Short-term and holiday lets in England: what a Manchester landlord needs to know

Short-term and holiday lets sit in a legal gap. They are mostly carved out of the assured tenancy rules built for long-term renting, there is no Manchester-specific licence for them, and several widely-reported changes are still only proposals. Here is where the position actually stands, and what is simply announced.

Holiday let or assured tenancy: the practical dividing line

Most tenancies of a dwelling in England are automatically assured tenancies under the Housing Act 1988, giving the tenant significant statutory protection. Schedule 1 to that Act lists the lettings excluded from assured tenancy status. Paragraph 9, under the heading "Holiday lettings," excludes a tenancy "the purpose of which is to confer on the tenant the right to occupy the dwelling-house for a holiday."

The dividing line is the purpose of the letting, not the length of the stay. A genuine holiday let, taken for leisure rather than as someone's home, falls outside the assured tenancy regime regardless of booking length. A letting that is really providing someone's home, however short the paperwork says, risks being treated as an assured tenancy, with the restrictions that brings on recovering possession. If a short-term booking turns into someone living there as their only home, get advice from a solicitor before assuming the holiday-let label still applies.

Planning permission: the position in Manchester right now

There is no dedicated planning use class for short-term lets in England. The Town and Country Planning (Use Classes) Order 1987 was amended in 2022 to insert new classes C5 (home used otherwise than as a main residence, let for 183 days or fewer a year) and C6 (commercial short-term letting of up to 31 days a stay) — but that amendment, the Town and Country Planning (Use Classes) (Amendment) (Wales) Order 2022, applies only in Wales. England has not adopted equivalent classes, and a 2023 consultation proposing one has not been brought into force.

That leaves the ordinary Use Classes Order position for England. Letting your own main home occasionally, including while you are away, is generally not treated as a material change of use requiring planning permission. Letting a property that is not your main home as a short-term let more frequently, or running it as a dedicated holiday-let business, is more likely to amount to a material change of use needing planning permission from Manchester City Council. Whether a pattern crosses that line is a judgement for the council, not a fixed rule, so check with the planning department before committing a property to a holiday-let model.

The national registration scheme: legislated, not yet operating

The Levelling-up and Regeneration Act 2023 gives the Secretary of State power to make regulations requiring registration of short-term rental properties in England (section 228). That section has been in force since 26 December 2023 — but it is an enabling power, not the scheme itself. Government policy from February 2024 described a planned mandatory, national register, with operational detail to follow and no date given.

As of October 2026, the detailed registration regulations have still not been made, and the scheme is not operating. GOV.UK's own guidance, updated 2 October 2026, lists registration under the heading "Register your property (not yet in force)" and states: "The UK government is introducing a mandatory national registration scheme for short-term lets in England. It is expected to begin in March 2027." There is no registration duty in force today, and "expected to begin" is not a commencement date — check gov.uk again before relying on it.

London's 90-night rule does not apply here

You may also see references to a "90-night rule." That comes from the Deregulation Act 2015, which allows a London home to be let for successive short periods, up to 90 nights total a calendar year, without needing planning permission. It is specific to Greater London and has no effect in Manchester, where the ordinary Use Classes Order position above applies instead.

Tax: the Furnished Holiday Lettings regime has been abolished

The Furnished Holiday Lettings (FHL) tax regime no longer exists. HMRC's guidance confirms the FHL rules "cease to apply in tax years commencing on or after 6 April 2025" for Income Tax, and from 1 April 2025 for Corporation Tax. FHLs that previously qualified are now taxed broadly in line with other residential lettings — affecting how mortgage interest is relieved, and the capital allowances and gains treatment that used to apply. If you hold, or are weighing up, a furnished holiday let, get current advice from an accountant; anything you knew about FHL tax before April 2025 is very likely out of date now.

Safety duties: do not assume they transfer automatically

Ordinary landlord safety duties do not transfer to holiday lets as one package — each regulation has its own wording. The Gas Safety (Installation and Use) Regulations 1998 apply broadly to residential premises occupied for payment under a lease or licence, and HSE guidance confirms equivalent duties in comparable paid-accommodation settings such as hotels and B&Bs, so a gas safety check regime is the safer assumption for a holiday let. By contrast, the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 and the Smoke and Carbon Monoxide Alarm (England) Regulations both turn on a "specified tenancy" or "relevant tenancy" giving the occupier the right to live there as their "only or main residence" — a test a genuine holiday let usually fails, so those two sets of regulations will often not apply as they would to a long-term tenancy. Check which regulations actually bite on your arrangement, rather than copying across the checklist for an assured tenancy.

Mortgage, insurance and your lease

As general market practice rather than law, a standard buy-to-let mortgage and landlord insurance policy are usually written around assured shorthold tenancies, not Airbnb-style letting. Many lenders and insurers require separate consent, or a different product, before covering short-term letting, and letting without it can put your cover and mortgage terms at risk. Check your mortgage conditions and policy wording, or ask your lender and insurer, before you list a property. If the property is leasehold, the lease may be the real obstacle: most residential leases restrict or prohibit short-term sub-letting, separately from planning or tenancy law — see service charges and buying a leasehold flat for how to check a lease before you commit.

For the wider checks before taking on a let in Manchester, see buy-to-let checks and HMO licensing and Article 4; if you are weighing short-term letting against selling, sell or keep letting covers that decision. For what we charge to manage a let, see our fees.

The bottom line

Short-term letting in England is being reformed in stages, but most of that reform is still proposed or partly built. The holiday-let exclusion from assured tenancy status is settled law. The national registration scheme is legislated for but not yet operating. A dedicated English short-term-let use class does not exist. The FHL tax regime is gone. Treat anything else you read as a snapshot that may already be out of date.

This is general information current at October 2026. It is not legal, tax or planning advice. Confirm the current position with a solicitor, an accountant, and Manchester City Council's planning department before committing a property to short-term letting.

If you are weighing up short-term letting against a standard tenancy for a property in Manchester, call us on 0161 710 4510 or visit us at 12–14 Midland Street, Manchester M12 6LB — we can talk through the practical side of letting while you take legal and tax advice on the rest.