Legal framework and basic direction of the proposal

The amendment affects the Act already at the level of defining its subject matter. Section 1 (1) of the Act is to newly reflect the collection and sharing of data relating to accommodation services and the performance of state administration in tourism. The proposal explicitly declares the connection to a directly applicable regulation of the European Union, namely Regulation (EU) 2024/1028 of the European Parliament and of the Council on the collection and sharing of data relating to short-term accommodation rental services. From an interpretative point of view, it is essential that the national regulation is to be conceived from the outset as part of the European data framework, not as an isolated national regime.

Definition of basic concepts

The definitions contained in the proposed Section 9e of the Act are of decisive importance. It is here that the personal and material scope of the new regulation is defined, i.e. the range of entities and situations that will be subject to registration and record-keeping obligations. An “accommodation provider” is to be considered both a person who provides accommodation on the basis of a trade license and a person who is a host within the meaning of the EU regulation. The proposal is thus clearly not focused only on hotels, guesthouses or similar facilities, but also on a wider range of persons offering accommodation in the platform rental regime.

The proposal also works with the category of "accommodation units" to cover individual apartments or houses offered for short-term use. This terminology is important for practice. The registration regime should also apply to situations that in everyday operation appear more like "renting an apartment for a few nights" than as a classic accommodation service in the traditional sense.

A practical connecting institution is the registration number, which is intended to function as a unique identifier linking the offer, the state register and the related obligations in the digital environment. The purpose of this element is obvious: to enable the "matching" of a specific accommodation with a specific provider and with data registered in the public system.

The registry as a central tool for data regulation and management

The proposed Section 9f of the Act establishes the “Register of Accommodation Facilities, Accommodation Units and Accommodated Persons” as a public administration information system managed by the Ministry for Regional Development. The register is to serve as a single digital point of contact under EU legislation. From the point of view of the design of the proposal, it is a key element. The data is to be concentrated in one central system, which will serve not only as a record, but also as an infrastructure for data sharing.

Centralization has major consequences beyond tourism itself. Data currently scattered across various regimes (local fees, foreigner agenda, operational records) is to be concentrated into a single system. This naturally increases the demands on the accuracy of records, on process settings at providers and on clear definition of access and data flows between public authorities.

The proposal also includes a data retention regulation that works with several regimes. The basic rule is a six-year period from the registration of the end of accommodation; in addition, the periods according to EU regulations, regulations on local fees and regulations on the residence of foreigners are to play a role. It is specifically stipulated that data on a foreigner registered by a person who is not the accommodation provider are stored for a maximum of 24 hours from the automated confirmation of receipt by the information system of the Police of the Czech Republic.

Scope of duties

The proposal is based on a combination of one-time registration and subsequent ongoing registration. In practice, this means that publishing an offer on the platform should no longer be seen as the only step to starting an activity; the provision of short-term accommodation should be linked to registration in the information system, including the precise identification of the place and the provider.

The most sensitive part of the proposal, however, is the registration of accommodated persons. That is, the obligation to record data immediately after accommodation, no later than 24 hours. This construction will be directly reflected in the operational reality of short-term rentals, especially where the practice is based on simplified digital check-in or limited contact between the host and the guest. The 24-hour period is short and therefore requires a procedurally disciplined data collection and recording regime, including the ability to identify the guest to the extent required by the proposal.

The position of online platforms and issues not addressed by the proposal

The proposal explicitly includes online platform operators in the system of the Act, thereby confirming that platforms are understood as part of the regulatory ecosystem. At the same time, however, the background does not indicate how the obligations of platforms will be specifically defined. It is not clear how platforms will work with the registration number, what scope of data they will transfer, at what frequency, or how control mechanisms will be set up against offers that do not meet the conditions. The “platform” level of the proposal thus remains open to a certain extent, despite the fact that a significant part of short-term rentals is carried out through platforms in practice.

This openness has practical implications. Accommodation providers will have to set up internal processes to withstand even without support from a unified platform standard (e.g. if the platform does not technically enforce the provision of a registration number or does not provide tools for compatible work with records).

Practical implications and interpretation risks in follow-up agendas

The proposed amendment clearly aims to increase transparency through standardized data collection, sharing and storage. At the same time, however, it increases the administrative and procedural requirements of short-term rentals. It is not just a one-time registration, but an ongoing regime with short deadlines and a link to a central register. In practice, the obligation to record guest data within 24 hours, standardized location identification allowing for the “matching” of offers with real estate, six-year data storage and ambiguity regarding the obligations of platforms appear to be key.

The reservations and areas for clarification that appear in the related opinions are also significant. The government in the opinion[1] of March 9, 2026, identified the eTurista system as necessary, but pointed out the need for substantive clarification of the relationship to the administration of local fees, the foreigner agenda and the protection of personal data. It warned against higher administrative burdens and duplicate filling in. It also pointed out the unclear scope of access for other authorities, the absence of regulation of automated data transfer to the Police of the Czech Republic, the unclear technical compatibility of the systems, the budgetary aspect and legislative and technical shortcomings.

The Czech Chamber of Architects pointed out[2] that the amendment may enable the registration of apartments as accommodation capacities regardless of their construction law designation. It proposed including building authorities among the entities with access to the register and mentioned the issue of transferring decisions on the use of buildings to municipalities outside of administrative proceedings. The proposal thus opens up not only questions of the technical setup of the register, but also broader issues of links to tax administration, security agendas, personal data protection and construction law.

Conclusion

The proposed amendment aims to address short-term accommodation in a more systematic manner through standardized data collection, sharing and storage. The register as a public administration information system, mandatory identification of the accommodation provider and location, and ongoing records of accommodated persons represent a shift towards a more formalized and digitalized regulatory model.

The trend of legislative regulation is clear, but the specific implementation and clarification of open links will be decisive. The practical impact on short-term rental providers is direct. It will be necessary to set up operational discipline for continuous data recording, work with precise location identification and count on a longer data retention period. It is sensible for practice to start preparing for the new rules now, whether it is setting up internal processes, contractual relationships or technical support so that they meet the requirements for registration and compliance with registration deadlines. At the same time, however, it is true that a number of essential things are not yet clear. For example, how broad the mandatory cooperation of online platforms will be, how the registration number will be worked on in practice, or how exactly the register will be linked to the administration of local fees and the foreigner agenda. It will be interesting to see what direction the expert discussion on these topics will take and what specific form they will ultimately take.

[1] Parliamentary Paper 106; Amendment to the Act on the Conditions of Doing Business in the Field of Tourism; available here.

[2] For more information: GOVERNMENT OPINION on the proposal of deputies Eliška Olšáková, Karel Dvořák, Lucie Sedmihradská, Julia Smejkalova, Michal Zuna, Jiří Horák and Zdeňka Blišťanová for the issuance of an act amending Act No. 268/2025 Coll., amending Act No. 159/1999 Coll., on certain conditions for doing business and performing certain activities in the field of tourism, as amended, and other related acts (Parliamentary Press No. 106); available here.

[3] More on this: Statement of the Czech Chamber of Architects on the pending draft law amending Act No. 159/1999 Coll., on certain conditions for doing business and performing certain activities in the field of tourism, as amended, and other related laws; available here.

Source: legalweb.cz