collected MAT on behalf of operators since August 2018. All monthly revenues generated through

Toronto’s MAT are directed towards Destination Toronto, which supports the tourism industry, as

well as various programs and services (e.g., roads, transit, culture, parks) which travelers use and

benefit from when visiting the city. In Ottawa, the MAT replaces the Destination Marketing Fee.

Revenues are used to support Ottawa Tourism’s sales, marketing, and destination development

efforts.

O Reg 435/17; O Reg 436//17

TABLE 9: TAXES ON STR ACCOMMODATION

Authority

Tax or levy

Details

Revenue allocation

Total amount

CANADA

GST (5%): AB, BC, MB, NWT, NU,

QC, SK, YK; HST (13%): ON; (15%):

NB, NL, NS, PEI

Applies to purchase price, platform booking and service

fees.

Consolidated revenue fund

----

Provincial Sales Tax (8%)

Applies to purchase price, platform booking, admin

fees.

Platforms must register to collect, remit PST.

----

Kelowna

Municipal and Regional District

Tax (3%)

Same applicability, registration/remittance rules as

PST.

Allocated to Tourism Kelowna.

All revenues from STRs go to affordable housing.

11% + 5% GST

Tofino

Municipal and Regional District

Tax (3%)

Same applicability, registration/remittance rules as

PST.

Allocated to Tourism Tofino, passed to Town.

$400,000/year of revenue for wastewater facility.

11% + 5% GST

Vancouver

Municipal and Regional District

Tax (3%)

Major Events MRDT (2.5%)

Same applicability, registration/remittance rules as

PST.

Major Events MRDT in effect Feb 2023–Jan 2030.

Allocated to Tourism Van. Can use for aff. housing.

Major Events MRDT: help with 2026 World Cup.

13.5% + 5% GST

Victoria

Municipal and Regional District

Tax (3%)

Same applicability, registration/remittance rules as

PST.

Allocated to Tourism Victoria.

100% of revenues to City for Housing Reserve

Fund.

11% + 5% GST

Whistler

Municipal and Regional District

Tax (3%)

Same applicability, registration/remittance rules as

PST.

Revenues from online accomm. platforms have

traditionally supported affordable housing projects.

11% + 5% GST

Alberta Tourism Levy (4%)

Applies to the purchase price.

Platforms responsible for collecting, remitting.

Unclear how/where revenues are allocated.

4% + 5% GST

Provincial Sales Tax (6%)

Applies to purchase price; not platform transaction

fees.

Platforms responsible for collecting, remitting.

6% + 5% GST

Retail Sales Tax (7%)

Applies to purchase price, as well as booking fees.

7% + 5% GST

Churchill

Accommodation Tax Levy (5%)

Applies to purchase price of accommodation.

Allocated to Reserve Fund to support Community

Enhancement/Tourism; Waste Management;

Utilities

5% + 5% GST

Hamilton

Municipal Accommodation Tax

(4%)

Applies only to room portion of booking.

Destination marketing and tourism development,

including hosting major tourism festivals, events.

4% + 13% HST

Niagara-on-

the-Lake

Municipal Accommodation Tax

(3%)

Applies to all transient accommodation with >5 rooms.

Tax will increase to 4% in 2024.

Funds are put in reserve for tourism infrastructure.

3% + 13% HST

Ottawa

Municipal Accommodation Tax

(4%)

Applies to room portion of STR bookings.

Airbnb collects and remits MAT on behalf of operators

Allocated to Ottawa Tourism to be invested in

destination marketing, sales, and development

activities.

4% + 13% HST

Toronto

Municipal Accommodation Tax

(6%)

Applies to purchase price.

Platforms can collect and remit tax on behalf of

operators.

Allocated to Destination Toronto to support tourism

industry, programs and services used by visitors.

4% + 13% HST

Québec Sales Tax (9.975%)

Québec Tax on Lodging (3.5%)

Applied only on price of overnight stay.

Tax remittance agreement with Airbnb.

Allocated to Tourism Partnership Fund.

13.5% + 5% GST

Fredericton

Tourism Accommodation Levy

(3.5%)

Could be interpreted as applying to operators renting

properties with 6+ rooms; Must submit monthly report.

Support and promote local tourism.

3.5% + 15% HST

Halifax

Marketing Levy (max 3%)

Applied to total revenue for the sale of a room or unit,

plus any other fees for services provided such as

cleaning and administrative fees, before GST.

Supports tourism industry: funding events through

the Special Events Reserve Grant Program,

partially fund operations for Discover Halifax.

3% + 15% HST

Charlotte-

town

Tourism Accommodation Levy

(3%)

Applied to the purchase price.

Remitted to City monthly.

Revenue must be used to promote the municipality

as a tourist destination.

3% + 15% HST

St. John’s

Accommodation Levy (4%)

Applied to purchase price of accommodation .

Requires filing of quarterly report.

Allocated to Destination St. John’s to support

marketing and promotion of tourism.

4% + 15% HST

Yellowknife

----

5% GST

Whitehorse

----

5% GST

6. COMPLIANCE AND ENFORCEMENT

Compliance and enforcement approaches span a spectrum of strategies and tools, from soft

measures (e.g., education and information sharing), which are focused on achieving voluntary

compliance, to proactive requirements as part of the application process (e.g., attestations),

complaint-based measures (such as tip lines), platform-supported measures, and resourced

enforcement (e.g., audits). Some or all of these strategies are present in many of the jurisdictions in

our review, and this information is summarized in Table 10 (pp. 41-42).

SOFT STRATEGIES

Rather than pursue strict and audit/inspection-based enforcement, many jurisdictions, particularly

those with limited budgets, seek to foster an environment of voluntary compliance, including

through the implementation of soft strategies, which employ webpages, information campaigns,

and citizen engagement to build local understanding of regulations and associated processes. To

this end, most jurisdictions in our review have created dedicated short-term rental webpages, which

provide information on a range of topics, from regulatory development to application requirements;

some also include FAQ guides and best practice manuals. Only Tofino, Banff, Churchill, Fredericton,

and Iqaluit do not have such a site. Online information provided by Kelowna, Vancouver, Whistler,

Niagara-on-the-Lake, Halifax, and Charlottetown is particularly comprehensive, and enables

members of the public to easily access information on policy rationale, the regulatory process,

bylaws and current regulations, and common questions. In addition, Vancouver’s website hosts a

number of informational videos.

LICENCE-ORIENTED MEASURES

Compliance can also be strengthened as part of the application process, and specifically through

the various licence requirements detailed in the previous section (e.g., sharing of site, parking, and

guest management plans; undergoing property inspections for health, safety, fire, and general

compliance; and host attestations regarding knowledge of and adherence to bylaws, compliance

with safety measures, etc.). Further, Vancouver has introduced a notable way of ensuring listings

comply with provisions related to prohibited buildings (e.g., certain strata buildings, as well as

affordable housing and SROS). Specifically, the City has established (and keeps current) a

prohibited buildings registry, and when online applications are made for a new STR operation, the

address is automatically flagged against this list. In Halifax, prospective STR operators are also

required to add their properties to a Residential Rental Registry, through which Halifax Regional

Municipality authorities hope to develop a complete record of rental properties (including, but not

limited to, STRs) and thus gain a clearer picture of the local rental landscape (Halifax Regional

Municipality 2023).

In municipalities in which STR operators are subject to a provincial framework, compliance is

reinforced through the application process, as provincial licences are typically granted only after

compliance with local bylaws in confirmed. In Québec, for example, a condition of registration for

both a principal residence accommodation and a general tourist accommodation is the submission

of a notice of compliance with municipal bylaws, signed by a local authority. Similar systems exist in

Nova Scotia and Prince Edward Island.

Finally, in most jurisdictions in our review, authorities have introduced the licence condition that an

STR operator must post a valid licence number on all online listings. Only Banff, Newfoundland, and

Iqaluit have not introduced this requirement. This enables authorities to track online listings against

registered/licenced STRs, and supports targeted enforcement, indicating where inspections should

be prioritized.

TRADITIONAL ENFORCEMENT: COMPLAINTS, AUDITS, AND INSPECTIONS

Many jurisdictions rely on a combination of information received through local complaints and

inspection and audit powers to manage enforcement. Most jurisdictions appear to rely on existing

general bylaw complaint mechanisms (e.g., 311), while a select few (Kelowna, Victoria) offer

additional contact information for staff focused specifically on licensing or the STR market. Notably,

Niagara-on-the-Lake has enlisted a third-party service, Host Compliance, to support complaint-

based enforcement and the management of a large volume of STR-related complaints (Niagara-on-

the-Lake 2021). In most cases, it is difficult to discern the extent of proactive enforcement

approaches, such as active inspections. However, Kelowna, Vancouver, Whistler, and Banff all

indicate in policy materials and reports, and on public websites, engagement in active inspection.

In jurisdictions where platform registration requirements exist (Ottawa, Toronto, Halifax,

Charlottetown), active listing data obtained from platforms can be used alongside complaints and

additional information held by Administration to support a systematic and targeted approach to

enforcement. Such a system also appears to exist in Vancouver, where authorities rely on a

combination of proactive audits and data from licences, Airbnb, third-party scrapes, and

complaints.

PLATFORM ENGAGEMENT

Municipalities that have either created licensing requirements for or struck agreements with

platforms benefit from engaging platforms in compliance and enforcement efforts. Specifically,

Vancouver, Toronto, and Québec require platforms to be active collaborators in enforcement

efforts. Though Vancouver does not require the registration of platforms, the City has signed a

Voluntary Compliance Agreement ("Memorandum of Understanding - Airbnb Ireland and City of

Vancouver" 2018) with Airbnb, outlining stipulations regarding the operation of the platform in the

city. Part of the agreement rests on Airbnb supporting the implementation of Vancouver’s STR

regulations, which includes the platform agreeing to prevent new listings which do not provide a

business licence number. In Toronto, platforms must provide information on regulatory

requirements to hosts who register listings, as well as create mandatory licence number fields as

part of listing registration. The company must then ensure that all listings have valid registration

numbers consistent with those published by the City on its Open Data portal: validation of this must

occur before an operator can list an STR on the platform. Companies must also set out processes

for removing listings that do not comply and for handling problem operators. Most recently – and

following a deadly fire in an Old Montréal building housing several illegal STRs – the province of

Québec passed amendments to the Tourist Accommodation Act and Regulations to require active

engagement of digital platforms in enforcement efforts. Specifically, digital platforms cannot display

STR listings without the operator first providing an electronic registration certificate and including

the registration number and expiry date on the advertisement; the amendments also stipulate that

the platform must verify listings for such information.

Data provision requirements, which are often achieved through a data sharing agreement (DSA)

between the platform and the government, are another way of leveraging platform data to support

enforcement efforts. Such requirements exist in Vancouver, Toronto, Ottawa, Québec, Nova Scotia,

and PEI. In these cases, regulation stipulates that, as a condition of operating in the jurisdiction,

platforms must register and uphold a number of data provision responsibilities. In Toronto, for

example, the DSA sets out requirements regarding the records that the STR company must send to

the City on a regular basis, including STR operator transaction data (e.g., names, addresses,

registration numbers, dates and number of nights booked, prices charged, type of rental). The data

provision requirements in Ottawa are similar to those applied in Toronto, and include municipal

addresses of each listing, total number of nights each listing is rented in a calendar year, the

amount of revenue collected by accounts associated with each listing, the total amount of

Municipal Accommodation Tax collected, and the total number of complaints received. In Québec,

platforms are required to provide listing information to the Ministry of Tourism and must also assign

a company representative to liaise with the province.

TABLE 10: COMPLIANCE AND ENFORCEMENT APPROACHES

Soft compliance strategies

Licence-oriented measures

Complaint mechanism

Platform engagement

Proactive enforcement

Kelowna

STR webpage: policy rationale,

timelines; info on eligibility, app.

process, complaints; bylaw links

Informational materials: Operator’s

Guidebook

Licence #: Ensure all listings, promo

materials include licence #, approved

sleeping unit count.

Attestation: self-evaluation safety audit;

good neighbour agreement

Online complaint

mechanism on City

STR website; Bylaw

Services #; Licensing

branch contact

----

Active inspection of STR units by City

staff.

Tofino

No STR webpage: business licence

page with bylaw links, contact info

Informational materials: Respectful

Neighbourliness Brochure

Licence #: Ensure all listings, promo

materials include licence #

General Bylaw

Complaint

mechanism

----

Inspections by staff possible.

Vancouver

STR webpage: clear info about app.

Process, regulations, including videos

and eligibility quiz; links to bylaws,

reports; link to complaint tool; data on

active listings, licences, audits.

Licence #: Ensure all listings, promo

materials include licence #

Prohibited Buildings Registry: property

flagged during licence application,

prevents registration.

Online STR-specific

complaint mechanism

(through 311)

indicated on City STR

website.

Voluntary Compliance Agreement with Airbnb:

(1) licence field on listing (must be filled); (2)

data sharing; (3) host education; (4) remove

illegal units upon City request

Proactive audits and use of data

tools (licence data; Airbnb data; 3rd

party scrapes; complaints).

Enforcement Team of 7 focused on

data analysis, compliance (2020)

Victoria

STR webpage: info about process,

eligibility; links to forms, bylaw, FAQ

Informational materials: STR info sheet

Licence #: Ensure all listings, promo

materials include licence #

General online Bylaw

Complaint tool,

STR-specific email

contact

----

Inspections by staff possible.

Whistler

STR webpage: info on tourist

accommodation licensing, eligibility

flowchart, zoning rules; presents policy

direction and rationale.

Licence #: Ensure all listings, promo

materials include licence#

Database of tourist accommodation

inventory

General complaint

system (Bylaw

Services)

----

Active enforcement by staff on a

case-by-case basis.

Banff

No STR webpage: Dedicated webpage

to ongoing B&B Regulations review,

links to progress and reports

----

General online bylaw

complaint system

----

Council direction has historically

been to proactively enforce (~150

hrs/yr); Compliance Officer leads

this work.

Calgary

STR webpage: info about regulation,

licence costs, process, eligibility,

complaint lines, fines

Informational materials: Good Host &

Good Guest Guides

Licence #: Ensure all listings, promo

materials include licence #

General City of Calgary

complaint line and

website (311)

----

Approach has been to work with

operators to achieve voluntary

compliance.

Edmonton

STR webpage: info about regulation,

app. process, complaints; links to

operational plan, Guests Guide; links to

and info about relevant bylaws.

Informational materials: Information for

Guests Guide

Licence #: Ensure all listings, promo

materials include licence #

Operational Plan: Must be approved by

City staff before licence issued

General City of

Edmonton complaint

line and website

(311)

----

Inspections by staff possible.

Regina

STR-specific webpage: info about

licence types, reg. requirements,

application process, FAQs, links to

application and relevant bylaws

Licence #: Ensure all listings, promo

materials include licence #

URL and Platform: Operator must list in

app. platform they use; URL of listings

General bylaw

complaint line and

website; no info on

STR webpage

Upon written request of licence inspector,

platform or marketing agent must remove or

correct listing within 7 days of request

Inspections by licence inspector

possible.

Saskatoon

STR webpage: info about regs, STR and

licence types, application process,

FAQs, links to application and relevant

documents

Host Declaration: Submitted at time of

application, includes attestation of

compliance with life-safety standards

General bylaw

complaint line and

website; no info on STR

webpage

----

Inspections by licence inspector

possible.

Churchill

No STR-specific webpage

----

Town contact

information on

website.

----

Inspections by licence inspector

possible.

Soft compliance strategies

Licence-oriented measures

Complaint mechanism

Platform engagement

Proactive enforcement

Niagara

OTL

STR-specific webpage: info on MAT,

app process w/ required forms/plans,

links to bylaws, list of STRs,

compliance program, complaint line

Licence #: Ensure all listings, promo

materials include licence #

List of STRs: Town publishes public list of

all licensed accommodation

Compliance program in

partnership with Host

Compliance, to help

volume of complaints

----

Bylaw Enforcement officers enforce,

with support from Host Compliance

system. Given 4-year licence, must

be inspected every 2 years.

Ottawa

STR-specific webpage: info about host

requirements, regulations, application

process, fee schedule, complaint

reporting, prohibition process (condos,

landlords, etc.), links to relevant bylaws

Permit #: Ensure all listings, promo

materials include permit serial #, max.

overnight guest limit

Signed Declaration: Operator must sign

declaration of compliance will STR Bylaw

General complaint line

(311) indicated on STR

website.

Platforms must (1) register w/ City; (2)

maintain records for min 3 years (addresses, #

nights, revenue, MAT, complaints) and report

every 3 months; (3) convey regs to hosts; (4)

collect/remit MAT

Audits by Bylaw Officer possible:

examination of electronic records

held by platform, PM, permit holder

Toronto

STR-specific webpage: info about

regulations; info & app. requirements

for platforms, operators; high-level info

for residents and visitors; complaint

line information

Reg. #: Ensure all listings, promo

materials, invoices, include registration #

Open Data portal: info on all STRs with

active registration; updated daily

General City of Toronto

complaint line (311) or

online process.

Platforms must: be licensed; have data

agreement w/ City; keep records for 3 years

(address, licence, nights, price, revenue);

create host, guest accounts; publish complaint

info; communicate regs to hosts

City officials may inspect units; audit

or examine all books and records

and any account held by operator or

platform.

Montréal

STR-specific webpage:

▪ City of Montréal: overview of/links to

prov. registration; portal for rules by

borough.

▪ Province & CITQ (registration body)

have websites with info, links to regs,

online application

Reg. #: Ensure all listings, promo

materials include registration #

Quebec: Public register of STRs with reg.

numbers, expiry dates, etc.

Municipal approval: Licence not granted

without signed notice of compliance with

municipal bylaws

City website refers to

Revenu Québec to

make complaints

Rules for platforms in legislative and regulatory

amendments: (1) cannot display listings

without registration certificate and expiry data

– must verify; (2) must provide information to

Ministry on listings; (3) must assign company

representative to Quebec

Revenu Québec manages

inspections.

New (2023) Montreal enforcement

task force (coordinator and 3

inspectors) to focus on illegal listings

in Ville-Marie; le Plateau-Mont-Royal;

le Sud-Ouest

Québec City

STR-specific webpage:

▪ Québec City: overview of STR types;

local rules & links; links to prov.

▪ Province & CITQ (registration body)

have websites with info, links to regs,

online application

Reg. #: Ensure all listings, promo

materials include registration #

Quebec: Public register of STRs with reg.

numbers, expiry dates, etc.

Municipal approval: Licence not granted

without signed notice of compliance with

municipal bylaws

311 Complaint Line

Rules for platforms in legislative and regulatory

amendments: (1) cannot display listings

without registration certificate and expiry data

– must verify; (2) must provide information to

Ministry on listings; (3) must assign company

representative to Quebec

Revenu Québec manages

inspections.

Halifax

Tourist Accomm. Webpage (NS):

Info on legislation, types of accomm.;

registration process, cost; contact info

HRM webpage: info about bylaw

changes; definitions; eligibility; process

for registration; FAQs

Licence #: Ensure all listings, promo

materials include licence #; public registry

Municipal approval: Operator must

declare in application that use

complies with municipal land-use

bylaw

General HRM bylaw

complaint system.

Platforms must: (1) register with province; (2)

ensure listings have valid licence #; (3) keep

records (listing addresses; nights rented;

nightly & total price charged); and (4) share

records as requested.

Legislation permits Province to enter

into data sharing agreements with

municipalities to support

enforcement of municipal bylaws,

inform planning.

Charlottetown

City – STR webpage: FAQ; forms and

approvals; eligibility; process; links to

background reports and bylaws

Tourist Accomm. Webpage (PEI):

Info on leg. framework, purpose,

registration, reporting requirements

Licence #: Ensure all listings, promo

materials include licence #

Public list.: Province maintains list of

licensed, noncompliant units

Municipal approval: Compliance with

municipal rules is verified

General bylaw

complaint system

Platforms must register with province, keep

transaction records (7 years): name, address,

reg. #; nights rented; nightly rate, total price.

Records must be provided upon request

Inspections by province possible

St. Johns

Tourist Accomm. Webpage (NL)

Basic information on licensing

requirements and process, relevant

legislation and regulations

Public Registry

General bylaw

complaint system

----

Unclear whether/how enforced

Iqaluit

No STR-specific webpage

----

City officials may inspect.

Yellowknife

STR-specific webpage: info about STR

types, licensing requirements, relevant

bylaws, other permit requirements,

contact information

Licence #: Ensure all listings, promo

materials include licence #

----

City officials may inspect.

7. BRINGING IT TOGETHER

A TYPOLOGY OF CANADIAN RESPONSES

From our analysis in this report, it is evident that while it is occasionally presented as contentious in

public discourse and news reports, the regulation of the STR market is an increasingly common and

accepted practice in Canadian jurisdictions: not a question of “if,” but rather a matter of “how” and

“to what extent.” In particular, licensing or registration requirements are widespread, such that for

STR hosts, this can now largely be conceived of as merely another step in the process of preparing

to list a property on an STR platform. Taxation of such activity on par with other forms of tourist

accommodation is also a common approach. At the same time, it is evident that there are marked

differences in the STR regulations present within Canadian municipalities, not only in terms of their

restrictiveness, but also when considering their complexity, their constituent elements (including

the various frameworks of which they are composed), and the orders of government they involve.

To enable a more systematic comparison of these myriad approaches—and to make better sense of

the Canadian policy response—we developed a typology of planning and regulatory responses.

Typologies are useful for synthesizing and making sense of the results of comparative research,

and can also produce generalizations about what policy efforts have looked like overall and across

contexts in reference to a particular management objective. They allow for relational comparisons

among different cases. On the STR question, several typologies have been set out in the academic

literature. Nieuwland and van Melik (2020), for example, place STR policy approaches along a

continuum of stringency (spanning full prohibition, laissez-faire, and limitation with certain

restrictions), where prohibition implies bans on STR activity (either overall or in a particular

community), laissez-faire suggests few concrete measures with the exception of tax collection

agreements with platforms, and limitation describes the presence of some or all of a mixture of

quantitative, locational, density-based, and qualitative restrictions.

Quantitative restrictions

involve limitations on licences, number of guests, and nights rented annually; locational rules aim

to manage the spatial dimension of the market, limiting STRs to certain areas; density restrictions

seek to limit the concentration of STRs in certain areas; and qualitative restrictions define and

place limits on the type of listing and introduce health and safety requirements.

Furukawa and Onuki (2019) use the same stringency continuum, but specify, in addition to laissez-

faire and prohibitive approaches, general (no distinction between types of STR operation),

residence-oriented (regulations either ban or impose limits on non-primary residence STRs); host-

See also Finck and Ranchordàs (2016) and Crommelin et al. (2018), in which similar understandings of regulatory

differences are outlined.

oriented (regulations limit entire-unit operations where the host is absent); and hybrid (combine

host- and residence-oriented restrictions. Setting out the most distinct typology, von Briel and

Dolnicar (2020) group popular tourist destinations by four categories: liberal (weak regulation,

enabling activities); moderate (interventions exist to enable tax and data collection); moderate-

collaborative (city is willing to work with platforms and community, including to develop tourism

plans, and rules are frequently reviewed and changed); and protective (heavy spatial and

operational restrictions and requirements).

One shortcoming of the above typologies is that they focus primarily on the stringency of

regulations, without considering other aspects of management, such as order(s) of government

involved and complexity of the overall response. Drawing on elements of the above approaches, but

also integrating considerations of complexity and multi-level governance, we developed a two-

dimensional typology (Figure 1; p. 45) for comparing the management responses adopted in

Canadian jurisdictions. In this model, complexity refers to the extent to which classifications and

limitations reflect different categories of use (e.g., different categories of STR, other forms of tourist

accommodation, etc.), levels of activity (e.g., primary residence, entire unit), and specific

exemptions, as well as if operators are subject to multiple regulatory frameworks, spanning

jurisdictions. Restrictiveness captures the relative strength of prohibitions, including considerations

of spatial restrictions, quotas, and limitations on operation types. Importantly, we conceptualize

both complexity and restrictiveness as existing as a continuum, rather than as binary concepts (i.e.,

simple/complex; permissive/restrictive).

Along the spectrum of complexity, we note three ideal-type categories: basic and streamlined

(generally one category of use, limited introduction of spatial and/or quantitative elements, simple

application process); technical and multi-dimensional (several categories of use and licence, with

different requirements; existence of spatial and/or quantitative rules across different bylaws, which

condition eligibility; involved application process with specific conditions; licence categories for

platforms and property managers); and multi-jurisdictional (involving compliance with at least two

orders of government

). In addition, we indicate three categories of restrictiveness: permissive (no

or very few restrictions based on use type); moderate-proactive (spatial restrictions for primary use

STRs; night caps and other quantitative measures; operational requirements and registration

systems that support compliance); and protective (strict measures for or prohibitions of primary use

STRs in most areas; zoning strictly dictates use types; prohibition in several dwelling types).

With the caveat that provincial tax compliance is, on its own, insufficient to meet this criteria. That is, jurisdictions

that have local rules, and which are subject to a provincial accommodation tax (e.g., Calgary), are not considered to be

in this category.

PROMISING PRACTICES

Overall, regulatory approaches in Canada reflect a more measured and exacting approach by

comparison to early international efforts, particularly to the extent that they reflect more

sophisticated understandings of market actors and contain provisions introduced to address

different types of activity. For example, several Canadian jurisdictions do not ban the operation of

secondary property listings outright, instead distinguishing such operations from those

corresponding with a host’s primary residence and introducing tiered licensing schemes which

impose higher entry costs for those looking to operate listings of a more commercial nature.

Further, in several Montréal and Québec City boroughs, primary residence listings are permitted

throughout, but secondary listings are contained to select commercial areas; this is similar to the

approach taken in Kelowna, where primary use operations (i.e., non-principal residence STRs) are

restricted to set tourist commercial and health districts.

Some regulatory approaches also involve platforms. For example, in Toronto, Nova Scotia, PEI, and

Ottawa, to be able to operate platforms must first register with the government. Registration not

only provides governments access to additional revenue, but also enables the imposition of

additional requirements related to data collection and information sharing. However, regulatory

frameworks which recognize platforms as market actors are not the only approach. In recent years,

platforms—and Airbnb in particular—have altered the nature of their interactions with local

FIGURE 1: TYPOLOGY OF POLICY RESPONSES

authorities to focus on partnerships and agreements, rather than legal battles, and in many cases,

governments have been able to draw on this shift to fill gaps, particularly in terms of compliance,

enforcement, and access to data. In Canada, several jurisdictions have now struck agreements with

Airbnb specifically to leverage the platform’s position, expertise, and data in order to improve

regulatory effectiveness.

Other jurisdictions have found ways to introduce flexibility into regulatory approaches to allow for

adjustments in the face of emerging issues and shifting market dynamics. In Regina and

Saskatoon, for example, bylaws include particular provisions for secondary property STRs that

prohibit the granting of new primary use licences if more than 35 per cent of the dwelling units in a

multi-dwelling structure are non-PR STRs, or if the city’s vacancy rate falls below three per cent.

These are best practices that merit should be considered elsewhere: it is indeed noteworthy that,

given widespread community concerns about availability and affordability of long-term rentals, only

two jurisdictions have introduced such measures.

Finally, numerous municipalities in British Columbia, through permissions in provincial tax

legislation, are innovating in terms of the purposes towards which revenues generated through

accommodation taxes can be directed. Here, i.e., to support affordable housing initiatives, rather

than tourism budgets, for example). This is one way of balancing or offsetting the community

effects of STR market growth without banning or placing severe restrictions on the practice, and in

a way that directly addresses the area of concern.

GAPS AND OPPORTUNTIES

It is well-documented that local efforts to regulate the STR market internationally have been

hampered by compliance and enforcement struggles, despite the importance of this aspect to the

success of regulatory efforts. It is likely that such issues also impact regulatory effectiveness in the

jurisdictions reviewed in this study. Part of this is due to lack of staff capacity within local offices,

the dynamic nature of the market and constant proliferation of listings, and limited or incomplete

data access (Wegmann and Jiao 2017; Nieuwland and van Melik 2020). As detailed in the

literature, meaningful enforcement likely requires dedicated staff operating exclusively in the area

of short-term rentals (Wegmann and Jiao 2017). In Canadian jurisdictions, the ability and

commitment of local governments to undertake enforcement with the rigour required to achieve

high compliance is unclear. Most jurisdictions in our review employ complaint- and audit-based

systems, which are reliant upon concerned residents reporting issues through a complaint line or

online portal, as well as proactive inspections of STR units by licence inspectors or bylaw officers,

and it is expected that smaller governments in particular have limited staff and budgetary capacity

in this area. Indeed, even the largest cities in Canada have reported administrative strain, with

recent reports out of Toronto noting that City Administration was struggling to process thousands of

licence applications and required more staff to close the enforcement gap (Woodward 2021).

As we detailed in the section on compliance measures, platform engagement is one approach to

overcoming some of the above challenges in this area. However, reports out of Toronto also

indicate that co-regulation remains an imperfect process – or a work in progress – with Airbnb

suggesting that certain aspects of enforcement, such as flagging listings or comparing new listings

to the City’s registry of licensed operators, remain the responsibility of the City (Woodward 2021).

Indeed, coregulatory models remain novel in the STR context, and jurisdictions will continue to

learn from efforts to navigate relationships with platforms with policy objectives in mind.

Further, additional factors contribute to low compliance, including a number of barriers inherent

within the licensing and registration system for hosts. The first concerns the extensiveness and

accessibility of the application process, particularly if hosts are required to comply with bylaws and

regulations enacted by several levels of government, and across departments (e.g., land use,

licensing, and tax). Secondly, low compliance could be linked to a lack of awareness among small

scale operators that they must obtain a business licence to share space in their home: such

individuals may not be deliberately avoiding compliance with STR regulations but, at the same time,

may not conceive of their participation in the STR market as constituting business activity, or at

least activity that requires a licence for commercial operations. At the same time, however, it is

cause for regulators to reflect on the suitability of licensing schemes—particularly those which do

not distinguish between licence classes, or which use business and commercial language—for all

types of STR activity, even that which reflects small-scale home-sharing operations. As a result,

there could be merit in distancing STR registration from business licensing processes.

Multi-Level Governance

One potential path forward that would support improved regulatory capacity, effectiveness, and

compliance would be to recast the management of the STR market in broader governance terms

and shift to a provincial registration framework model. As the STR market becomes more complex

and partnership with digital platforms a necessity, provinces are in a stronger position to lead

governance efforts, particularly with regard to registration, data management, and market

oversight. Indeed, management systems for general tourist accommodation already exist in

Quebec, Nova Scotia, and Prince Edward Island and—as indicated by recent reform initiatives in

these provinces—these legislative frameworks are adaptable for the purposes of STR market

operations, including platform management. Further, the Union of B.C. Municipalities has called on

the provincial government to introduce a provincial regulatory framework for short-term rentals,

similar to that in place for ride-sharing, to ensure stronger platform accountability and information

validation, and to improve enforcement capacity that is currently lacking at the local level (Union of

B.C. Municipalities 2021).

Under such an approach, provinces would have additional opportunity—and capacity—to set,

through consultation and expert review, clear policy objectives related to the management of the

STR market, in line with provincial dynamics and strategies for other sectors, particularly those

impacted by the STR market, such as housing and tourism. For example, in the Atlantic provinces,

governance of the STR market could be primarily aimed at boosting tourism, and thus the

framework might be overseen by the tourism ministry. Similarly, provinces that have experienced

considerable housing market issues, such as British Columbia, might adopt strategies aimed

primarily at ensuring access to affordable housing, and thus see that the framework falls under the

purview of the minister responsible for housing.

Such a framework would also create regulatory certainty in jurisdictions across the province, and

done effectively, would reduce administrative burden for local governments, many of which do not

have sufficient resources to administer and enforce robust licensing and registration systems.

Given several provinces have already established agreements with platforms regarding the

collection of accommodation tax, PST, and other such charges, moving a licensing and registration

system to the provincial level would reflect a streamlining of processes under a single level of

government (even if done by distinct authorities). Involving the provincial government in this way

would free up local governments to focus on effective planning and land-use frameworks,

particularly those related to zoning and community health and safety, as has been done in

Montréal, Quebec City, Charlottetown, and Nova Scotia.

CONCLUDING THOUGHTS

In the past five years, Canada’s STR market has grown significantly, and now extends to

communities of all varieties and in every region of the country. Planning and regulatory measures

have proliferated in response, and at the time of writing, additional local governments, including

Hamilton, Winnipeg, and Sault Ste, Marie, are reviewing or finalizing plans to implement

management frameworks. As we find over the course of the analysis done in this paper, though

many governments across Canada have only recently adopted regulatory frameworks, trends and

promising practices can already be observed. However, we also note that, as implementation

proceeds, authorities will need to find ways to overcome interconnected challenges spanning

compliance and enforcement, access to data and information, and management of platforms. Two

approaches—platform engagement and the introduction, at the provincial level, of STR registration

frameworks—show particular promise in the face of these issues.

The principal aim of this report has been to take stock of the various regulatory approaches

Canadian jurisdictions have applied to date in an attempt to manage platform-mediated home

sharing in their communities. In conducting this review, we sought answers to general questions

about the nature and extent of the regulatory push in Canada, whether trends and themes could be

identified across efforts, and whether jurisdictions are developing regulatory approaches that

account for the complexity of the STR market (as three- or four-sided, for example) and reflect an

advanced understanding of market actors and drivers of participation. From here, further research

is required to assess the suitability, effectiveness, and impact of these chosen regulatory

mechanisms, and to uncover best practices and areas of particular challenge—including whether

patterns exist across jurisdictions of a particular nature (e.g., whether optimal approaches as well

as challenges are similar in all mountain resort towns). Additional research efforts might focus on

the drivers of regulatory approaches, with an eye to discerning how local dynamics—whether

economic, political, cultural, or otherwise—and various stakeholder groups shape policy and

regulatory responses.

50 
 
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REFERENCED LEGISLATION AND BYLAWS

Jurisdiction

Legislation and Bylaws

Kelowna

Short-Term Rental Accommodation Bylaw

City of Kelowna Municipal and Regional District Tax Bylaw

Zoning Bylaw

Official Community Plan Bylaw

Tofino

Business Licence Regulation Bylaw

Zoning Bylaw

Official Community Plan Bylaw

Vancouver

Licence Bylaw

Zoning and Development Bylaw

Victoria

Zoning Bylaw

STR Regulation Bylaw

Whistler

Business Licence Bylaw

Tourist Accommodation Business Regulation Bylaw

Zoning Bylaw

Banff

Land Use Bylaw

Calgary

Business Licence Bylaw

Edmonton

Business Licence Bylaw

Zoning Bylaw

Regina

Residential Short Term Accommodation Licensing Bylaw

Saskatoon

Business Licence Bylaw

Zoning Bylaw

Churchill

Business Licensing Bylaw

Fees and Charges Bylaw

Regulation and Licensing of Accommodation Providers Bylaw

Zoning Bylaw

Niagara-OTL

Short Term Rentals, Licensing, Zoning & Official Plan Bylaws

Ottawa

STR Bylaw

Zoning Bylaw

Toronto

Licensing and Registration of Short-Term Rentals Bylaw

Zoning Bylaw

Fees and Charges Bylaw

Québec

Tourist Accommodation Act and Regulation

Various urban planning bylaws in Montréal and Québec City

Fredericton

Zoning Bylaw

Nova Scotia

Tourist Accommodations Registration Act and Regulations

HRM Regional Planning Strategy

Land Use bylaws (for different HRM plan areas)

PEI

Tourism Industry Act and Regulations

Charlottetown Zoning & Development Bylaw

Charlottetown Official Plan

St. John’s

Newfoundland Tourist Accommodations Act and Regulations

Yellowknife

Business Licence Bylaw

Zoning Bylaw

Iqaluit

Business Licence Bylaw

Zoning Bylaw

General Plan