Regulatory intelligence briefing

New York City’s Short-Term Rental Law: Three Years Later

Regulatory Intelligence & Policy Impact Assessment

Prepared by Strategic Awareness Group from public sources reviewed October 22, 2026. Not prepared for or commissioned by any client. Not legal advice.

New York City’s Local Law 18 of 2022 requires short-term rental hosts to register with the Mayor’s Office of Special Enforcement (OSE), and requires booking services to verify that a listing is registered or exempt before processing a transaction. OSE began accepting registrations on March 6, 2023, and began enforcing the booking-service requirement on September 5, 2023.¹ According to OSE, the law created a registration system to ensure compliance with the city’s longstanding rules, which limit short-term rentals in homes to one or two guests staying with the permanent resident.¹ This briefing reviews what the city’s latest reports show three years after platform verification began, and where that evidence stops.

How to read this briefing. Each statement is labeled by the kind of evidence behind it:

City data
City claim
Independent research
SAG assessment
Uncertain

“City data” means figures reported in the city’s official reports. “City claim” means a characterization or conclusion stated by the city that this briefing has not independently tested. “SAG assessment” is our own analysis of the sources cited. “Uncertain” marks questions the available evidence does not settle, and figures we could not independently confirm.

1. Bottom line

Three years after booking platforms began verifying registrations, New York City’s legal short-term rental market is small and mostly held by unit owners, and the city is enforcing the law through summonses and, since FY26, registration revocations.^1,2 Most 2025 violations were found at corporate-controlled properties and larger buildings; that describes where violations were cited, not evidence that the city selects corporate operators for enforcement.² The reported 6.6% share of 2025 penalties paid is a point-in-time snapshot: about half of those summonses were still awaiting a hearing as of April 2026.² Whether the law has improved housing affordability is not established. The city links illegal rentals to rising rents; one independent study found no statistically detectable first-year rent effect, which does not rule out other housing-market effects.^1,4

3,500+registrations active at some point in FY26 (3,522); 3,338 at June 30, 2026¹

76%of active registrations held by the owner of the unit, as described by applicants¹

67%of 2025 locations issued violations were controlled by corporate entities, per the city²

2. Key findings

City data
The registry is small. 3,522 registrations were active at some point between July 1, 2025 and June 30, 2026, and 3,338 were active at the end of that period. OSE approved more than 460 new host registrations during the year.¹
City data
Registered hosts are mostly owners in small homes. 76% of active registrations are held by the unit’s owner, and 68% are in one- or two-family homes. Both figures are based on applicants’ own descriptions.¹ The city’s press release adds that 24% are held by renters.³
City data
Most denials follow uncorrected applications. 749 applications were denied in FY26 (counted by date of denial). 613 of them (about 82%) were denied after applicants did not make required corrections despite at least 90 days and specific guidance. Of those 613, 74% lacked adequate proof that the applicant was the permanent occupant, 57% involved listings the host had not shown to be legal, and 37% had uncorrected safety violations; one application can fall into several categories. A further 65 applications were denied because the unit was rent-regulated.¹
City data
Revocations have begun. OSE began revoking registrations in FY26. By June 30, 2026, 17 registrations had been revoked and 15 more were subject to revocation actions, which OSE says focused primarily on false statements in applications followed by patterns of illegal rentals. Several cases list alleged penalties above $100,000; alleged amounts are not final penalties.¹
City data
Most violations were cited at corporate-controlled properties and larger buildings. In calendar 2025, OSE received 2,036 complaints, recorded 8,553 inspection visits (attempted, conducted, and follow-up), and issued 1,909 violations. The city reports that about 67% of locations issued violations were controlled by corporate entities, and that 60% were multiple dwellings (three or more units).² These figures describe the properties where violations were found. The reports do not say how cases were selected, and multiple dwellings also accounted for 51% of complaints, so the mix may partly reflect where complaints arise and who owns larger buildings.²
City data
A small share of imposed penalties had been paid when the city reported. Penalties of about $9.6 million were imposed on the 1,909 violations issued in 2025, and about $632,000 (6.6%) had been paid.² This is a snapshot. As of April 2026, 963 of the 1,909 summonses were still pending a hearing, 451 were in default, and 121 had been dismissed.² The report also gives conflicting dates for the penalty figures (see Data notes). Pending adjudication, appeals, payment deadlines and collection practices could each affect the paid share, but the reports do not show how much any of them contributes.
City claim
The city credits the law with protecting housing. OSE states that illegal short-term rentals “have been linked to rising rents” and to removing homes from the long-term market, and estimates that as many as 18,000 permanent housing units were used as illegal short-term rentals by 2018.^1,3 Christian J. Klossner, OSE’s executive director, said: “Local Law 18 is not a ban; it simply prevents rentals that were already illegal.”³
Independent research
No statistically detectable first-year rent effect. A 2026 working paper by economist Alexander Marsella found that, among listings with a recorded review date, entire-home Airbnb listings requiring stays under 30 nights fell about 87% between March 2023 and January 2024, while 30-night listings became the dominant type. Using Zillow asking-rent data, it estimated a first-year citywide rent effect of −0.1%, with a 95% confidence interval of −2.3% to 2.2%. It found no additional increase in StreetEasy rental inventory when enforcement began. More Airbnb-exposed ZIP codes saw a modest relative rent decline for part of the period, which faded and was hard to separate from earlier trends.⁴ The paper has not been peer reviewed.
SAG assessment
“Not detected” is not “no effect.” The study measures asking rents, mainly in the first year, and its confidence interval allows for an effect of roughly two percent in either direction. It does not measure effects on housing supply, neighborhood conditions, or rents over a longer period. Its result does not show that the law had no housing-market impact; it shows that a first-year effect on asking rents was not statistically detectable.⁴

3. Confirmed facts vs. analytical assessments

Statement	Type	Source
Hosts must register; booking services must verify registration before processing bookings.	City data	1
3,522 registrations active during FY26; 3,338 at June 30, 2026.	City data	1
76% of active registrations held by owners; 68% in one- or two-family homes (applicant-described).	City data	1
749 denials in FY26, including 613 after uncorrected applications and 65 for rent-regulated units.	City data	1
17 registrations revoked and 15 pending revocation in FY26.	City data	1
~$9.6M in penalties imposed on 2025 violations; ~$632,000 paid at the time of the report.	City data	2
963 of 1,909 summonses from 2025 still pending a hearing as of April 2026.	City data	2
~67% of 2025 violation locations controlled by corporate entities. The city does not describe its method, and SAG could not reproduce the figure from the published summons list.	Uncertain	2
Illegal short-term rentals have been linked to rising rents.	City claim	1
Up to 18,000 permanent housing units used as illegal short-term rentals by 2018.	City claim	3
No statistically detectable first-year effect on asking rents (95% CI −2.3% to 2.2%).	Independent research	4
The composition of cited properties does not by itself show selective enforcement against corporate operators.	SAG assessment	2
Revocation and court action may prove stronger enforcement tools than fines while most fines remain unpaid.	SAG assessment	1, 2
Why the share of penalties paid is low.	Uncertain	2
The law’s effect on housing affordability and supply.	Uncertain	1, 4

4. Risk and opportunity assessment

All points in this section are SAG assessment, based on the sources cited. They are general observations, not legal advice.

Hosts

Risk: Registrations last up to four years, and OSE expects the first renewal applications in fall 2026.¹ Most FY26 denials followed uncorrected applications, most often for missing proof of permanent occupancy.¹

Practical step: Before renewing, have current proof of permanent occupancy and evidence that each listing is legal, and correct any open safety violations.

Opportunity: Registered hosts operate in a small legal market of about 3,300 registrations.¹

Property owners and managers

Risk: Summonses are issued to a named respondent, and many 2025 respondents are business entities, often named after the building.² Revocation cases list alleged penalties from the thousands to the hundreds of thousands of dollars.¹

Practical step: Owners who do not allow short-term rentals can place buildings on the city’s prohibited buildings list, which blocks registrations there; the city reports more than 14,000 owners and managers have done so.^1,3

Opportunity: Owner-occupants of one- and two-family homes would gain flexibility under Int. 0879-2026, but it has had no recorded action since its referral to committee on April 30, 2026.⁵

Policymakers

Risk: The affordability case for the law rests on city claims that independent research has not yet confirmed, and the city’s reports do not measure rents or housing supply directly.^1,4

Practical step: Ask OSE for hearing outcomes, collection rates over time, and its method for identifying “corporate” control, which would allow enforcement to be evaluated independently.

Opportunity: The city has now published four annual registration reports (FY23–FY26) with district-level data, a base for future evaluation.¹

Industry organizations

Risk: Claims that the law clearly did, or clearly did not, improve affordability go beyond current evidence and are open to challenge.^1,4

Practical step: Prepare members for the fall 2026 renewal cycle, and track Int. 0879-2026 for any hearing.^1,5

Opportunity: Position statements grounded in the city’s published data, with limitations stated, are likely to be more credible to policymakers.

5. What to watch

Fall 2026First registration renewals. Renewal approvals and denials will show whether hosts are keeping registrations current.¹
Int. 0879-2026Whether the Council’s Committee on Housing and Buildings schedules a hearing. As of October 22, 2026, the only recorded actions are introduction and referral on April 30, 2026.⁵
HearingsOutcomes for the 963 summonses pending as of April 2026, and whether the share of penalties paid changes in the next report.²
RevocationsThe outcome of the 15 pending revocation actions and any further cases.¹
ResearchPeer review of the Marsella working paper, and any studies of longer-term rent and housing-supply effects.⁴

Data notes and audit

Registrations. “More than 3,500” counts registrations active at any time during FY26 (July 1, 2025 – June 30, 2026): 3,522. The count at June 30, 2026 was 3,338. Owner/renter status and building type are based on applicants’ descriptions.¹
Denials are counted by date of denial, not date of application.¹
67% corporate. The press release describes this as the share of summonses issued to corporate entities.³ The underlying report describes it as the share of locations issued violations that were controlled by corporate entities, without describing how control was determined.² The published summons list truncates respondent names, so SAG could not reproduce the figure; a rough name-based review found about half of respondents had recognizable business-entity names, which should be read as a lower bound. This briefing uses the report’s wording and treats the exact figure as unconfirmed.
60% multiple dwellings. The report describes this both as 60% of violations and as 60% of locations receiving summonses; the press release says 60% of violations were in buildings with three or more units.^2,3
Penalties. The penalty table is labeled “as of April 2025,” which predates many of the 2025 violations; the summons list is labeled “as of April 2026.” SAG treats the penalty figures as a snapshot of uncertain date. “Penalties paid” is defined as imposed fines collected for summonses issued in the year.²
City estimates. The 18,000-unit and 14,000-owner figures come from the city’s press release, which does not describe the underlying methodology.³
Working paper. SSRN blocks automated access, so SAG reviewed the paper’s abstract from its DOI registration record, not the full text. Its exact posting date could not be confirmed.⁴
Registrations, listings and hosts are different measures; figures from different sources are not directly comparable.

6. Sources

NYC Mayor’s Office of Special Enforcement, Short-Term Rental Registration Report, July 1, 2025 to June 30, 2026 (Local Law 18 annual report, FY26). nyc.gov (Excel); index at OSE data and reports.
NYC Department of Buildings and Mayor’s Office of Special Enforcement, Illegal Conversions of Dwelling Units from Permanent Residences, 2025 (Local Law 87 report, dated September 1, 2026; covers calendar 2025). nyc.gov (Excel).
NYC Mayor’s Office of Criminal Justice, “New Report Reveals Number of New Yorkers Registered to Host Legal Short-Term Rentals Surpassed 3,500 for First Time,” September 1, 2026. criminaljustice.cityofnewyork.us.
Alexander Marsella, “Did New York City’s Airbnb Ban Lower Rents? Evidence from Local Law 18,” SSRN working paper, 2026; not peer reviewed. doi.org/10.2139/ssrn.7341298.
New York City Council, Int. 0879-2026, “Short-term rentals in one- and two-family dwellings,” introduced and referred to the Committee on Housing and Buildings April 30, 2026; status “Committee” as of October 22, 2026. legistar.council.nyc.gov.

Independent Research Demonstration — Not Commissioned Client Work. Prepared by Strategic Awareness Group from public sources reviewed October 22, 2026, to illustrate our research methodology. Figures are as reported by the cited sources. This briefing is not legal, financial, or real estate advice.