5	Licensing the operating platform and keeping two registries, the first for those listed with a provider and would pay a small fee for administration of the register. The other for those who don’t operate through a provider who pay a full licence fee with normal inspections.		Moderate
6	Licensing only the platform providers at full licensing rates to cover all normal inspections		High
7	Licencing the operating platform as well as the platform providers at full licencing rates to cover all normal inspections.		High
8	Changes to the B&B Schedule of the Licensing bylaw to add a new schedule for Short Term Rentals (current cost is $616 with $191 annual renewal fee).	STRs would be regulated like traditional B&Bs (changes may be required to B&B regulations to harmonize requirements)	High

Licensing Challenges

Most STR platforms operate as foreign entities within Canada which may pose a concern regarding the ease of licensing the platform itself. It is difficult to enforce municipal regulations on companies of this type and outright refusals to comply may become an issue. The enforcement and methods of recourse in these situations are difficult at best and this factor must be considered in implementing any regulatory regime. In some cases, as in the regulation of Transportation Sharing Networks (such as UBER), agreeable terms can be negotiated and platform compliance can be obtained. Some STR companies, such as airbnb, have made a commitment to work with municipalities in order to create a fair and balanced licensing regime. This is not however guaranteed and thus is an important consideration to bear in mind in any decision.

In regards to inspection requirements as a part of the licensing process, the Business Licensing By-law allows the City to inspect any licensed (or intended to be licensed) premises to carry out the functions of the Licence Commissioner, at any reasonable time. With that being said, there is the possibility that inspections could be refused by the licensee or homeowner. These types of refusals could present difficulty in ensuring compliance with any licensing regulations for operators with existing licenses. It would also result in difficulty entering a home to determine if a licence is required - in cases of homeowners operating a STR without a licence. Right of entry challenges are difficult to navigate as they are legally and constitutionally supported. In cases of those who are