Edinburgh's August festivals (the Fringe, the International Festival, the Book Festival and the Tattoo combined) drive what is probably the densest concentration of accommodation demand in the UK calendar. For roughly three weeks the city absorbs hundreds of thousands of additional visitors, hotels sell out months in advance, and per-night rates for STL accommodation reach multiples of their off-season equivalents.
The temptation for any Edinburgh property owner with space to spare is obvious. So is the question. What do you actually need in place, legally, to let your property during the festival?
The short answer is: it depends on your property, your relationship to it, and what kind of use you are putting it to. The longer answer, with the four scenarios we get asked about most often, is below.
The headline rules
Two regulatory regimes apply to any short-term let in Edinburgh, and both need to be addressed:
1. Licensing. Under the Civic Government (Scotland) Act 1982 (as amended), any short-term let in Scotland requires a licence. There is no "festival-only" exemption from the licensing requirement. Letting your property for a single night without a licence is a criminal offence carrying a fine of up to £2,500 per let. Edinburgh's licensing department is active and well-resourced; festival-period unlicensed activity is highly visible and is routinely enforced.
2. Planning. Edinburgh's whole local authority area was confirmed as a Short-Term Let Control Area (STLCA) on 5 September 2022. Within a STLCA, the use of a dwellinghouse for secondary letting is deemed to involve a material change of use and therefore requires planning permission. Home letting and home sharing are excluded from the deeming provision and do not on that basis require planning permission, though there can still be planning considerations in particular cases.
These two regimes are separate and administered by different parts of the Council. Holding a licence does not satisfy your planning obligations. Holding planning permission does not satisfy your licensing obligations. Both, where applicable, must be in place.
There is also a third regime that applies to a minority of properties (HMO licensing, which applies to flats let to multiple unrelated occupants on a longer-term basis). This is a separate matter again from STL licensing - critical for the student-let scenario below.
What licence type fits you?
The Civic Government Order 2022 defines three operating categories. The licence application form will ask you to pick one of these:
| Category | What it covers | Common festival scenario |
|---|---|---|
| **Secondary letting** | Letting a property that is not your principal home | Investment flat let during August |
| **Home letting** | Letting your principal home entire while you are away | You leave town for August and let your home |
| **Home sharing** | Letting part of your principal home while you remain | Renting out spare rooms while you live in the rest |
Each category has its own paperwork, fee scale, and implications under the planning regime. But for festival operators the more important distinction is often between a full licence and the two short-form routes that exist alongside it: temporary exemptions and temporary licences. These deserve their own section.
Temporary exemptions and temporary licences
For an operator who only intends to let during the festival, applying for a three-year full STL licence is usually disproportionate to the activity. Two shorter mechanisms exist and they are commonly conflated. They are not the same.
Temporary exemption
A temporary exemption is an exemption from the requirement to hold an STL licence for a defined short period. The operator does not hold a licence; the council has formally accepted that, for the limited duration specified, no licence is required.
Edinburgh has been granting temporary exemptions for festival-period operators, including:
- Owners who let their home for a single August period each year
- Owners who let an otherwise-empty property for a short defined window
- Operators with one-off circumstances (a family event period, a single-property short-term opportunity)
The application is simpler than a full licence. The fee is meaningfully lower. Processing times are typically shorter. The exemption is granted at the council's discretion and is generally limited to short periods - in practice, single annual windows of a few weeks rather than recurring use throughout the year.
A note on planning. In strict legal terms a temporary exemption only addresses the licensing regime. It does not, on its face, exempt you from the planning regime, and on a strict reading of the rules an operator in Edinburgh doing secondary letting would still need planning permission for the change of use even where a temporary exemption is in place.
In practice, we have observed that the council rarely treats temporary exemptions as triggering a separate planning consideration. Operators relying on a temporary exemption have, to date, generally not been pursued for the parallel planning point. This is not a guarantee. The position can change at any time - and given the direction of travel on planning enforcement in Edinburgh, we would not assume the current practice continues indefinitely. Please contact us for the current position before you rely on this - we keep close to council practice and can give you a clear read at the time you are planning your festival operation.
Safety requirements (gas, electrical, insurance, fire risk assessment) also continue to apply during the exempt period and the operator remains responsible for them.
Temporary licence
A temporary licence is a real, time-limited licence granted under Paragraph 8 of Schedule 1 of the Civic Government (Scotland) Act 1982. It typically lasts up to six weeks, is granted at the council's discretion, and goes through a streamlined version of the standard licensing process.
A temporary licence sits between a full three-year licence and a temporary exemption. It is useful where the operator needs a formal licensed status (for example because they are advertising on a platform that requires the licence number, or because they want the legal certainty of a licence rather than an exemption) but where applying for the full three-year licence would be excessive.
Like a temporary exemption, a temporary licence does not address the planning regime. Planning permission requirements are determined entirely separately.
What certificates do you actually need?
Edinburgh changed its certification requirements for temporary exemptions on 31 January 2025. The rules now turn on which let type you are applying for, and the practical effect is to materially lower the paperwork for home-letting and home-sharing operators going through the festival on a temporary exemption.
Home Letting or Home Sharing (temporary exemption):
- Gas safety certificate if any gas appliance is present.
- EICR is no longer required.
- PAT testing is no longer required.
- Fire risk assessment still applies.
- Both an EICR and PAT are still recommended as good practice, but they are no longer needed for the temporary exemption itself.
Secondary Letting (temporary exemption):
- Gas safety certificate (where applicable).
- EICR still required.
- PAT still required.
- Fire risk assessment.
- Floor plan typically requested.
Full three-year STL licence (any let type):
- The full set: gas safety certificate, EICR, PAT, fire risk assessment, fire safety checklist, floor plan and site location plan.
In other words, the change in January 2025 was a real loosening for owners letting their own homes during the festival on a temporary exemption. For secondary letting the bar is unchanged. For a full three-year licence the bar is unchanged either way.
If you are unsure which route applies to your property, or whether your existing certificates would meet Edinburgh's current expectations, please get in touch - we keep up with how the council is actually processing applications in practice, not just what the guidance says on paper, and we can take the whole application off your hands if you would prefer.
When does each apply?
In rough order of when each tends to be the right answer:
- Temporary exemption - festival-period letting of your own home; one-off short use of an investment property where the planning position is already established; any short-window use where the operator wants the lightest-touch route and the council is likely to agree.
- Temporary licence - where a formal licence number is required (some platforms now enforce this); where the operator wants the regulatory comfort of a licence rather than an exemption; where the council has indicated an exemption is unlikely to be granted in the particular circumstances.
- Full three-year licence - any operator intending to let beyond a single short annual window; year-round operators; operators who want long-run regulatory certainty.
We will walk through the four scenarios that cover the great majority of festival-period enquiries, and indicate which of these routes is typically the right fit in each.
Scenario 1: Home letting (you let your own home while away)
This is the scenario most Edinburgh residents fall into. You normally live in the property. You plan to be out of the city for two or three weeks in August, often at a holiday let elsewhere. You want to let your home short-stay during your absence to make the trip pay for itself.
Licensing. You need a Home Letting licence. Edinburgh grants these on the standard process, and the fee is meaningfully lower than the secondary letting equivalent. For a single short window each year - which describes most festival operators in this scenario - a temporary exemption is usually the right route. It is simpler, cheaper and faster than either a full or temporary licence and Edinburgh has been granting them for home letting during festival period. A temporary licence is an alternative if a formal licence number is needed.
Planning. Home letting is explicitly excluded from the STLCA deeming provision. You do not need planning permission for the home letting use itself.
Practical considerations. You will still need to comply with all the standard licensing conditions: safety certificates (gas, electrical, EICR), valid building and contents insurance covering the let, a fire risk assessment, satisfactory cleaning between guests, and appropriate guest information. Your home insurance may not cover the let period - check, and if necessary obtain dedicated STL cover for the period.
This is the most achievable route for festival letting, and the one we recommend most operators consider first.
Scenario 2: Home sharing (your own home, you stay)
You stay in the property. You let one or more rooms during the festival, with shared use of the kitchen and living areas.
Licensing. Home Sharing licence required. Same basic licensing requirements as home letting.
Planning. Excluded from the STLCA deeming provision. No planning permission required for the home-sharing use itself.
Practical considerations. Home sharing is broadly the most straightforward category to license, and as long as the property remains your principal home, the planning position is also clear. The catch is that it requires you to be in residence throughout the let, which not everyone wants to do during festival period.
Scenario 3: Secondary letting (you have an investment property)
You own a flat or house in Edinburgh that you do not live in. It might be let to long-stay tenants for most of the year, vacant, or already operating as a year-round STL. You want to use it as an STL during the festival.
Licensing. Secondary Letting licence required. Substantially higher fee than the home letting equivalent and a more onerous application. For a single festival period you may be able to apply for a temporary exemption or temporary licence instead, and we would recommend doing so where the underlying planning position is settled. Without that planning position settled, however, a temporary exemption from licensing does not address the bigger issue.
Planning. Because you are inside the STLCA and the use is secondary letting, planning permission is required. The deeming provision in Section 26B of the Town and Country Planning (Scotland) Act 1997 means the question is not "is this a material change of use" but rather "what permission do you have for this material change of use". Without permission, the use is unauthorised.
Edinburgh's planning permission approval rate for secondary STL use in flats since the STLCA was confirmed has been very low. Even at full festival rates the economics of pursuing a fresh planning application purely to let for three weeks rarely work.
There is, however, one important nuance: if your STL use pre-dates the STLCA's confirmation (5 September 2022), you may be able to secure a Certificate of Lawfulness for Existing Use or Development (CLEUD) confirming that your use is lawful under the pre-STLCA regime. A CLEUD, once granted, is durable and removes the planning permission requirement. For long-established festival operators with pre-2022 letting history, this is often the route that makes the year-on-year economics work.
If your secondary letting use post-dates 5 September 2022 and you do not have planning permission, the position is materially more difficult and our advice is to take detailed counsel before committing the property to festival-period STL use.
Scenario 4: Student flat let as a festival let (the August arbitrage)
This is a category we are asked about a great deal. The setup: an Edinburgh flat is let to students on a Private Residential Tenancy for the academic year (typically September through June). The students vacate in early summer. The flat sits empty through July and most of August. The owner wants to let it as an STL during the festival.
The economics are obvious. Edinburgh student lets often produce rents of £600 to £800 per room per month; the same flat let furnished short-stay during festival period can produce a multiple of that in a single fortnight. The question is what is needed to do it legally.
The bad news. This scenario is secondary letting for both the licensing and planning regimes. The owner does not live in the property, so home letting and home sharing categories do not apply. Edinburgh sits within the STLCA so planning permission is required as well as a licence. And the existing HMO licence (if the flat is HMO-licensed for term-time use, as is common for shared flats of three or more unrelated occupants) does not transfer or convert. HMO and STL are different licensing regimes entirely.
The added complication. Mixed-use properties that switch between residential and short-stay multiple times per year are not, in planning terms, simple. A pattern of student tenancy for ten months and STL for one to two months may, depending on the facts, count as dual-use that requires its own bespoke planning consideration. Operators who simply assume "the flat sits empty in August so I can let it short-stay" may discover that the change of use, even temporary, triggers a planning issue.
What can be done. For owners with long-established festival letting history (pre-STLCA), a CLEUD application may secure the position. For owners who have been doing this informally for years without ever holding a licence or planning permission, the position is now exposed and a careful conversation with a planning consultant is the right first step. For owners contemplating doing it for the first time post-2022, we generally counsel that the economics rarely justify the regulatory exposure unless the property has a substantive festival-period letting history that could be evidenced and lawful status established.
A note for purpose-built student accommodation (PBSA): PBSA blocks are typically excluded from the STLCA effect because they are not "dwellinghouses". This is a narrow category and operators should not assume it applies without checking. The vast majority of "student flats" in Edinburgh are converted residential dwellings let on PRTs, not PBSA.
Common missteps
A few patterns we see every festival cycle:
- "I am only doing it for two weeks, so I don't need a licence." Wrong. The licensing requirement applies to any short-term let regardless of duration.
- "My HMO licence covers it." Wrong. HMO licensing is for ongoing residential use by multiple unrelated tenants. STL is a separate regime requiring a separate licence.
- "I already have planning permission for residential use." Residential use and short-term let use are different uses for planning purposes. Existing permission for one does not cover the other.
- "I have always done it; the Council knows about it." Tacit awareness is not a formal determination of lawfulness. If you have not held planning permission or a CLEUD throughout, you are exposed.
- "My letting agent says it is fine." Letting agents are not regulated for planning advice. The accountability for licence and planning compliance sits with the property owner.
What to do now if you want to let during the 2026 festival
The lead time matters. Standard Edinburgh STL licences can take several months to process; temporary licences are quicker but still require time. Planning applications, where needed, take longer again.
If festival 2026 is your target, the practical sequence is:
1. Identify which category applies (home letting, home sharing, secondary letting, temporary). Most operators benefit from a brief consultation before they commit. 2. Get your planning position confirmed. This is the harder of the two regimes and the one most operators underestimate. 3. Lodge the licence application well in advance. Festival-period applications submitted in late spring are routinely processed too late to be useful for August. 4. If your existing operating model has historic depth (pre-2022 STL use in a secondary letting context), consider a CLEUD application. This is the structural fix that converts a fragile position into a durable one.
How STL Solutions can help
We work with Edinburgh festival operators every year, across all four scenarios above. We can:
- Assess your scenario in a 15-minute free consultation
- Prepare and submit Home Letting, Home Sharing, Secondary Letting or Temporary STL Licence applications
- Lodge a Certificate of Lawfulness application where you have established pre-2022 use
- Advise on planning permission strategy for secondary letting in the STLCA
- Liaise with Edinburgh Council on your behalf
- Represent you at any licensing committee or planning appeal
The 2026 festival is approaching. If you are operating, or considering operating, get the regulatory position confirmed before the calendar gets away from you.
Book a free 15-minute consultation or start a Certificate of Lawfulness application.
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Ross Armstrong Head of Professional Services, STL Solutions
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