Aparthotel: what is it and can I convert to one?

 

An aparthotel is not a separate use class. Depending on how the accommodation is laid out and operated, it may fall within Use Class C1 as a hotel, but that is not automatic. Some serviced-apartment or short-stay accommodation may instead remain within Use Class C3 or amount to a different use altogether.

The planning question is therefore about the character of the use rather than the marketing label. Relevant factors can include the degree of transience, whether guests treat the accommodation as their home, the level of management and servicing, the physical layout and whether the building operates as a single hotel-style business.

Read on to see the factors that can point an aparthotel towards C1, and why two schemes using the same description can nevertheless have different planning classifications.

 

 

The Government has proposed a new Use Class C5 for short-term lets in England, but it has not been brought into force in England as at 2nd September 2026. An aparthotel should therefore be assessed under the law that applies now. A block of self-contained short-term lets does not become C1 merely because it is branded as an aparthotel or uses hotel-style booking or digital check-in.

If, for example, an existing bed and breakfast is converted into self-contained apartments, the planning position should not be assumed to remain C1 simply because the building was previously a guest house. The question is whether the character of the resulting use is still that of a hotel, boarding house or guest house, or whether the new operation amounts to a materially different use.

Use Class C1 covers use as a hotel or as a boarding or guest house where no significant element of care is provided. Aparthotels are not named in the Order. A proposed aparthotel therefore needs to fit the ordinary planning meaning of a hotel use on its particular facts.

 

Facilities of an aparthotel

 

Aparthotel accommodation is often more self-contained than a conventional hotel room, with a kitchen or kitchenette, living space and facilities suitable for longer stays. Those physical features are relevant, but they are not decisive on their own.

Features which may point towards a hotel-style C1 operation include:

• central management or reception arrangements
• hotel-style booking and guest administration
• regular housekeeping, linen or other guest services
• communal areas or facilities serving the operation as a whole
• short or transient occupation rather than residents making individual units their homes
• the building being managed and presented as a single accommodation business rather than a collection of independent dwellings

None of those is a statutory checklist and there is no rule that a particular reception desk, breakfast service, gym or communal lounge must exist. Conversely, simply adding one communal facility does not turn self-contained dwellings into a hotel. The planning judgment is made on the overall character of the use.

This is why a proposed conversion should be assessed before the rooms are laid out and marketed. Where the existing and proposed uses are materially different, planning permission may be required, and operating outside the lawful use can lead to planning enforcement.

 

 

Does an aparthotel property need to provide food?

 

There is no rigid planning checklist which says that premises must provide meals, a restaurant or any particular package of services before they can have the character of a hotel. The classification is a matter of fact and degree, assessed from the overall nature of the accommodation and the way the premises operate.

A useful example is Planning Inspectorate decision APP/G5750/C/15/3005653. The Inspector concluded that premises could reasonably be described as a hotel even though meals were not provided. He placed greater weight on the short-term accommodation for travellers, the hotel-style bedrooms, reception, services, advertising and overall look and feel of the operation. He expressly treated the conclusion as one of fact and degree.

Upholding an enforcement notice alleging unauthorised use of premises in London as a hotel, an inspector concluded on the basis of his own experience and the advertising material that a hotel use was being operated. The appellants considered that the premises were not a hotel as no meals were provided and there was no dining room, the use being more in the nature of a sui generis use. The Inspector took into account the dictionary definition of a hotel as an establishment providing accommodation and meals for travellers and tourists, agreeing that it would be unusual for there to be no provision of food at all. Nevertheless, from his own extensive experience, he considered that other factors were of greater significance in establishing the essential nature of the use.

An establishment providing short term accommodation in individual bedrooms for travellers and tourists together with a range of other related services is likely to have the essential character of a hotel even if no food is provided.

Apart from the lack of food, in all other respects the premises had the character and appearance of a hotel. The appeal premises were advertised as a hotel not only on the sign outside the property but also on the internet. The inspector concluded that, as a matter of fact and degree, the use could reasonably be described as a hotel.

There is no simple planning rule that a hotel must provide meals, nor is there a statutory minimum number of bedrooms for C1. Scale may still be relevant to the overall character of the operation, but the more important question is how the premises are actually used.

Likewise, the distinction from Use Class C3 is not determined simply by asking whether every guest has another permanent address. Duration and pattern of occupation, the degree of transience, the physical characteristics of the units and whether occupiers are making them their homes are all relevant to the fact-and-degree assessment.

 

Aparthotel, serviced apartment or short-term let?

 

The marketing label does not determine the planning use. A building described as an aparthotel may operate more like a Class C1 hotel, a group of Class C3 dwellinghouses, or a sui generis use depending on the facts.

Relevant factors can include the length and pattern of occupation, whether the units function as homes, the level of management and servicing, reception and communal facilities, housekeeping, booking arrangements and the degree of control retained by the operator. No single feature, including a kitchenette, decides the use class by itself.

 

When is planning permission needed for an aparthotel?

 

Planning permission is normally required where the proposal would involve a material change from the existing lawful use. Converting a conventional hotel to self-contained accommodation can therefore need permission if the resulting use is materially different, just as converting flats or another building to a hotel-style operation can do.

Establish the existing lawful use before relying on the name shown in a booking listing, business-rates record or old planning description. Where the existing position is uncertain, a certificate of lawfulness may be relevant.

 

What will a planning authority look at?

 

Where an application is required, issues can include the intensity of occupation, arrivals and departures, servicing, refuse, noise, amenity, access, parking and the effect on the supply of permanent housing. Local-plan policies can be particularly important in areas with strong visitor-accommodation or housing pressures.

The application should describe how the aparthotel will actually operate rather than relying on a brand label. A clear management statement, expected length of stay, staffing and servicing arrangements can help the authority understand the proposed use.

 

Planning Geek can help

Planning Geek can help establish the likely use class of an existing or proposed aparthotel and, where necessary, prepare the planning application or lawful development certificate. A change from Use Class E to C1 does not benefit from a general permitted development right, so a planning application will normally be required where a material change of use is proposed.

If you would like us to review a property or proposal, request a fee proposal or book a consultation.

 

 

 

Page Updated: 2nd September 2026

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