On the 19th of May 2025, the City of Edinburgh Council’s Regulatory Committee resolved to extend the length of time for which a Secondary Let STL Licence can be renewed from 1 year to 3 years.

This decision represented a distinct change in policy, with members diverging from their earlier decision to resist the calls (both from STL operators and stakeholders, and the city’s own regulatory officers) for such a measure.

The decision, which may recognise the administrative pressures that the STL Licensing Scheme has placed on Edinburgh’s licensing infrastructure, brings the period for which a Secondary Let licence can be renewed in line with the 3-year licensed period currently associated with the Home-Letting and Home-Sharing licence types. 

Members’ thinking may also be partly underpinned by the city’s recent admissions regarding the “relatively low number of complaints received in respect of secondary lets.” (Report, City of Edinburgh Council Regulatory Committee, 10.00 am Friday, 31st January 2025, @ 4.10.)

This development will be a welcome one for secondary let operators, helping remove that sense that the secondary let licence application process was akin to the painting of the Forth Rail Bridge (no sooner has the exercise been completed than it must be renewed).  As alluded to above, that may also have been the feeling amongst the city’s licensing and regulatory officers, as well.

However, the decision only being taken on 19.05.25 did pose some uncomfortable questions for the Authority; namely, what of those licensees who had already applied to renew their licences prior to that date? 

The initial sense (and advice) was that only those applying for a renewal on or after 20.05.25 would be eligible to pay against an updated fee scale and avail themselves of the 3-year renewal period.  This position appeared arbitrary, not to mention punitive towards those who (being amongst the earliest to require renewal of their licences) were presumably the most proactive operators to engage with the licensing scheme.

This situation appeared ever more insupportable given that the Authority had the option to adopt these measures long before May 2025 (for example, at a time when current licensees had not yet been required to make renewals) thus ensuring greater uniformity in the treatment of all those engaging with the licensing system.

STL Solutions has therefore been advocating on behalf of our current licensing clients (and the wider community), for a position where ALL those whose licensing renewal applications have not yet been determined will be afforded a potential 3-year renewal period (assuming all else is equal in terms of other concerns the Authority might have).

We are pleased to share that, following these representations, the Council appears to be now indicating a flexible approach for applicants who submitted renewal applications prior to the policy change.

One of our clients, who submitted a renewal in April 2025, has today been contacted directly by the licensing team and offered the opportunity to “upgrade” their renewal application to reflect the potential of a 3-year licence by paying an additional fee (£400 in this case).

This suggests the Council is open to allowing applicants in similar circumstances to benefit from the new 3-year term, rather than being locked into a shorter one-year renewal.  This is a welcome and pragmatic step, which should offer no legal difficulties for the Authority.

Our advice is therefore as follows:

• If you have already submitted a renewal application for a 1-year secondary let licence and would prefer a 3-year licence instead, we recommend contacting CEC licensing directly, or if an STL Solutions licensing client, contacting our licensing team to request this option.
• If invited to upgrade, you will be asked to pay the outstanding fee difference and quote your licence reference when doing so. Be prepared to do this, therefore. The “additional” or “top-up” fee is £400 (seemingly for both a 1-to-3-person licence and for a 4-to-5-person licence).
• As this process is not yet formally published on the Council’s website, we advise proceeding cautiously and keeping a record of any communication or payments made.

NB. This option is only available to existing licensees seeking secondary letting renewals. Home let and home share licences are already subject to 3-year terms as a matter of course, and “new” secondary let applications will remain restricted to 1-year initial terms (capable of being then renewed, before expiry, for 3 years).

We consider this position (in respect of initial 1-year secondary letting licence periods) to be arbitrary (particularly given the admission by the city in its report of 31^st January regarding the low number of complaints that secondary let STLs engender, and given that secondary and home letting often involve identical management practices).

However, the power to restrict licence terms to “such shorter period as the licensing authority may decide at the time when they grant or renew the licence” is afforded by Schedule 1, Para 8 (2) (b) of the 1982 Act.

It is also expected that a renewal period may be restricted if concerns or objections are received during the application process.  Operators will therefore continue to be well-served by responding to licence objections in the strongest possible terms, not only to ensure that renewal is possible, but also to ensure that the longest possible period of renewal is achieved.

We continue to engage with the Council for formal confirmation of this approach and will issue further updates as soon as this is confirmed in writing.

Ross Armstrong.  

If you have any questions or would like assistance in renewing your licence, requesting an upgrade to a 3-year licence, or responding to a licensing objection, please don’t hesitate to contact our team.

STL Solutions further offers a range of planning services aimed at ensuring that any 3-year licence obtained remains useful throughout the entire term.  If the planning status of a given property cannot be addressed, then any property (irrespective of the length of its licensed period) could be vulnerable to planning enforcement.  Furthermore, mandatory condition 13 of any licence issued may mandate that an operator have careful regard to the planning status of their property. 

The timing of mutually supportive planning and licensing renewal applications can be an important strategic element in extending trade. A consultation with a planning and licensing expert remains strongly recommended, therefore.