On Friday evening, 28 August at 17:39, the City of Cape Town emailed its ratepayer base directly about the draft Short-Term Letting By-law. Subject line: Comment on draft Short-Term Letting By-law. Salutation: Dear Cape Town Metro Property Owners. If you receive your rates bill by email, this notice is sitting in your inbox now. That single fact changes the temperature of this process, and the wording of the email deserves a closer read than most owners will give it. Both are worth your five minutes.
What the City's email says
The email is a plain-language summary of what we have covered in detail before: the by-law exists to work out which short-stay properties should pay commercial rates under the City's Rates Policy. It lists the draft's four proposals: registration with the City for every property advertised on a booking platform, a unique City-issued registration number displayed on every listing, data sharing by platforms, owners and operators, and compliance and enforcement mechanisms.
It also leads with reassurance, and the reassurance is specific. Commercial rates do not apply to properties with less than 50 percent of room-night availability for short-term letting, the email notes, naming people who supplement their income by letting part of their primary home some of the time. Long-term rentals that are the tenant's primary residence are also out of scope. The email then offers a rule of thumb: a property is likely commercial if you are "using most of your property most of the time" for short-term letting, and likely residential if you let a portion of it for parts of the year.
On process, two details matter. The comment window ran to 5 October 2026 (it has now closed), following what the City describes as a year of stakeholder engagement. And after public input the draft may be revised before going to Council, with a grace period for owners, operators and platforms, and implementation foreseen from July 2027 onwards.
Read the rule of thumb next to the actual test
Here is the closer read. The email's own definition section, two paragraphs below the reassurance, states the binding test: a primary residence becomes commercial accommodation when it is used or available for short-term letting for more than 50 percent of its total annual room-night capacity. The rule of thumb says using. The test says available. Those are different measurements, and the difference is the whole game.
A whole-home listing that stands open all year is 100 percent available even if it sells 70 nights. By the rule of thumb as plainly worded, that owner is not using most of the property most of the time, and should relax. By the availability test, that owner sails past the threshold into commercial rates. We walked the arithmetic in our position piece: the City's plain-language reassurance describes an occupancy world, while the policy underneath measures the calendar. When the City's own summary to ratepayers reads like an occupancy test, that is not a gotcha. It is evidence that occupancy is the intuitive, defensible measure, and it is precisely the amendment we asked for while the window was open: make the test say what the reassurance says.
The inbox move matters on its own
Consultations are usually easy to miss. This one is now distributed to every e-Billing subscriber in the metro, which tells you three things. The process is serious and resourced. The City is comfortable using its billing data pipes for short-stay policy, which is worth remembering when the by-law's own data-sharing clauses come into force: the machinery to know who you are and what you owe already exists. And nobody will be able to argue, at promulgation, that owners were not told. The quiet era of this policy is over.
The softer signals in the email are real too. A draft that may be revised before Council, an explicit grace period, and a from-July-2027 start all say the same thing: nothing is final. Public comment closed on 5 October 2026, and the next step is a revised draft before Council. The legal briefing we summarised reaches the same conclusion from the statute side.
Where things stand: the short list
- Read the source documents, not just the email: the draft by-law, the executive summary and the FAQ with its worked calculation.
- Comments closed on Monday 5 October 2026. Submissions went in via the public participation page (archived copy) or STL@capetown.gov.za. The point to watch for in the revised draft: does the test now match the rule of thumb, measuring nights sold, not nights available?
- Do not decide anything about your calendar yet. Whether to stay under the line or trade above it depends on what your own nights earn, and the 182-night calendar explains why that is a projection, not a guess.
Let us run your numbers
The email makes one thing plain: the City intends to see your availability and occupancy, and the gap between "using" and "available" will be settled with numbers. Yours should exist before theirs do. That means a running record of nights offered, nights sold and guests a stay for each property, kept every month, and a price on every open night that reflects what your suburb, the season and the events calendar will actually bear. Done by hand, that is a spreadsheet nobody keeps up and a rate card that goes stale by February.
RateVeld does both for members: it keeps the availability, occupancy and rate history per property, and it prices every night from local comps, hotel rates and a curated events calendar, never under your floor. See the plans and we will show you your own calendar the way the City will see it. We will keep summarising each development as it lands.