Every whole-property short let in Greater London is running against a clock.
Under the Deregulation Act 2015, which amended the Greater London Council (General Powers) Act 1973, a residential property in the 32 boroughs and the City of London can be let as temporary sleeping accommodation for a maximum of 90 nights in a calendar year without planning permission for change of use. The counter resets on 1 January. It applies per property, not per platform, and Airbnb blocks listings automatically once the ceiling is reached.
Going past it means applying to your borough for change of use, and in central London the approval rates for those applications are poor. Westminster, Camden, and Kensington and Chelsea refuse the large majority. Councils are considerably more likely to issue an enforcement notice than to grant retrospective consent, and planning fines can reach £20,000 per offence.
So the practical reality for most London operators is not a compliance question. It's a calendar. You run one business for part of the year and a different one for the rest, in the same flat, with the same keys.
That switch is where London property management actually gets expensive.
Two businesses, one property
The 90-night cap only bites on whole-property lets under 90 consecutive nights. Two routes around it stay open, and both are widely used.
Hosted stays. If you're living in the property while a guest rents a room, the cap doesn't apply. That's a genuinely different operation with continuous shared occupancy.
Longer lets. A single let of 90 or more consecutive nights to the same occupier falls outside the definition of short-term letting altogether. This is the route most professional operators take, and it produces the hybrid year: short lets through the peak season until the counter runs low, then a switch into mid-term or a longer tenancy for the remainder.
The two halves of that year have almost nothing in common operationally.
In short-let mode you're handling frequent arrivals, high key circulation, changeover cleans between every stay, guests who need instructions in several languages, and arrivals landing at Heathrow and Gatwick at hours no member of staff wants to cover.
In longer-let mode you have one occupier for months, but you gain scheduled maintenance, periodic inspections, gas safety and electrical checks, letting agents conducting viewings ahead of the next tenancy, and in leasehold blocks, managing agents and their contractors coming and going.
Most operators handle this by bolting together two different arrangements: a lockbox and a WhatsApp group for the short-let months, a set of physical keys handed to an agent for the rest. Twice a year, keys change hands, codes get reset, and something gets lost.
The system doesn't need to change when the model does
Keycafe assigns access by person and by time window rather than by booking, which is exactly the shape a hybrid year needs.
A guest on a four-night stay in July holds access for four nights. A tenant on a five-month let from October holds access for five months. The changeover cleaner holds a recurring Saturday morning slot through the summer and then stops. The gas safety engineer gets a two-hour window in November. The letting agent gets Thursday afternoons in February while they're conducting viewings.
None of those require a different system, a different box, or a different set of keys. When the property flips models on 1 October, you change who holds permissions. The infrastructure doesn't move.
That matters more in London than the description suggests, because the switch is not annual and tidy across a portfolio. If you manage 30 flats, they hit their 90 nights at different points in the year depending on demand, pricing, and how aggressively each one was booked. At any given moment you're running some units short and some long, and the mixed state is permanent.
Borough by borough, and the leasehold layer
London's other structural feature is that it isn't one jurisdiction. It's 33 planning authorities with meaningfully different appetites for enforcement.
Westminster, Camden, and Tower Hamlets actively monitor listings on the major platforms using third-party data services. Some boroughs have pursued Article 4 directions to remove permitted development rights in specific areas. Outer boroughs are generally more pragmatic on change of use applications, though allowing eight to thirteen weeks for a decision is realistic anywhere.
Alongside planning sits a second layer that catches people who assumed planning was the only issue. Most London flats are leasehold, and a large proportion of long leases prohibit short-term letting outright. That restriction operates independently of planning law and independently of any registration. So does the typical residential mortgage condition. An operator can be entirely correct on the 90 nights and still be in breach of their lease.
For key management this has a practical consequence: anything you install in a common part of a leasehold block requires the freeholder's or managing agent's consent. That's a separate conversation from the borough, and it's the one that determines where the hardware can physically go.
The national picture is also shifting. Powers under the Levelling Up and Regeneration Act 2023 provide for a mandatory registration scheme for short-term lets in England, with a proposed C5 planning use class for dedicated short-term lets alongside it. Implementation has been staged and the detail has moved more than once, so treat GOV.UK and your borough as the authority rather than any summary, including this one.
Where the hardware goes in a London portfolio
London is dense and walkable, and the transport network is genuinely good, which changes the deployment maths compared to spread-out cities. You don't need a key point at every door. You need one within a sensible walk or a couple of Tube stops.
In-building, for blocks. If you manage several units in the same building, or you're a managing agent responsible for the block, an installation in the lobby, post room, or a ground-floor service area covers everything in one place. This is the cleanest arrangement and the one that requires freeholder consent.
Cluster point, for scattered flats. Operators with flats spread across a borough often install at their own office or a small leased space and have guests, cleaners, and contractors collect from there. In zones 1 and 2 a ten-minute walk covers a lot of ground.
Per-property, for houses and larger single lets. A unit mounted in a porch, side return, or utility area handles a single high-value property directly.
The unit itself is roughly the footprint of a picture frame at 11.4 inches wide and 4 inches deep, mounts on any wall type, and carries an IP52 weather resistance rating, which suits sheltered outdoor positions. Given London's weather, sheltered is the operative word. WiFi, Ethernet, and optional cellular connectivity cover the connection, which is worth planning for in basements and thick-walled Victorian conversions.
Capacity starts at 9 key bins on a base unit and grows through daisy-chained expansion modules, so a cluster point that opens with a handful of flats can scale into the hundreds of keys without a second installation.
The record and what it's for
Access logs don't demonstrate that you stayed within 90 nights. Night-counting is a booking-records exercise, and you should keep those properly regardless of what any access system tells you.
What a log does provide is evidence of physical access, and in London that gets used constantly. Deposit disputes under a tenancy deposit scheme. Insurance claims. Managing agent queries about who was in the building. Contractor damage attribution. Complaints from other leaseholders about unfamiliar people in the block, which in central London blocks is a common precursor to a freeholder taking an interest in what you're doing with the flat.
Being able to produce a named, timestamped, exportable record turns most of those into short conversations.
Running the calendar instead of reacting to it
The 90-night cap isn't going away, and the boroughs are getting better at spotting breaches rather than worse. The operators who handle London well aren't the ones who found a clever way around the rule. They're the ones who built an operation that switches modes cleanly, twice a year, thirty times over, without anybody driving across town to hand over a set of keys.
Access is the part of that switch you can make invisible.
Configure a SmartBox deployment or speak with our team about a London installation.
Regulatory details in this article reflect publicly available information at the time of writing and are provided for general guidance only. Planning rules, borough enforcement practice, and the national registration scheme for short-term lets in England are actively changing. Confirm current requirements with GOV.UK, your borough council, your freeholder, and qualified professional advisers before making operational decisions.
