A Holiday House by the Sea: How CWTON Registration Differs

A holiday house by the sea: how registration differs from a city apartment

A holiday house in Łeba, Mielno, or on the Vistula Spit looks nothing like an apartment in downtown Warsaw, and while both will fall under the same CWTON system once it launches, preparing a holiday house already today raises questions a city apartment owner never has to ask.

Key takeaways

• A note on the legal state of play: the CWTON register has not launched yet, the Polish implementing act has not been passed, and registration is currently impossible - a holiday house will fall under the same obligation as a city apartment only once the system goes live
• The legal status of the land (building plot vs recreational plot) affects whether the structure can even be legally rented short-term
• Coastal and tourist municipalities more often impose local fees (local/resort tax) that a city-centre apartment never has to think about
• Concrete requirements already apply today: registering the property in the municipal record, and smoke detectors (mandatory from 30 June 2026)

CWTON: the same future obligation, a different context

A note against the online headlines: the CWTON register (Central Register of Tourist Accommodation Facilities) is not operating yet. EU Regulation 2024/1028 has applied since 20 May 2026, but the Polish implementing act has not been passed, and there simply is no system in which you could obtain a number - registration is physically impossible. When CWTON does launch (the realistic start of municipal preparations is 15 October 2026, and host registration possibly not until 2027), a holiday house rented by the night or week will fall under the same obligation as a city apartment: there will be no exemption for seasonal or recreational properties. For now, though, no CWTON number can be obtained or added to a listing.

Land status: a question a city apartment never asks

Before even getting to future CWTON registration, the owner of a holiday house should verify the legal status of the land the building stands on:

• Building plot: a residential or individual recreational building constructed under a building permit, usually without additional formal obstacles to running a short-term rental
• Recreational plot (allotment gardens, recreational land): buildings on such plots may have restrictions on the type of use permitted, including commercial activity, it's worth checking the local zoning plan and land use conditions before starting a rental business
• A house on a campsite or holiday resort site: registration obligations here can differ depending on whether the rental is managed by the resort operator or by an individual house owner

If there's any doubt about the plot's status, it's worth consulting the local municipal office before starting the rental, to avoid a situation where the activity gets challenged over a mismatch with the land's designated use.

What to do today: preparation instead of CWTON registration

Since the CWTON register doesn't exist yet, it makes sense to use this time for what actually applies to the owner of a seaside house right now:

• Register in the municipal record: a facility providing accommodation services other than hotel services (which includes a short-term rental house) must be reported to the record kept by the mayor of the relevant municipality (Articles 38-39 of the Act on tourism services). This is the only "register" that actually works for hosts today.
• Smoke detectors from 30 June 2026: premises where accommodation services are provided (including short-term rental) must have smoke detectors, and where fuel is burned, a carbon monoxide detector too. This is a hard, already-binding requirement worth sorting out before the season.
• Documentation and inspections: up-to-date chimney sweep and installation inspections are the basis of safety in a house, especially one with a fireplace or stove.

Local and resort tax: a quirk of tourist municipalities

Municipalities with a recreational character, including most coastal towns, collect a local or resort tax from people staying for tourist purposes longer than a day. The host is usually responsible for collecting this fee from guests and remitting it to the municipality according to the local council resolution, rates and rules vary between municipalities, so it's worth checking the current resolution for the specific town rather than assuming it's identical to a neighbouring one.

Seasonality and future CWTON registration

Once the CWTON system does launch, seasonal occupancy most likely won't exempt you from keeping the registration active outside the season - under the draft act the number is to be attached to the property, not to specific months. The details (including any option to mark a property as temporarily inactive) will only be known after the act is passed and the system goes live. Today there is no CWTON panel and no number to maintain - this is a matter for the future, not a current obligation.

Frequently Asked Questions (FAQ)

Will a holiday house rented only to friends of friends fall under CWTON registration?

If the rental is paid and has a recurring character, even without listings on platforms like Airbnb, it will be covered by the same obligations as standard short-term rental once the system launches. A one-off, unpaid loan to friends is a different legal situation, but regularly collecting payment qualifies the activity as short-term rental. Today, such a rental should already be reported to the municipal record.

Will I need a separate CWTON number for the house and for my city apartment, if I have both?

Under the proposed rules the number is to be attached to a specific property, so each separate accommodation property will require its own registration, regardless of both belonging to the same owner. The final rules will only be known once the act is passed - today no CWTON number can be obtained at all.

What if the municipality introduces a short-term rental ban in a certain zone?

Restriction zones for short-term rental are, for now, only a provision of the draft act - they are not in force and could realistically take effect years from now at the earliest. If introduced, they usually specify a transition period for existing properties. It's worth following council resolutions for the specific town, especially in popular coastal resorts, where local regulation is a recurring topic of public discussion.

Does the local tax apply to children too?

Exemption rules (e.g. for children under a certain age) vary between municipalities and are set out in the local resolution on the local tax, it's worth checking the exact wording of the resolution for the specific town rather than assuming a nationwide rule, since there isn't one.

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