The users of this service
How did we identify possible users of the service?
As part of this delivery, we have been able to identify the different user groups of a short-term lets registration service with more certainty. The team completed a number of different activities to do this which are outlined below.
Review of pre-discovery report and research
We used the pre-discovery report as a starting point for understanding more about the different users of the service, and which of those might be the ‘primary’ users. We also learnt more about the amount of research that had already taken place with each of these groups.

The pre-discovery report also included some first versions of personas for some of these user groups (see below). These helped us build up a high level understanding of these user groups, and formed a basis from which we could produce iterated personas.

Review of consultations and call for evidence
We were able to use the Government’s call for evidence and consultation on developing a registration scheme for short-term lets as sources to understand more about the users of the service.
This included reviewing the ‘Developing a tourist accommodation registration scheme in England: analysis of the call for evidence’ document which was produced from the call for evidence, and also the statement setting out the next steps on delivering a registration scheme for short-term lets which came as a result of the consultation. We also had a draft of the ‘Consultation analysis report’ which we were also able to use to uncover information about users. Additionally, in some instances we looked at individual responses to the consultation, this allowed us to dive deeper into the particular user groups who might have more niche needs. As an example we read some individual responses from Local Authorities or booking platforms to help create our initial assumptions, and later on to draft our discussion guides.
Desk research on similar schemes
There are similar schemes both in the United Kingdom and internationally which we reviewed to try and understand more about the different user groups. Within the UK, we focussed on:
- Short-term let licences in Scotland
- Registration and licensing scheme for all visitor accommodation in Wales
- Certification of all tourism/visitor accommodation in Northern Ireland
Outside of the UK, the team conducted desk research on schemes in Amsterdam, Barcelona, Berlin, Brussels, Paris and Milan.
Stakeholder mapping and user identification sessions
During our inception week, the team conducted a number of different activities during a face-to-face workshop. These activities were run with the aim of uncovering as much detail as possible about the user and stakeholder landscape.
We ran a post-up activity where we tried to think of any potential users and stakeholders that might fall into different categories. Those categories and some examples of the users and stakeholders identified are shown below:
Primary users
- Operators (year-round/ sporadic)
- Bookers (more/less experienced) i.e. travellers (domestic/international)
- Intermediary Bookers (booking on behalf of non-digital friends/family)
- Property management companies - national
- Property management companies - regional
- Booking platforms that offer a property managing capacity
Secondary users
- Booking platforms
- Social media or advertising platform sites where short-term lets are listed
- Property owners that delegate management
- Local Authorities (popular tourist hotspots)
- Local Government Association
- Arms Length Bodies
- British Tourism Association
- Trade and membership associations, bodies or groups
Tertiary users
- Fire Brigades in LAs
- Police
- The Health and Safety Executive (HSE)
- Other government departments
- Academics
- Advertising Agencies
- Banks + insurers
- Lenders
- Devolved Govts/Administrations
- Civilian interest groups
- No 10
- Neighbours who live in tourist hot spots
- People who run local communities
- DCMS core teams
An example of the output for one of these groups is shown in the photo below:

Once we felt our session represented the whole landscape of users and stakeholders we did a stakeholder mapping activity with all of the post-its that remained. These were moved into one of four quadrants.
- Keep satisfied
- Actively engaged
- Monitor
- Keep informed
Completing this exercise helped us in a number of ways. It allowed us to link user groups with whom we would want to test and research, as well as those that we would want to collaborate with, and also those that we wanted to show our work to at showcases and through wider engagement.
Deepened our understanding through interviews and testing sessions
Our stakeholder mapping, alongside defining our assumptions for alpha, resulted in us identifying 4 user groups with whom we believed we needed to engage with to test the riskiest parts of the service. These groups were:
- Short-term Let Operators and Management Companies
- Local Authorities
- Booking platforms
- Possible service owners
The format of our engagement with these groups varied, and is detailed in our research and testing methodology page. Through testing with all of these groups we were able to confirm who the key user groups were for this service, and deepen our understanding of them by learning more about their needs, emotions, feelings and behaviours.
What are the key user groups for this service?
Through conducting the activities listed above, we have been able to identify and group with more certainty who we believe to be the different user groups of a short-term lets registration service. Our users fall into one of 4 different groups:
- Primary users. Those who need to use the service to register a short-term let.
- Impacted / Involved users. Those who are impacted by or involved in the scheme.
- Data users. Those who directly benefit from the data.
- Other users. Those who might have an interest in the registration scheme but will not have to use, or benefit from the data it collects.
Who are our ‘Primary users’?
Our primary users are people who need to interact with the service directly in order to register a short-term let. We have identified two types of primary users:
- Operators and owners of short-term lets
- Management Companies
Operators and owners of short-term lets
The Consultation on a registration scheme for short-term lets in England defines operators and owners as:
“Operator: Any person who is the owner or tenant of a dwelling unit, or portion thereof, who offers or provides that dwelling unit, or portion thereof, for hosted short-term rental use.”
“Owner: The person or persons or legal entity or entities holding interests of record to a property or any portion of the property.”
These definitions have helped us frame our thinking during Alpha, especially when planning and conducting user research with this group. More detail about how we engaged with this group can be found in our research and testing methodology page. After conducting user research and testing sessions, we identified 5 different personas that make up the operator and owner user category. Whilst these personas share many needs, motivations, challenges, worries and opportunities we identified, we currently believe that each of these 5 personas are distinct enough in their own right to separate out in this way:
The Experienced Operator
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Sarah (57) & Victor (61) Property Owner / Experienced Short-term Lets operator |
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We have been operating as hosts of a short-term let property in a popular English town for over 5 years. We’re both self-employed and we do this in order to generate income to make additional contributions to our pension pot.
We take pride in operating a successful short-term let business and we want our guests to enjoy their stay, so that they return and tell others about us.
Needs and motivations
I need to be able to advertise my property in different ways - repeat business, their own website and socials, and different booking platforms - both national and niche
I care about our reputation, and the reputation of the short-term let(s). I also care about the reputation of the sector, and dislike people who give it a bad name.
I am happy to comply with regulations and see it as a positive step to rooting out bad apples. I need to show I am one of the good hosts.
I am proud to be responsible hosts and like to think we have a good knowledge of the different health and safety elements of running and operating a STL.
I’m a diligent record keeper and I feel confident we would have anything required to comply with a registration scheme. However, we might need the time to bring all those records together to submit into any sort of application.
I have an awareness of different organisations within the sector, and trade bodies etc. I’m more likely to be a member of such bodies and associations. I’d likely respond better to something that is affiliated with a trade body.
Challenges and worries
We have some nagging doubts about the true intention of such a scheme. Is it actually for monitoring or maybe for tax?
I’d like any registration scheme to be a collaboration with operators. I don’t really want to feel like I am being bullied or threatened into complying. It feels like we’re beaten with enough sticks already from the media etc.
Opportunities
A registration scheme could be a way for our business to benefit. Could there be a commercial upside to us registering?
There are some areas that are less I am less certain of, such as Fire Furniture Safety regulations. However, we will always be trying to adhere to these regs.
The registration scheme is a chance for me to ensure that I am as good a host as I can be. I would definitely want to continue trading in a sector that is more regulated. Having to register is not a drawback for us.
The Prospective Operator
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Alex (41) Property Owner / Prospective Short-term Lets Operator |
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I have recently acquired and renovated a small property in a popular tourist town in England. My job requires me to travel a lot, so my property is often unoccupied. I like the idea of letting it out on a short-term basis, to ensure that it is occupied when I’m not there, and to generate additional income to help with my mortgage payments.
Needs and motivations
I’m happy to comply with regulations. I would have half expected there would be something already. I need to show that I am one of these good hosts.
I’ve thought a lot about how this is going to work. I’ve Googled a lot of stuff online, including looking at competition and looked at related professionals websites (i.e. solicitors). I’ve also spoken to my friends who do something similar. I need to have all that information at the top of Google search.
I want to do the right thing from the off. If I am asked to provide certain information that is fine, I just need to understand what is being asked.
When things get more technical, or beyond what I might already know as a home owner then I’ll need clearer instructions on what to do.
Challenges and worries
As someone new to the sector getting a bad reputation might be something I can’t recover from. I need to make sure I do everything I can to be reputable.
I’ve not got a clue how time consuming or costly some elements of running a STL will be. I’m hoping this will make me money so I need to know if parts of running a STL are going to cost me money or take up my time
If I’ve got something that you need to see then I’d prefer to just take a photo of it and send it to you. I’m not as set up to scan something in.
I’ve got ADHD so when I am presented with a lot of information to read this becomes an issue for me.
Opportunities
Could my new venture benefit from a registration scheme? Could there be an upside to me registering? Will this make it easier for me as a new entrant to the sector?
My research gave me some understanding of the local STL market, but I’m keen to know more. The STL scheme could be a way I could learn more about how many STLs are operated near me.
The Multiple Short-Term Let Operator
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Imran (66) Property Owner / Multiple Short-term Lets Operator |
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I have built up a portfolio of short-term let properties. Having done this for over 20 years I see myself as something of an expert in the sector. Managing my lets comes as second nature to me now. I’m open to changes but the thought of more admin does not sit well with me.
Needs and motivations
It’s paramount that all of my properties can be advertised in as many places as possible. Without this I will likely have no income.
I do this for a lot of properties so I’m comfortable with many different scenarios, regulations and health and safety checks. I don’t think a lot would faze me. I’d just need enough time to bring it all together.
I know I will need to register each of my properties, all I ask is that this is done in as painless a way as possible, and that it doesn’t become a big administrative burden for me.
Challenges and worries
I’d like any registration scheme to be a collaboration with operators. I don’t really want to feel like I am being bullied or threatened into complying. It feels like we’re beaten with enough sticks already from the media etc.
Opportunities
I see a registration scheme as necessary and as a chance for all my properties to be a step up from any dodgy landlords and owners out there.
I work hard to build a brand for my STLs, and I need to make sure that credibility is kept. Registering is just another way that I can show this. I feel strongly that those who don’t do things right shouldn’t be allowed to do it at all.
The Anxious Operator
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Anna (35) Property Owner / Anxious Short-term Lets operator |
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I own a second property which I use as a holiday home for me and my family. I don’t like the idea of the property being empty when we’re not there, so I let it out as short-term accommodation. This also helps me to generate additional income.
I do this via a management company, in exchange for a percentage of booking revenue.
Needs and motivations
I take pride in my STL being well run. And for the parts that I handle I do that to the best of my ability, as I know that is something guests want. I need my agency’s help there to make sure that I am on top of the latest goings on.
I did some research when I started, basically relying on what a Google search told me. I think I have a foundational knowledge, but I am dependent on my agency to steer me in the right direction nowadays. If I have to register myself I’m going to need to have the information explained in a digestible format.
I’d like to think that if I was asked about health and safety and compliance I’d know the right answer. But my default is to contact the agency for confirmation. If the onus is on me then I need to understand what is being asked.
When things get more technical, or beyond what I might already know as a home owner then I’d be getting in touch with the agency straight away.
Challenges and worries
If I have to do it, that is completely fine. I’d likely need some help from my management company as I don’t feel like I have the expertise to do it myself.
I know all this stuff exists as I pay someone to get it done. It would just be a case of me getting it and bringing it together. As someone who is not too experienced I’d probably worry that I’d send the wrong thing.
I’m not super confident in the sector and I know I have gaps in knowledge, so I don’t respond well to the thought of being ‘threatened’ into registering.
Opportunities
I like to handle some of the bookings and guest management so I’d be up for anything that helps me STL stand out. I’d see it as an opportunity if there is something that gets me more guests.
The Niche Operator
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Natalie (46) Property Owner / Niche Short-term Lets Operator |
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I own several shepherd huts close to a National Park. This was something that started as a hobby, but now is a full time business. I take care of all the hosting duties and love the challenge of doing something a bit different.
Needs and motivations
I use lots of different platforms to advertise my STLs including some specialist ones, I need to be able to continue to do so to drive guests to my STL.
If you want me to provide some of this information you’re going to need to tell me how to do that. As my circumstances don’t fit into this typical scenario.
I want to register. I just need to know how any registration scheme applies to my specific circumstances.
I have dyslexia, so I need any content to be presented in a digestible format.
Challenges and worries
I don’t think it’s particularly fair that my STLs are treated the same as some big second home in Padstow or some penthouse suite in Knightsbridge.
Because my set-up is not typical I know I won’t be able to provide some info - that worries me. Does it mean I can’t register? And that I’ll have to stop trading? Or will there be some sort of exceptions?
I have a good understanding of what is required to be a good host. But I worry about how my different STL might be able to adhere to what is being asked compared to the “normal” STLs on the market.
It feels like this might just be a way to monitor people or get more tax. I’m not making much of this so I don’t think that’s fair on someone like me.
Opportunities
This is a chance for me to be able to show that what I provide is super safe, and not have to answer those same questions from potential guests again and again.
Management Companies
The Consultation on a registration scheme for short-term lets in England defines a management companies as:
“A company allowing hosts to outsource some or all of their functions in respect of services provided to guests during their stay.”
This definition has helped us frame our thinking during Alpha, especially when planning and conducting user research with this group.
To help test some of our riskiest assumptions that related to management companies we invited around 50 to take part in a survey. More detail about the techniques that we used and how we engaged with this group can be found in our research and testing methodology page. Our analysis of this survey shows that there are likely to be two similar but also distinct types of persona within this user group. Whilst many of the sentiments expressed by Management Companies are similar - mainly that they have a desire to support their clients in being compliant, and also that they are in favour of more regulation in the sector. There are, in our opinion, some fundamental differences which necessitate two different personas. The main differences are in the role that management companies envisage themselves having in the scheme, and how ‘hands on’ they might be with regards to the registration process.
The Supportive Management Company
Supportive Short-term Lets Management Company |
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We are predominantly a booking and marketing agency. We keep on top of what is required of a short-term let(s) owner and keep them up-to-date, but we don’t have the capacity to implement necessary changes or run day-to-day logistics on a client’s behalf.
Needs and motivations
We see it as our responsibility to keep clients updated on important relevant information with regard to what they are required to do to keep up with their obligations as short-term let(s) owners and operators
We would much prefer to self-certify compliance. It is enough to remind people of their obligations, and reduces the admin burden on us, and likely also the government collecting the information.
We are happy to support clients where they need it but see it as their responsibility to go through the process of registering for the scheme.
It is important for our reputation, and that of our clients, that we are seen to be compliant with the relevant regulations
The registration process and what is asked for within seems reasonable and straightforward. We believe we, our clients and the sector as a whole will benefit from the scheme and there is no danger of either of us leaving as a result of registration becoming a requirement.
Challenges and worries
We manage properties for a lot of owners, so we need a way to provide a lot of information quickly, otherwise registration of all properties may take weeks or months
What’s required to comply is clear, though could be an extra burden to upload everything.
We are concerned that some information requested we do not typically collect, which could make the process of registration longer
Opportunities
We will collect important regulatory documentation from our clients in order to make sure they are compliant. We usually have more on file than the scheme asks for (PAT, CO, insurance) and believe the sector could benefit further if the scheme collected more evidence that it currently proposes to.
The Full Service Management Company
Full service Short-term Lets Management Company |
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We offer a full service to support our clients and they have varying needs. We complete all safety checks and services for clients on their behalf.
Needs and motivations
We see it as our responsibility to keep clients updated on important relevant information with regard to what they are required to do to keep up with their obligations as short-term let(s) owners and operators
Requiring upload of proof of compliance feels like the more reliable option, self-certification would be to easy to abuse for those so inclined. And we already have the necessary documents on file anyway, it wouldn’t be too much of a burden to upload them.
What’s required to comply is clear, and will be straightforward enough. We request these documents anyway and keep them on file for our records, as well making sure they are kept up-to-date. There would be no issue finding and sharing them.
The registration process and what is asked for within seems reasonable and straightforward. We believe we, our clients and the sector as a whole will benefit from the scheme and there is no danger of either of us leaving as a result of registration becoming a requirement.
We offer a full management service and as such will endeavour to register all clients’ properties on their behalf
It is important for our reputation, and that of our clients, that we are seen to be compliant with the relevant regulations
Where we support or complete a client’s registration we need clarity on what information is required of us, and which party’s information the form is requesting.
Challenges and worries
We manage properties for a lot of owners, so we need a way to provide a lot of information quickly, otherwise registration of all properties may take weeks or months
We are concerned that some information requested we do not typically collect, which could make the process of registration longer
Opportunities
We will collect important regulatory documentation from our clients in order to make sure they are compliant. We usually have more on file than the scheme asks for (PAT, CO, insurance) and believe the sector could benefit further if the scheme collected more evidence that it currently proposes to.
Who are our ‘Impacted users’?
‘Impacted users’ are people who are in some way impacted by the scheme or involved in the scheme but do not need to register This group is made up of the following users:
- Local authorities
- Booking platforms
Who are our ‘Data users’?
The data user group consists of people who have no direct link to the registration scheme and how it is run, but would use the data that it produces. This group is made up of the following users:
- Central government users
- Relevant public bodies
Who are our ‘Other users’?
This group is made up of those who might have an interest in the registration scheme and what it will deliver, but they do not have to register, and they would not benefit from any of the data it collects. They group has the following users:
- Bookers
- Neighbours
As part of managing scope it was decided that both of the users within the group were not a priority to research and test with. This decision was made as a result of these groups not being the subject of any of our assumptions for alpha.