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Highland Sends Two More Short-Term Let Control Areas to Scottish Ministers

Councillors have approved proposals covering Inverness and a broad sweep of the rural Highlands. If ministers agree, future conversions of homes to secondary short-term lets in the designated areas would automatically require planning permission.

Highland Council has approved two new short-term let control area proposals and will now ask Scottish Ministers to designate them, moving a large part of the region one stage closer to additional planning controls over homes converted for use as holiday accommodation.

The decision was taken by the council’s Economy and Infrastructure Committee on 28 September. One proposed control area covers Inverness and surrounding areas. The second would cover Aird and Loch Ness, Inverness South, Wester Ross, Strathpeffer and Lochalsh, Lochaber, Skye and Raasay, and Sutherland.

Modern Scot reported on 23 September, in Highland Short-Term Let Control Areas Move Towards a Decision, that the council was approaching the point at which it would decide whether to submit both schemes to ministers. That decision has now been taken. The proposals are no longer simply consultation exercises within Highland Council; their next stage lies with the Scottish Government.

Short-term let control area does not create another licensing scheme. Scotland already has a national licensing system for short-term lets. A control area changes the planning position for certain properties, particularly homes that are converted into secondary short-term lets where the host does not normally live.

What the designation would change

Within a designated control area, the use of a dwellinghouse as a secondary short-term let is treated in planning law as a material change of use. That means planning permission is required when a home is moved into that use after the control area takes effect.

Outside a control area, councils can still decide that a particular change from residential use to short-term letting amounts to a material change of use, but that judgment is ordinarily made on the circumstances of the individual property. Inside a control area, the planning position is clearer: the relevant change to secondary short-term letting is automatically brought within the planning system.

The measure is not retrospective. Existing secondary short-term lets do not automatically become unlawful merely because a control area is later designated. That does not mean every existing property is guaranteed to have lawful planning status. A council can still examine whether an earlier change of use required permission under the planning law that applied at the time, and operators can still need to establish lawful existing use where the position is disputed.

Home sharing and home letting are also distinct from secondary letting. A resident who lets a room in the home in which they live, or temporarily lets their own home while absent, is not automatically put into the same planning category simply because the property is within a control area. The council can nevertheless consider whether the particular scale and character of an operation amounts to a material change of use.

The result is a planning filter rather than a prohibition. If ministers approve the Highland proposals, a future owner seeking to turn a residential property into a secondary short-term let in the designated area would have to make a planning application. The local authority would then decide that application under the development plan and other material planning considerations.

More than 800 responses

Highland Council held a six-week statutory consultation during May and June. It says more than 800 responses were received from residents, businesses, community organisations and short-term let operators.

According to the council’s published account, 84 per cent of residents and businesses who responded supported the proposed Inverness City control area, while 72 per cent supported the Highland Rural proposal. Those percentages describe the people and organisations who participated in the consultation; they are not measures of opinion across the population of the proposed control areas as a whole.

The geographical scale of the rural proposal is one of the most consequential aspects of the decision. It would not apply to a single resort or concentrated tourism district. It would reach across communities with very different housing markets, from parts of the Inverness hinterland to Wester Ross, Lochaber, Skye and Raasay and Sutherland.

In some of those areas, the interaction between the permanent housing stock, second homes, holiday accommodation, local employment and seasonal visitor demand has become an increasingly important part of local housing policy. A control area does not determine how many short-term lets a community should contain, but it gives the planning authority a direct decision over future changes of residential property into secondary letting.

The scale of the existing short-term let sector is also significant. Scottish Government licensing statistics to 31 December 2025 recorded 8,284 short-term let licences in operation in Highland, by far the largest number of any Scottish local authority. Licensing data do not show how many of those properties would fall within the two proposed control areas, nor do they equate directly to homes removed from permanent residential use: licences include different types of short-term letting, including home sharing and home letting.

They do, however, show why the planning decision has consequences beyond a small number of properties.

Highland already has one control area

The Highlands are not entering the policy for the first time. Badenoch and Strathspey became a short-term let control area on 4 March 2024 after Scottish Ministers approved Highland Council’s earlier proposal.

Edinburgh became Scotland’s first designated short-term let control area in September 2022. If the two new Highland proposals are approved, they would extend the policy across a much wider area of the country and place several of Scotland’s most intensively visited rural and island communities within the same planning framework.

That does not mean the eventual planning decisions will be uniform. Planning applications remain applications. The designation establishes that permission must be sought; it does not predetermine whether individual proposals should be approved or refused.

The council will also have to administer the relationship between planning and licensing. A short-term let licence concerns whether an operator meets the requirements of the licensing scheme. Planning permission concerns the lawful use of land and buildings. Obtaining one does not automatically provide the other.

That separation has sometimes been obscured in the public debate because both systems apply to the same businesses and properties. The proposed control areas make the distinction more important: an operator may satisfy licensing requirements but still need planning permission for the use of the property.

The decision now belongs to ministers

The committee’s vote does not bring either control area into force immediately.

Highland Council must now submit the proposals to Scottish Ministers. The Government will consider whether each area should be designated. The council has said officers will report back following the ministerial decision, including on implementation arrangements and the date on which any approved control area would begin operating.

That commencement date will become the practical dividing line for future changes of use. A qualifying conversion from a dwellinghouse to a secondary short-term let after designation would automatically require planning permission. Existing uses would remain subject to the planning circumstances that already apply to them.

The next questions are therefore no longer whether Highland councillors support submitting the proposals, or what boundaries they intend to put forward. Both are now known.

The unresolved questions sit in Edinburgh: whether Scottish Ministers will approve both areas as submitted, whether either boundary will be changed, and when any approved designation will take effect.

For a region that already accounts for more short-term let licences than any other council area in Scotland, those decisions will determine how much of the future conversion of ordinary homes into secondary visitor accommodation must first pass through the planning system.

Sources

  • Highland Council — Highland Council agrees to submit Short Term Let Control Area proposals to Scottish Ministers, 28 September 2026. Read the council announcement.
  • Highland Council — Economy and Infrastructure Committee, 28 September 2026. Meeting record.
  • Scottish Government — Planning Circular 1/2023: Short-term lets and planning, 17 May 2023. Read the circular.
  • Scottish Government — Short-term lets licensing statistics: Scotland to 31 December 2025. Local-area licence statistics.
  • Highland Council — Short Term Let Control Areas: Badenoch and Strathspey. Current Highland control area.
  • Modern Scot — Highland Short-Term Let Control Areas Move Towards a Decision, 23 September 2026. Modern Scot.
Andrew Robertson

Andrew Robertson

Writes analysis on public policy and national developments, focusing on the structures and decisions shaping modern Scotland.

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