rules-and-licence

---
name: rules-and-licence
description: Produces one dated compliance file for a UK short let - which registration or licence applies where the property is, which certificates are due and when, what the lease and the insurer need to be told, and the numbered list of what is missing. Use before you list a property, when a council letter arrives, or when you genuinely do not know whether you are allowed to be letting it.
---

# What your council, your lease and your insurer need from you

You give this the property address, what you already hold (certificates, a licence, an insurance schedule, the lease or title), and how you let it. You get back one dated file: which nation's rules apply and what that nation currently requires, a certificate register with expiry dates and who to chase, the permission questions that belong to your council, your freeholder and your insurer with the wording to ask each, and a numbered list of what is missing ranked by what stops you letting tomorrow. It tells you what it could not verify rather than filling the gap.

## What it does

1. **Establish which nation the property is in before anything else, because the four answers are genuinely different.** Scotland has a mandatory licensing scheme run through local councils with conditions set in law. Wales has a registration duty on a published timetable run by the Welsh Revenue Authority. England has planning rules and a registration scheme the government has committed to, which is not the same thing as a licence. Northern Ireland has a separate certification regime administered by Tourism NI which this skill has not verified and which must be checked on Tourism NI's own website before the property is advertised. Write the nation at the top of the file. An owner reading Scottish licensing advice about a Cornish cottage will spend a fortnight on the wrong problem.

2. **For a Scottish property, work the mandatory conditions as a checklist, because they are in the statute.** Schedule 3 of the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022 sets them out. Where there is gas, the holder "must arrange for an annual gas safety inspection of all gas pipes, flues and appliances"; must "arrange for an electrical safety inspection to be carried out by a competent person at least every five years"; "must assess the risk from exposure to legionella within the premises"; must have "valid buildings insurance" and "valid public liability insurance for the duration of each short-term let agreement"; must ensure "the number of guests residing on the premises does not exceed the number specified in the licence"; and must ensure any listing or advert "includes...the licence number". mygov.scot adds the documentary detail: "a Gas Safety Certificate dated within the last 12 months", "an Electrical Installation Condition Report on any fixed installations", "a Portable Appliance Testing Report on moveable appliances that guests have access to", and, where an EPC is needed, you must "display the EPC rating in all adverts for the accommodation". Tick each against a document you can open.

3. **For a Welsh property, put the registration deadline in the diary with the penalty next to it.** GOV.WALES states: "From October 2026, if you take bookings for overnight stays in Wales, you must register", and registration must be completed "by 31 March 2027". It applies where you take bookings "of 31 nights or less" and you are responsible for the accommodation. "Registration is free." The consequence is stated plainly: "The first penalty is £100 per premises. If you still do not register after the WRA contacts you, penalties can increase to a total of £1,400 per premises." Record the date the owner registered and the registration number, because that number goes into the adverts.

4. **For an English property, separate the planning question from the registration question, because owners conflate them constantly.** GOV.UK's guidance on letting out a self-catering holiday home in England is deliberately unspecific on planning, and that is the point: "Your local planning authority will decide whether you need planning permission. This is based on how the property is used for short-term letting and its impact on neighbours and the local area." Registration is a separate track. The government's page on delivering a registration scheme records that "61% of those who responded supported this option" for a mandatory national scheme, against 28% for opt-in and 11% for opt-in with a review point, commits to an approach that is "light touch, low cost and simple", and sets out planning changes with flexibility to let a main or sole home for up to 90 nights a year. So the file records two open questions, each addressed to a different body, with the date the guidance was read, because this is live policy.

5. **Build the certificate register with expiry dates and a named person to chase, not a pile of PDFs.** One row per document: gas safety record, electrical installation condition report, portable appliance test, energy performance certificate, fire risk assessment, legionella risk assessment, buildings insurance, public liability insurance. Each row carries the issue date, the expiry date, the issuer's name and registration number, where the original is kept, and who chases it. HSE's guidance is specific about what a gas record must contain: "a description of and the location of each appliance or flue checked", "the name, registration number and signature of the individual carrying out the check", "the date on which the appliance or flue was checked", the property address, the landlord's name and address, and "any safety-related defect identified and any remedial action taken". On retention: "You have to keep records for at least two years." A certificate with no engineer registration number on it is not a record, and the register is where that gets noticed.

6. **Name the responsible person for fire in the file, in the legal sense.** Article 3 of the Regulatory Reform (Fire Safety) Order 2005 defines the responsible person as, for a workplace, the employer where the workplace is to any extent under his control, and for other premises, the person who has control of the premises in connection with carrying on a trade, business or undertaking, or the owner where that person does not have control through a trade or business. GOV.UK's guide for small paying guest accommodation puts it in the owner's language: this is "likely to be the owner, letting agents, or other persons who have control of the premises". Where a managing agent runs the property, the file says in one line who the parties agree it is, and whether that agreement exists in writing. An unnamed responsible person is the most common gap in a short-let compliance file and the most expensive.

7. **Do not assume the private rented sector electrical regulations apply, and do not assume they do not.** The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 attach to specified tenancies, and Schedule 1 lists excluded tenancies, including those "under the terms of which the occupier shares any accommodation with the landlord or a member of the landlord's family", long leases, student halls of residence, hostels and refuges, care homes, hospitals and hospices. Holiday lettings are not named there, and a holiday let is generally not a tenancy at all, which is a different point again. The correct output is a question to the owner's adviser with the regulation named and the schedule cited, not a conclusion. Separately, GOV.UK tells English holiday home owners they "must follow the: HSE guidance on electrical safety" and the "guidance on electrical safety standards in the private and social rented sectors", so the inspection goes in the register either way.

8. **Ask the lease, the mortgage and the insurer in writing, and quote the clause back to them.** A leasehold flat is where this goes wrong fastest. In Nemcova v Fairfield Rents Ltd [2016] UKUT 303 (LC), the Upper Tribunal held that short-term letting breached a covenant permitting use only as a private residence; the case comment records the reasoning that "Occupation as a home requires a degree of permanence. This...is not met in the type of short term letting entered into...where the occupants only stay for a few days or possibly weeks." So the file carries three written questions with the relevant clause pasted into each: to the freeholder or managing agent about the user covenant and any subletting clause, to the lender about consent to let on this basis, and to the insurer about cover for paying guests, public liability and unoccupied periods. Record the date each was sent and answered. An unanswered question stays on the list.

9. **Rank what is missing by what stops you letting tomorrow, and date the whole file.** Three groups, clearly headed: cannot let until this is in place; must be fixed within a stated number of days; and monitor with a date. Every item names the body or person it is addressed to, an owner and a date. Put the build date and the date each source was read in the footer, because the rules in three of the four nations are actively changing and an undated compliance file will be trusted six months too long.

## Then it checks

1. The file states the nation the property is in, and the requirements listed are the ones for that nation only, with no Scottish licence condition applied to an English property or the reverse.
2. Every certificate row carries an issue date, an expiry date, the issuer's name, where the original is held and who chases it, with no row reading "in hand", "renewed recently" or "with the agent".
3. Every permission question is addressed to a named body or person, with the wording to send and the date it was sent, and unanswered questions remain on the list rather than being treated as approvals.
4. The fire responsible person is named, with a line saying whether the agreement is in writing.
5. Nothing in the file states a legal conclusion about whether the property complies, whether planning permission is required, or whether a lease permits short letting.
6. Every requirement quoted names its source and the date that source was read, and anything that could not be verified, including the Northern Ireland position, is listed as unverified rather than described.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is.
- Never tell an owner they are compliant, that they do or do not need planning permission, or that their lease permits short letting. Those are conclusions for their solicitor and their council, and an owner told "you are fine" by a document stops asking the people who could actually tell them.
- Never carry a rule forward from an earlier file without re-reading the source. Short-let regulation changed in three of the four nations within two years, and a quote right in March can be wrong by September.
- Never treat silence as consent. A freeholder, lender or insurer who has not replied has not agreed, and the item stays on the missing list with the date it was sent.
- Never record a certificate as held unless you have opened it and read the dates. A renewal the owner is sure was done is not a renewal.
- This output is a working document prepared for the owner's solicitor, insurer, letting agent or local council to check before it is relied on. It gathers published requirements, lists what the owner holds and names the gaps. It is not legal advice, it is not a licensing decision and it does not certify compliance with anything.

## Built from
- The Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022, Schedule 3, https://www.legislation.gov.uk/ssi/2022/32/schedule/3/made, read 14 September 2026: the mandatory conditions checklist in step 2.
- mygov.scot, "Legal requirements for short-term let accommodation", https://www.mygov.scot/short-term-let-licences/legal-requirements, last updated 9 October 2025, read 14 September 2026: the twelve month gas certificate, the EICR, the PAT report and the EPC display rule in step 2.
- GOV.WALES, "Registering visitor accommodation: overview", https://www.gov.wales/registering-visitor-accommodation-overview, last updated 14 July 2026, read 14 September 2026: the dates, the 31 nights scope and the £100 to £1,400 penalties in step 3.
- GOV.UK, "Letting out a self-catering holiday home in England: rules and regulations", https://www.gov.uk/guidance/letting-out-a-self-catering-holiday-home-in-england-rules-and-regulations, published 25 March 2026, updated 15 May 2026, read 14 September 2026: the planning wording in step 4 and the electrical duty in step 7.
- GOV.UK, "Delivering a registration scheme for short-term lets", https://www.gov.uk/guidance/delivering-a-registration-scheme-for-short-term-lets, 19 February 2024, read 14 September 2026: the consultation figures and 90 nights point in step 4.
- Health and Safety Executive, "Gas safety check records and what to keep", https://www.hse.gov.uk/gas/landlords/gassaferecord.htm, no publication date shown on the page, read 14 September 2026: record contents and the two year retention rule in step 5.
- The Regulatory Reform (Fire Safety) Order 2005, SI 2005/1541, article 3, https://www.legislation.gov.uk/uksi/2005/1541/article/3/made, read 14 September 2026: the responsible person definition step 6 forces the file to name.
- The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, Schedule 1, https://www.legislation.gov.uk/uksi/2020/312/schedule/1/made, read 14 September 2026: the excluded tenancies list step 7 turns into a question.
- JB Leitch, "Nemcova v Fairfield Rents [2016]", https://www.jbleitch.co.uk/news-insights/case-law-comment/nemcova-v-fairfield-rents-2016/, 20 October 2016, read 14 September 2026: the degree of permanence reasoning behind step 8.

# rules-and-licence

## You are given

A folder for one UK short let containing: the property address with postcode, scans or photographs of whatever the owner holds (gas safety record, electrical installation condition report, portable appliance test report, energy performance certificate, fire risk assessment, legionella risk assessment, buildings insurance schedule, public liability insurance schedule, any licence or registration certificate), the lease or title where the property is leasehold, the mortgage terms, the managing agent agreement if there is one, a note of how the property is let and for how many nights a year, and saved captures of the source pages the owner or their adviser has read, each with the date it was read. Certificates are photographed at an angle, some have no engineer registration number on them, and several sources will be missing.

## Produce

Write these files into `./rules-and-licence-output/`:

1. `property.csv` - columns exactly: `field,value,source_file,confidence`. One row each for: address, postcode, nation, local authority, tenure, property type, freeholder or managing agent, lender, insurer, letting basis, nights let in the last twelve months, maximum guests advertised. `confidence` is `supplied`, `read_from_document` or `missing`.
2. `certificate-register.csv` - columns exactly: `certificate,held,document_file,issue_date,expiry_date,days_to_expiry,issuer_name,issuer_registration_number,property_address_on_document,defects_noted,original_kept_where,chased_by,record_complete,missing_fields`. One row each for: gas safety record, electrical installation condition report, portable appliance test report, energy performance certificate, fire risk assessment, legionella risk assessment, buildings insurance, public liability insurance.
3. `questions-to-ask.csv` - columns exactly: `question_id,addressed_to,recipient_name,subject,clause_or_regulation_quoted,source_file,wording_file,date_sent,date_answered,answer_summary,status`. `addressed_to` is `local_authority`, `freeholder_or_managing_agent`, `lender`, `insurer` or `owner_solicitor`. `status` is `UNSENT`, `SENT`, `ANSWERED` or `UNANSWERED`.
4. `letters-DRAFT/question-<question_id>-<recipient>.txt` - one drafted letter or email per question, each pasting in the clause or regulation it asks about, naming the property and the date, and signed with the owner's real name so it is clear whose name it is sent in.
5. `responsible-person.csv` - columns exactly: `role,name,organisation,basis,agreement_in_writing,document_file,source_file`. One row for the fire responsible person and one per other party with control of the premises.
6. `sources-read.csv` - columns exactly: `requirement_quoted,source_title,source_url,source_publication_date,date_read,applies_to_nation,capture_file,verified`. `verified` is `VERIFIED` only where a saved capture of that source exists in the inputs, otherwise `UNVERIFIED`.
7. `missing-ranked.csv` - columns exactly: `rank,group,item,addressed_to,owner,due_date,source_file`. `group` is `CANNOT LET UNTIL IN PLACE`, `FIX WITHIN STATED DAYS` or `MONITOR`.
8. `compliance-file.md` - the assembled working document. First line: the nation, the local authority and the build date. Then the property table, the certificate register, the responsible person, the open questions and the ranked missing list. Footer: the build date and the date each source was read, as DD Month YYYY.
9. `exceptions.csv` - columns exactly: `field_or_certificate,problem,what_it_blocks,source_file`.

## Rules

- Write files only. Never register, apply, submit, upload or pay anything, never open a council, platform or registry portal, and never send any letter in `letters-DRAFT/`. The owner sends them.
- Never state what licence, registration, permission or certificate this property needs. Licensing and registration differ by nation and by local authority, and the answer belongs to the owner's own council. Every such point becomes a row in `questions-to-ask.csv` addressed to the named body, with the wording drafted and `status` set to `UNSENT`.
- Never state whether planning permission is required, whether the property is compliant, whether it is in breach, or whether the lease permits short letting. Those are conclusions for the owner's council and solicitor. Assemble the clause, the question and the recipient instead.
- Never write a requirement into the file without a saved, dated source capture in the inputs. A requirement with no capture is written `UNVERIFIED` in `sources-read.csv`, kept out of `certificate-register.csv` and `missing-ranked.csv`, and named in `exceptions.csv`. Never carry a requirement forward from another file or from memory.
- Never record a certificate as held unless the document file exists and the dates were read off it. An issue date, expiry date, issuer name or registration number that cannot be read is left empty, listed in `missing_fields`, and `record_complete` is set to `no`. Never estimate an expiry from an issue date the document does not show.
- `days_to_expiry` is computed from the build date. An expired or unreadable certificate goes in `missing-ranked.csv` under `CANNOT LET UNTIL IN PLACE` or `FIX WITHIN STATED DAYS`, never under `MONITOR`.
- Silence is not consent. A question with no reply keeps `status` set to `SENT` or `UNANSWERED` and stays in `missing-ranked.csv`. Never convert an unanswered question into an approval, and never leave `answer_summary` populated from an assumption.
- The fire responsible person must be named with a real person and organisation, and `agreement_in_writing` set from a document in the inputs. If nobody is named, write it as the first row of `CANNOT LET UNTIL IN PLACE`.
- Never put a guest name, booking reference, contact detail or any occupancy record into any file. This is a property compliance file, not a booking file.
- Every item in `missing-ranked.csv` names the body or person it is addressed to, an owner and a due date. No row may read in hand, renewed recently, with the agent, approximately, circa or tbc.
- British English. £ for money. Dates DD Month YYYY. No em dash characters. No emoji. CSVs UTF-8, header row, comma separated, fields containing commas quoted.

## Return

The file paths written, the nation and local authority recorded, the certificate count by `held` and by `record_complete`, every certificate expired or expiring within 90 days, the count of questions by `status` and the bodies they are addressed to, the fire responsible person or the fact that none is named, the item count in each of the three groups in `missing-ranked.csv`, and every row in `sources-read.csv` marked `UNVERIFIED`. State that no letter has been sent and nothing has been registered or applied for, that the file states no conclusion about what licence applies, whether planning permission is needed or whether the property complies, and that it is a working document for the owner's solicitor, insurer, letting agent and local council to answer before it is relied on.