Will operators understand what they need to provide to be compliant?

Posted on 16 October 2024

Please note: the screenshots shown here document the evolution of the design and are not indicative of the final service.

What we tried to achieve

We wanted to know more about short-term let owners and operators’ understanding of the different things they might need to provide during the registration process in order to be compliant with the regulations included within the scope of the scheme.

We wanted to learn if there were any patterns in their understanding, for example whether more experienced operators know more, or whether there were certain elements of compliance which people knew more or less about.

We wanted to learn things such as:

Short-term lets owners’ understanding of compliance certificates and standards
How confident they would be in answering questions on whether their property complies with fire, fire furniture and electrical safety regulations
How comfortable they would be providing a Gas safety certificate
How comfortable they would be providing a Fire Risk Assessment
How comfortable they would be providing a Electrical Installation Condition Report (EICR)
How comfortable they would be saying their property complies with the Fire Furniture Standard
The time and cost it would take to obtain these different compliance checks or documents, or check their property complied with these regulations
Whether people wanted or needed guidance. And if they did want guidance how much additional guidance would they need, and what would they expect that guidance to contain
Their thoughts on uploading proof of compliance with regulations, as opposed to answering a series of ‘Yes/No’ self-certification questions

We also wanted to learn about Management Companies’ thoughts around compliance. From that user group we wanted to find out:

How Management Companies keep up to date with compliance and health and safety standards
How Management Companies work with their clients in relation to health and safety and compliance e.g. do they already share guidance on these regulations with clients
What compliance checks are already undertaken by Management Companies when onboarding clients
How easy or difficult is it for an owner or operator to obtain the type of compliance information that a registration scheme might request
How many of their clients would be in a position to provide the type of compliance information that might be requested by a registration scheme
Their thoughts on different compliance approaches (i.e. self-certification, document upload, spot checks, etc.)

Answering these questions would help us clarify Assumption 16 (“We assume that operators will understand the short-term let regulations they need to comply with as part of the scheme”).

How we tested our assumption: methods, validation, and rationale

Our testing approach

We tested this assumption in round 2 and round 3 with short-term let operators. This was something that we could test with any operator, irrespective of the number of short-term lets they own, or how long they have been operating. The make-up of the participants for these rounds of testing is shown in the table below.

Breakdown of key characteristics of round 2 and round 3 participants that tested this assumption:


	Round 2	Round 3
Experience of owner	2 × Prospective owners 2 × less than 12 months 1 × 10+ years	1 × 1-5 years 2 × 6-10 years 2 × 10+ years
Type of short-term lets owned	5 × Privately owned self-catering holiday home(s) e.g. Holiday Cottage	2 × Privately owned self-catering holiday home(s) e.g. Holiday Cottage 2 × Entire privately owned house(s) 1 × Individual rooms or annex within privately owned house(s)
Number of short-term lets owned	2 × 1 short-term let 1 × 2-5 short-term lets 1 × 5-10 short-term lets 1 × 10 short-term lets	3 × 1 short-term let 2 × 2-5 short-term lets
Number of days the short-term lets are let out over a calendar year	3 × Unsure on the exact amount 2 × Own a property that could be used as a short term let but are currently not using it for this purpose	1 × let for 31-90 days 2 × let for 91-180 days 2 × let for 181-365 days
Location of short-term lets	2 × North Yorkshire 1 × Derbyshire 1 × West Yorkshire 1 × West Yorkshire & Devon	1 × Southwest England 1 × Northwest England 1 × London 1 × East Midlands 1 × West Midlands
Self managed or using a management company	3 × self managed 2 × None of the above (prospective operator)	3 × self managed 2 × use a management company
Places where participants advertise (multiple choice)	1 × Facebook 1 × Airbnb 1 × Booking.com 1 × I don’t advertise online	5 × Airbnb 4 × Facebook
Digital literacy	2 × 10/10 3 × 9/10	1 × 8/10 1 × 6/10 1 × 7/10 2 × 3/10
Access needs	None	2 × Dyslexia 1 × Dyscalculia 1 × ADHD
Assistive Tech used	None	1 × iOS speech & Immersive Reader 1 × Isolator & Time Timer 1 × Text-to-Speech & MathTalk 1 × iOS speech, Immersive Reader, & Firefox Reader View

In the opening part of the testing sessions, we asked participants the following questions to ascertain their understanding of their responsibilities to their guests:

“How familiar were you with the different responsibilities you might have as a short-term let owner?
1. Wellbeing/safety of your guests
2. Planning permission (London)”

We also identified certain parts of the prototype where we could ask questions on this. These were:

Start page
- ‘See the full list of documents or certificates that you will need as proof of compliance’
Gas safety page
Fire safety page
Furniture fire safety page
Electrical Safety page

We drafted some prompts and probing questions to ask participants when discussing these pages of the prototype with them, an example of which is below:

Pause on ‘Upload your Gas safety certificate’ page

How comfortable would you be in providing this?
How much time do you think it would take you to find or obtain this certificate?
What are the costs associated with obtaining that certificate?

If participants selects ‘Read guidance about gas safety regulations for short-term lets.’

What were you hoping to find on that link?

Pause on ‘Does the short-term rental comply with the relevant fire safety standards for this type of accommodation?’

“On this page you can see you are not asked to upload anything, whereas previously you were asked about uploading a certificate”

What are your thoughts on uploading proof for things, as opposed to answering a Yes/No question?
How would you feel if you were asked to upload proof of this?
How confident would you be answering this question?
How much time do you think it would take you to ensure your property complied with the relevant electrical safety standards?
What are the costs associated with that?

If participants selects ‘Learn more about the fire safety standards for short-term rental accommodation in England.’
What were you hoping to find on that link?

This approach was consistent across both rounds 2 and 3 of the testing.

As part of our Management Company survey, we also asked a number of questions that related to compliance with health and safety regulations. Listed below are the questions that were asked to find out what Management Companies do in relation to compliance.

Screenshot of a related question from a survey sent to management companies. The question was; What resources or guidance do you use to find out about regulations and guidance on the operation of short-term lets in England? There is a free text space below for survey respondents to provide their answer.

Screenshot of a related question from a survey sent to management companies. The question was; What do you do to support your clients with their responsibilities regarding health and safety and other standards (e.g. fire standards, electrical standards)? There are 7 checkboxes underneath; Update them on changes to standards or regulations, Share possible upcoming changes that could impact them in the future, Share industry best practices, other suggestions on complying with standards, Arrange the safety checks with specialists on their behalf, Capture proof of each client's adherence to standards (e.g. Gas Safety Certificate, adherence to fire standards), None of the above, Other

Screenshot of a related question from a survey sent to management companies. The question was; What documentation or proof of adherence to standards do you request?
Please also tell us about any other checks you do with your clients. There are 9 checkboxes beneath the question; EICR (Electrical Installation Condition Report), Fire Risk Assessment, Gas safety certificate, Portable appliance testing (PAT testing), Accessibility checks (i.e. access for wheelchairs etc), Proof of carbon monoxide alarm, Furniture fire safety standards checks, Proof of insurance (i.e. holiday home insurance, public liability insurance, etc.), I don't request any documentation or proof of adherence to standards

Participants were also shown a screenshot of the different compliance pages in the prototype and asked to indicate how clear or unclear they felt what was being asked.

There were also several questions to understand more about providing proof of compliance, e.g. both themselves and their understanding of the clients’ readiness to do so.

Screenshot of a related question from a survey sent to management companies. The question was; Of the short-term lets you manage for your clients, how many short-term lets do you think already have the following proof of compliance (if it's applicable to them)? The first column lists 3 types of compliance certifications: Gas safety certificate, Fire Risk Assessment, and Electrical Installation Condition Report. The second column lists 4 possible responses for each type of certification: All of them, Most of them, Some of them, and None of them. There is a checkbox for each possible response.

Screenshot of a related question from a survey sent to management companies. The question was; If you were registering an individual short-term let on behalf of a client, typically how easy or difficult would it be for you to obtain the following proof of compliance with regulations on their behalf? Below is a table of radio buttons with 3 rows; Gas safety certificate, Fire Risk Assessment and Electrical Installation Condition Report. There are 5 columns in the table; Very easy, Easy, Neither nor difficult, Difficult and Very difficult.

Management Companies were also asked their opinions on different approaches to compliance that the scheme might use and how comfortable they would be adhering to these in their capacity as Management Companies.

Screenshot of a related question from a survey sent to management companies. The question was; An alternative to asking operators (or owners) of short-term lets to upload proof of compliance (i.e. gas safe certificate) is to ask them to self-certify that they meet these standards (i.e. with a Yes/No question). In both cases, the details provided might be checked. Do you have a preference between uploading proof of compliance or self-certifying? Underneath there are 6 radio buttons which are; Prefer self-certify approach, Prefer upload documentation/certificates approach, Prefer the combined upload documentation and self-certify approach, Prefer the combined upload documentation and self-certify approach with spot checks, No preference, Not sure

Screenshot of a related question from a survey sent to management companies. The question was;If you were registering a short-term let on behalf of your clients, to what extent would you be comfortable self-certifying that it meets the gas, fire and electrical safety standards? There are 5 radio buttons underneath which are; Extremely comfortable, Very comfortable, Moderately comfortable, Not comfortable and Not comfortable at all

The findings from our usability testing sessions and survey of management companies can be found in the ‘Our findings’ section below.

Creating the ‘Compliance pages’ prototypes

In round 2 of testing, we mocked up a version of the registration start page which included a ‘details’ information drop down tab, named “See the full list of documents/certificates that you will need as proof of compliance”. We wanted to test users’ reaction on whether they had the necessary information they needed to complete the registration, prompted by this information page up front, or if they would need to search for anything additional and return to complete the form at a later stage.

Screenshot of a page showing a heading that reads: ‘Before you start’. Beneath this there are three detailed components that read “Check the type of dwelling that needs registration”, “See the full list of documents or certificates that you will need as proof of compliance” and “Check what happens to my data”.

Following on from conversation with the Policy team, the content within this drop down includes: “Fire risk assessments, Gas safety certificates (where applicable), Electrical & product safety”.

Screenshot of a page showing a heading that reads: ‘Before you start’. Beneath this there are three detailed components that reads “Check the type of dwelling that needs registration”, “See the full list of documents or certificates that you will need as proof of compliance” and “Check what happens to my data”. The details tab that reads “See the full list of documents or certificates that you will need as proof of compliance” appears open and three bullet points sit within this that reads: ‘Fire risk assessments’, ‘Gas safety certificates (where applicable)’ and ‘Electrical & product safety’.

We also created a declaration page in this round of testing to accompany the registration start page, requiring operators to tick two boxes: one confirming they are over 18, and another stating that the information they submit is complete and accurate. This change allowed us to test whether presenting the declaration at the beginning of the process had any impact on the operator behaving differently, compared to when we placed the declaration at the end of the form (after uploading property details). We aimed to determine whether an early declaration encourages more active participation in the registration application process.

Screenshot of a page showing a heading that reads: ‘Declaration’. Beneath this there is text that reads “By continuing this application you agree that the information you will give is complete and correct. If you deliberately give the wrong or incomplete information, you may: “need to pay a financial penalty” “your registration number may be revoked”. Below this there are two checkboxes which read: “I hereby declare that I am over 18 years of age.” and “I understand and agree with the above statement.”. Below this there is a green action button labelled “continue”.

Our findings

Findings from usability testing sessions with operators

The testing sessions from round 2 and round 3 provided us with some useful insights on whether operators will understand what they need to provide during the registration process in order to be compliant with regulations included within the scope of the scheme.

Below are some details on the key findings which relate to Assumption 16 (“We assume that operators will understand the short-term let regulations they need to comply with as part of the scheme”).

All the findings detailed below are a result of thematic analysis which uncovers the most common patterns and trends that occurred when we conducted our testing of this assumption. This analysis does not provide any quantitative metrics, but the findings set out below are the most important and frequent themes that came as a result of testing this assumption.

1. Most participants’ first impressions were that they understood what information was being asked for (with regards to health and safety and other compliance) during the initial parts the registration process, and they felt they could provide this information easily.

Participants understood the compliance requirements set out on the ‘Start’ page (under the ‘See the full list of documents or certificates that you will need as proof of compliance’ accordion); they also told us that they did not feel it would be particularly arduous to provide proof of this, be that sourcing it from scratch via a professional, or sharing the proof they already have. They did not feel what was being asked would have an impact on whether they would decide to register or not.

"(I have) done it and would be happy to share it. "

“not a burden at all”

Having said that, operators did express that they would want more detailed information so they could be certain that they were in fact complying with what was being asked, as opposed to relying on their own interpretation of compliance.

Resulting service design and prototype design suggestions:

Providing more of an explanation of what steps short-term let operators will likely need to take in order to comply with each of the gas, fire, electric standards. For example, provide them with the expected Fire Risk Assessment template. Where necessary signpost to other resources, or local services that operators could use to help them become compliant.
Where operators are not able to upload any documents to prove compliance, either include a short explanation of why that is the case (for example, “there is no standard Fire Furniture Assessment and therefore there is no need to upload any proof in this instance”). Ideally, where no ‘standard’ proof is available it must be made clear to operators how they can confidently answer ‘Yes’ to self certify, for example by providing a checklist of things which they must meet in order to comply. There should be no ambiguity.

2. When looking at the compliance section of the registration process in more detail, participants struggled when considering how to prove compliance with Fire Safety, Fire Furniture standards, and electrical safety.

When interacting with the ‘Fire Safety’ and ‘Fire Furniture Safety’ pages, participants were less assured and often less certain on what they would be able to upload as proof (for ‘Fire Safety’) or how they could confidently answer ‘Yes’ (for ‘Fire Furniture Safety’). This became more evident when compared to their understanding of the ‘Gas safety’ page.

Participants did not immediately recognise the Fire Assessment and Electrical Installation Condition Report (EICR) in the same way they did the Gas Safety Certificate and were more likely to try and use the corresponding ‘Learn more’ link (see screenshot below).However, this was not seen as a reason not to register. Participants expressed some concerns about how they would have to go about getting proof. For example, they were uncertain as to whether proof must come from a nominated body or association, their local authority or whether they could obtain proof through an independent tradesperson of their choosing.

“fire [requires] no upload - at work we don’t have a certificate, but had to be checked, do you get a certificate with fire safety? I don’t think you do”

“Wouldn’t automatically be able to say yes or no. I’d need to know first what that entails”

Screenshot of a page showing a heading that reads: ‘Does the short-term rental comply with the relevant fire safety standards for this type of accommodation?’. Beneath this there are two radio buttons that have a “yes” and “no” option. Beneath this there is a link that reads “ Learn more about the fire safety standards for short-term rental accommodation in England” Below this there is a green action button labelled “continue”.

Resulting service design and prototype design suggestions:

Ensure that the content within any ‘Learn more’ links is valuable to operators, and gives them the guidance and certainty they need.
If proof is being requested, be clear about what that might be and what the requirements for that are, i.e. where must it be sourced from, how often must it be updated, etc.

In round 3, we updated the compliance pages, revising the dropdown content two more times (see screenshot below) so the information section more helpfully explains to participants how to make their property comply with safety regulations.

Iteration 1 - “How can I comply…”

Iteration 2 - “How can the property comply…”

Screenshot of a page showing a heading that reads: ‘Does the short-term let comply with the relevant fire safety standards for this type of accommodation?’. Beneath this there are two radio buttons that have a “yes” and “no” option. The “No” radio button is checked. Beneath this there is a details component that reads “ How can the property comply with current fire safety standards for short-term let accommodation in England?”.

3a. All participants are comfortable with Gas Safety Certificates

The Gas Safety Certificate is something which all participants have an understanding of. This was true of all levels of operating experience.

3b. Opinions on uploading proof of compliance appear to differ depending on experience

When asked how difficult it might be to source and upload proof of compliance the responses seem to vary depending on the experience levels of the operator. A summary is below:

Prospective operators believed that obtaining a Gas Safety Certificate, a Fire Assessments and an Electrical Installation Condition Report would likely be a tricky, costly or time consuming task to complete.
More experienced operators all said that it would be easy to get hold of a Gas Safety Certificate as they would have records of this. However, there was still some uncertainty around sourcing Fire Assessments and an Electrical Installation Condition Report, although all participants provided educated guesses of how they might go about sourcing them.

Other observations from the testing around uploading proof were that operators mentioned it would be useful to be able to save and return to their registration if they did not have the proof immediately available. Also, no participants picked up that some pages required documentation to be uploaded as proof (Gas Safety, Fire Safety, and Electrical Safety) whereas other pages didn’t (Fire Furniture Safety).

“Most of them (gas certificates) I have, in fact all of them, anyway. Mostly well organised, everythings in a file, so going through and uploading them is fine. Where I don’t have them electronically I’d scan”

“For us everything is filed and is online, so uploading it would be easy.”

“(It’s) no problem understanding gas certificate, (it’s) just being able to share them would be a problem”

Resulting service design and prototype design suggestions:

It would not cause any issues to users to continue with a mix of providing proof via uploads, and self-certification questions. But be mindful that finding and uploading some proof is easier (Gas certificate) than others (Fire Assessment and Electrical Installation Condition Report).
Make it clear how applications are saved during the registration process and allow users to return to incomplete applications.

Example of self certification question and uploading proof:

We also recognise that users may want to upload multiple files at once on each of these compliance pages, if an evidence document is saved across several files. Currently our prototype uses the standard file upload component from the government design system, but if further research shows a need to upload multiple files at once, the Ministry of Justice’s multi-file upload component would be worth exploring, as this allows users to upload multiple files more efficiently.

4. The concept of property spot checks is not a barrier to people registering

When testing an iterated version of the declaration page, where users were asked about spot checks, no participants had any objections to the principle of a spot check of their short-term let (see screenshot below). As a result, all participants would have been happy to sign up to this on the ‘Declaration’ page. One participant did have some reservations about how the process of spot checks would work in reality, and they wanted to know that it wouldn’t negatively impact a guest’s experience.

Resulting service design and prototype design suggestions:

Continue to use spot checks as part of any compliance strategy as it would not have an impact on users registering.
Provide some additional information on how the spot checks process might work to alleviate any concerns hosts may have on how a guest experience could be impacted.

Findings from survey of Management Companies

Below is a summary of the findings that came from the Management Company survey that related to Assumption 16:

1. The ‘proof’ Management Companies ask for corresponds with most of what is being asked for as part of the registration scheme.

We asked survey respondents what proof of adherence to standards/regulations they request from their clients. The most commonly selected responses were

Fire risk assessment (14/16)
Electrical Installation Condition Report (13/16)
Gas safety certificate (11/16)
Portable appliance testing (11/16)
Proof of insurance (11/16)
Proof of carbon monoxide alarm (11/16)

From the six items above that are collected the most by Management Companies four (highlighted in bold) are also things that operators will be asked to provide proof of to comply with the registration scheme. One item that is part of the registration scheme but is only collected by 5 out of 16 respondents to our survey is proof of ‘Fire furniture safety’.

This finding indicates that most of the items being requested as part of the registration scheme are likely to be things that operators already provide to other organisations, and therefore might not be too burdensome to provide as part of a registration scheme.

2. There could potentially be scope to increase what is being asked for to comply with the scheme

As can be seen from the previous findings, there are several other items that are asked for by Management Companies and therefore could conceivably be asked for as part of the registration scheme. These items were ‘portable appliance testing’ (11/16), and ‘proof of insurance’ (11/16). These things are not currently under consideration as part of the registration scheme but our survey seems to indicate that they are things which operators might often have to provide.

3. Management companies felt that compliance pages in the prototype were clear

When asked how clear they felt each of the compliance pages were, the 16 respondents gave the following responses:

100% said that Gas safety / Gas Safe Certificate page was either extremely clear or very clear
100% said that the Electrical Safety Standards / Electrical Installation Condition Report page was either extremely clear or very clear
93.3% said the Fire Safety / Fire Assessment page was either extremely clear or very clear
80% said the Fire Furniture Standards page was either extremely clear or very clear

This shows us that the language and terminology used is in keeping with what Management Companies might themselves use. It is worth noting that the ‘Fire Furniture Standards’ page was the lowest scoring. Could tThis could be because it is something that is less commonly requested by Management Companies, and therefore less known about and therefore not as clear.?

4. Management companies believe a high proportion of the clients would already be in a position to meet compliance requests**

When asked whether they felt their clients already had proof of compliance the results were:

15/16 thought most or all of their clients would have Gas Safe Certificates
16/16 thought most or all of their clients would have Fire Assessment
14/16 thought most or all of their clients would have Electrical Installation Condition Report

The only other responses to this question (1 or 2 in 16 responses) were where Management Companies thought only ‘some’ of their clients would have the proof. This helps to back up what is being asked for proof as part of compliance to the scheme as items that are quite common across the sector.

6. Management companies believe what is being asked would be easy to obtain

When asked how easy or difficult would it be for Management Companies to obtain the following proof of compliance with regulations (assuming they were registering an individual short-term let on behalf of a client) Management Companies responded:

75% thought it would be either very easy or easy for them to get a Gas Safe Certificates
75% thought it would be either very easy or easy for them to get a Fire Assessment
69% thought it would be either very easy or easy for them to get an Electrical Installation Condition Report

Some free text responses highlighted a need for Management Companies to have sufficient time to collect some of these examples of proof from their clients. There were also comments that some properties are quite niche so gathering proof may take more time, there were also references to simply having time to prepare and collect these documents.

"Many agents have lots of owners and we need reasonable notice, say six months to get all the info aligned. That would be more than sufficient to move 95% into ‘very easy’“Most of our clients are well versed in this process as we’ve been doing it for years anyway”

“There can be some extra work required in obtaining compliance records depending on the specific context of each property and the client’s availability. Some suggested additional time would be useful for them to source this information, or inform clients.”

Of the 16 Management Companies who completed the survey 3 made comments stating that they do not believe it is their responsibility to register and this was where we had some of the ‘difficult’ scores.

“We would put the onus on all owners to complete any registration forms themselves.”

“because it’s for THE OWNER to register”

“When we don’t manage something, we often spend a lot of time chasing owners to get the paperwork sent through to us.”

What happened next

The declaration page has undergone a few iterations based on user feedback and engagement. Initially featuring only a few checkboxes,as shown above, we expanded the content to address additional user questions and concerns. The latest addition is a new checkbox stating: “I confirm that I have the property owner’s consent to complete this application on their behalf, if applicable.” This is important for users who may be applying on behalf of someone else, for example, a Management Company registering on behalf of an owner or operator of a short-term let This new addition will need to be tested in Beta.