Renting guest rooms/guest apartments is a tourist activity within the meaning of the Tourism Act. The general rules for the hotel business as a tourist activity apply in this case as well.
According to Art. 113, para. 3 of the Tourism Act, "online, including through an electronic platform that connects users of tourist services and the persons providing them, tourist services may be offered only for categorized or registered sites for accommodation." In this relation, if you are doing or willing to do business in the field of renting guest rooms and apartments, then you have probably recently faced the policies and requirements of a number of online platforms for ads of such sites (guest rooms and apartments) that follow closely the provisions of the Ordinance, especially on advertising.
More and more platforms such as Booking.com require proof that your activity is lawful and that the site you are renting is registered in accordance with the respective procedure.
In 2020 the Ordinance on the requirements for categorized places for accommodation and restaurants and places for entertainment on the procedure for determining the category, as well as on the rules and the procedure for registration of guest rooms and guest apartments (Ordinance) was adopted and envisaged new rules for registration.
The Ordinance aims to introduce new rules and procedures for registration of guest rooms and guest apartments and categorizes them as a type of accommodation - class "В". The registration procedure includes several steps among which is the submission of an application-declaration by sample (with information about the capacity of the site, an identifier of the real estate, identifying information about the person who will perform the hotel business) and a document either certifying that you hold the right to ownership of the respective site or that you hold the right to carry out activity in the site, for example, a letter of permission from the landlord. The required documents are submitted to the mayor of the municipality at the location of the site. Within 7 days from the submission of the application-declaration, the mayor of the municipality or an official authorized by him will issue an order for registration and a certificate to the person, who has applied for rental management in a guest room/guest apartment. You can read more about the registration requirements in our material here.
Therefore, if you are willing to take advantage of the online advertising of your site/s by using the services of a platform such as Booking and to avoid a possible rejection on their part, which could slow down the process in the peak of the season, you should first follow the registration procedure according to the Ordinance. Otherwise, the platform puts a ban on advertising uncategorized and unregistered guest rooms and apartments.
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Pavla Tsvetkova
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