Remarks from the French Authorities

[camille-mosser-dge]

The answers to this survey come from the Directorate General for Enterprise of the Ministry of Economics, Finance and Industrial and Digital Sovereignty, one of the administrations responsible for implementing the European STR regulation at the French national level.

• 6 Overview : The diagram goes far beyond what is included in the regulation. It seems that the API calls / requests « POST:/ listing » and « GET :/ orders » aren’t included in the regulation as the platforms are not required to transmit their listings (without activity data) to the SDEP. As mentioned during the webinars, the way to inform Member States about the invalid listings is not defined by the regulation, nor is the manner in which listings should be removed from the platforms.
• 7 Main entities : among the entities listed in this part, the creation of a global entity that would encompass all six types of data transmitted by STR platforms should be considered
• 7.3. Legal entities Definition Legal entities are define as such : « A self-employed person, company, or organization that has legal rights and obligations However, a self-employed person is usually not a legal entity. In spite of being an entreprise, he or she remains a natural person (that is to say, in this case, there isn’t any creation of a legal person separated from the natural person). And what if a legal entity has several legal representatives ?
• 7.4 Online Short term rental platforms : The property « type » seems to be problematic, for which the usage mentions that "Values can take small, micro or medium". Indeed, only two categories are relevant for the regulation : on one hand, small and micro, on the other hand, the rest of them. Moreover the categorie ‘large’ is not represented here (or at least entities that are neither micro, small nor medium).
• 7.6 Person The definition of this entity is problematic. In fact, the regulation includes two categories of persons, natural persons and legal persons (see, in particular, Article 5). However, this definition only refers to natural persons.
• 8 Supportive entities 8.1 Address Usage note The link to the description of INSPIRE address representaton is not valid.
• 8.17 for location the use of GPS coordinates would also be appropriate
• 10 Use cases
• Use cases 2, 4 and 5 go far beyond what is included in the regulation. The regulation doesn’t include such exchanges for which specifications shouldn’t be included in the recommendations.
• Use case 6 (The STR Platform provides activity data to the Competent Authority) In general we would rather use CSV instead of JSON. The data should be reported monthly, not for each stay (as it is implied). Some data seem to be missing as, per article 9, providers of STR platforms should also transmit, together with activity data per unit, "the corresponding registration number as provided by the host, the specific address of the unit and the URL of the listing".
• Also, in general, a strong ontology may facilitate data exchanges but may be a bit hard for member states to put in place.

[EmidioStani]

Dear @camille-mosser-dge , thanks for your feedback !

Please find below the answers to the above points

• 6 Overview : The diagram is a UML class diagram that encompasses concepts from STR regulation, useful for member states and platforms, reusing, when possible, existing concepts coming from European specifications. The 2 API calls in question are: -- POST /listing, is an operation to check the listings are valid accordingly to the Article 7.1.c and 10.2.b -- GET /orders , is an operation to retrieve orders sent by the Competent Authority accordingly to the Article 6.6

• 7 Main Entity: What would be the usefulness of such a big entity ?

• 7.3. Legal entities: Self-employed people are legal entities, they don’t have to be confused with sole-traders as they need to be registered in business registers in order to conclude business. The Directorate is welcome to participate in the SEMIC webinars. For the legal representatives, according to Article 5.c it is written “the name of a legal representative;”, therefore only 1 is required by the legislation.

• 7.4 Online Short term rental platforms : Within the legislation, Article 9.2 mention “small or micro online short-term rental platforms within the meaning of Commission Recommendation 2003/361/EC1”. The value “medium” comes from the Commission Recommendation. The value “large” could be added.

• 7.6 Person: Person is meant to be a natural person, as clarified in the usage note and distinguished from Legal Entity

• 8.1 Address: Thanks for reporting, the link will be replaced with https://knowledge-base.inspire.ec.europa.eu/publications/inspire-data-specification-addresses-technical-guidelines_en

• 8.17 Location: The use of coordinates is foreseen in the Geometry class.

• 10 Use cases: Use case 2 is needed otherwise other use cases cannot be derived. Use case 4 and 5 are related to the POST /listing and GET /orders as mentioned before.

• Use case 6: CSV format cannot be easily validated using a schema (like it would be via XSD or JSON schema) therefore it is discouraged. Indeed the data should be reported monthly. The activity has a reference towards a URL of listing (see the usage of ActivityData.isAbout from which information of the registration number and address could be derived. However that information is not explicitly put in the UC6, therefore will be added.