A self-service unit cannot be let unless it is on the Register, the registration number appears in every advertisement, and the licence is renewed every three years.
Letting a flat or a villa to holidaymakers in Cyprus stopped being a private arrangement between an owner and a platform some years ago. Part IIIA of the Regulation of the Establishment and Operation of Hotels and Tourist Accommodation Law of 2019, Law 34(I)/2019, makes registration a condition of letting at all, and the obligations now reach the platform as well as the owner.
The whole regime turns on one number.
The prohibition is on letting, not on advertising
Section 16A(1) provides that, irrespective of any other provision of the Law or of any other law, a self-service unit may not be let or rented unless three conditions are met together:
- it bears the characteristics and specifications of a detached dwelling, a tourist furnished villa or an individual apartment, as those are defined in the Fifth Schedule;
- it is entered on the Register of Self-Service Accommodation, kept by the Deputy Ministry of Tourism under the Fifth Schedule; and
- it keeps in force, and has renewed, its registration licence as the Fifth Schedule provides.
That is a prohibition on the letting itself. An unregistered unit is not simply an unadvertised one.
The number goes in the advertisement, and in the transaction
Section 16A(2) allows the owner, the beneficial user, the businessman acting with the owner's approval or authorisation, or the proprietor of the unit, to advertise, let or rent it, provided that it is on the Register and has obtained a registry number, and that number is stated in the advertisement, in the promotion of the unit, and in all related transactions.
Two provisos follow. A unit already operating before the 2020 amending Law had three years to come into compliance. And after the transitional period for registration, the owner and the provider of an electronic advertising platform are prohibited from advertising or posting units that have not obtained a registry number.
The second of those is the reason the number matters commercially rather than merely legally: the listing itself is exposed, not just the letting.
What the application actually requires
Paragraph 1(b) of the Fifth Schedule puts the application in the hands of the owner, the beneficial user, the businessman with the owner's approval or authorisation, or the proprietor of the unit as the Immovable Property Law defines that term. It requires the prescribed form for the type of unit, the prescribed registration fee for its category, and a Responsible Declaration certifying:
- registration with the Tax Department, meaning the tax identification number of the owner or the manager, and VAT registration where the relevant legislation requires it;
- the details of the unit and the minimum technical and functional specifications for it; and
- all-risks insurance for the unit, covering fire and civil liability.
Paragraph 1(c) gives the Deputy Ministry two months from the filing of the Responsible Declaration to examine the application and inform the applicant of approval or rejection, with reasons where it is rejected. A reasoned rejection is a decision, which is what makes it capable of challenge.
Paragraph 1(d) provides that on registration the Deputy Ministry issues a special sign and a registration number, which is displayed and declared in all transactions, and issues the first registration licence, valid for three years from the date of issue. Paragraph 1(e) renews it every three years on an application made within the three months before the existing licence expires, with the renewal fee.
The renewal window is the deadline most owners miss, because it opens and closes before the licence itself runs out.
When registration is taken away
Section 16A(3) lets the Deputy Ministry revoke the registration licence and strike the unit off the Register at the same time, where:
- the licence was granted on false or misleading information submitted by the businessman;
- the business has permanently ceased trading;
- an inspection by an officer of the Deputy Ministry finds that any of the certificates and documents required for the licence have not been renewed;
- the businessman has been convicted of serious offences under the Safety and Health at Work Law and its Regulations, after consultation with the Director of the Department of Labour Inspection, or of offences concerning health matters under the legislation the Ministry of Health administers;
- the businessman has died, a bankruptcy order has been made against a natural person, or a liquidator has been appointed for a legal person;
- an interim order for the cessation of the unit's operations has been issued or made final; or
- there have been repeated contraventions of the Law or the Regulations.
The penalties, and the platform
Section 22(1) makes it an offence to keep or operate a self-service unit without a registration licence, or after the licence has been revoked, and to use the term self-service accommodation, or any other term suggesting a hotel or tourist accommodation, for a unit with no licence under sections 6, 13 or 16A. The penalty on conviction is imprisonment of up to one year, or a fine of up to 5,000 euro, or both, and where the contravention continues after conviction there is a further offence with a further fine of up to 200 euro for each day it continues. Section 22(2) allows the Court, on conviction, to order the operation of the unit to stop.
Section 23(1) gives the Deputy Ministry an administrative route as well: a fine of 2,000 euro for a contravention of the Law or its Regulations, rising to a fine not exceeding 4,000 euro where the contravention is repeated or continues.
Part IIIB then reaches the platforms. Section 16B(1) requires both the person managing a unit offered for short term rental services and published on a short term rental online platform, irrespective of where that platform is established, and the provider of the platform itself, to comply with Regulation (EU) 2024/1028. Section 16B(2) makes the Deputy Ministry of Tourism the competent authority for Article 12 of that Regulation, and section 16B(3) requires it to publish, at the single digital entry point, a list of the areas where the registration procedure applies and a list of the areas for which data has been requested from platform providers, updated regularly.
Section 22A attaches the penalty. A short term rental online platform provider that fails to comply with Article 6(11), Article 7(2) or (3), or Article 9 of the Regulation is guilty of an offence and liable on conviction to imprisonment of up to two years or a fine of up to 20,000 euro or both, and on repetition to a fine of up to 1,000 euro for each day the contravention continues.
What this means in practice
Register before you list, not after. Section 16A(1) prohibits the letting, and section 22(1) makes operating without the licence an offence in its own right. The listing is the evidence, not the wrong.
Put the number where it has to be. The advertisement, the promotion and every related transaction, which in practice means the platform listing, the booking confirmation and the invoice.
Diarise the renewal three months early. The application under paragraph 1(e) is made within the three months before expiry. A licence allowed to lapse takes the letting with it.
Check what the Responsible Declaration commits you to. It is a declaration that the tax registration, the technical specifications and the all-risks insurance covering fire and civil liability are all in place. A licence obtained on a declaration that was not accurate is revocable under section 16A(3)(a), and the insurance limb is the one owners most often assume rather than check.
Questions we are asked
Do I have to register a holiday apartment I let out?
If it is a self-service unit, yes, and the prohibition is on letting rather than on advertising. Section 16A(1) of Law 34(I)/2019 provides that a self-service unit may not be let or rented unless three conditions are all met: it has the characteristics and specifications of a detached dwelling, a tourist furnished villa or an individual apartment as the Fifth Schedule defines them; it is entered on the Register of Self-Service Accommodation kept by the Deputy Ministry of Tourism; and it keeps its registration licence in force and renewed.
Where does the registration number have to appear?
Everywhere the unit is offered. Section 16A(2) permits the owner, the beneficial user, the businessman with the owner's authorisation, or the unit proprietor to advertise, let or rent the unit provided it is on the Register and has obtained a registry number, and that number is stated in the advertisement, in the promotion of the unit, and in all related transactions. Paragraph 1(d) of the Fifth Schedule adds that on registration the Deputy Ministry issues a special sign and a registration number which is displayed and declared in all transactions.
How long does registration take, and how long does it last?
Under paragraph 1(c) of the Fifth Schedule the Deputy Ministry examines the application within two months of the Responsible Declaration being filed and informs the applicant whether it is approved or rejected, with reasons if it is rejected. Under paragraph 1(d) the first registration licence is valid for three years from issue, and under paragraph 1(e) it is renewed every three years on an application submitted within the three months before the current licence expires, with the renewal fee.
What has to be true before I can file the declaration?
Paragraph 1(b) of the Fifth Schedule requires an application on the prescribed form for the type of unit, the prescribed registration fee for its category, and a Responsible Declaration certifying three things: registration with the Tax Department, meaning the tax identification number of the owner or manager and VAT registration where the legislation requires it; the details of the unit together with the minimum technical and functional specifications; and all-risks insurance for the unit covering fire and civil liability.
What is the penalty for letting without registration?
Section 22(1) makes it an offence to keep or operate a self-service unit without a registration licence, or after the licence has been revoked, and to use the term self-service accommodation for a unit that has no licence. On conviction the penalty is imprisonment of up to one year or a fine of up to 5,000 euro or both, and where the contravention continues after conviction there is a further offence carrying a further fine of up to 200 euro for each day it continues. Section 22(2) lets the Court order the operation to stop, and section 23(1) allows the Deputy Ministry to impose an administrative fine of 2,000 euro, rising to 4,000 euro on repetition or continuation.
Sources
This article is provided for general information purposes only and does not constitute legal advice.
Klitos Platis
Advocate, Partner
Kleanthous & Platis LLC, Nicosia · Published 23 August 2026
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