Great analysis – you have spotted a winning blindside play by the Fireys which will change the financial viability of short-term rentals (for those not into rugby union or rugby league, a blindside play is where the ball is passed unexpectedly to the short side of the field (the side with fewer players) instead of to the other side with more players where it was expected, often resulting in try to the attacking team because of the element of surprise).
The Fireys do not enforce fire regulations, it is Local Councils which do. For example, the Sydney City Council which has for some years insisted on fire exit signs, a fire extinguisher and a fire blanket, annual certification and an evacuation plan in serviced apartments. Now, the Fireys have added hard-wired smoke detectors to this list and the NSW Government have extended the fire requirements to short-term rental accommodation. This will be expensive for providers of short-term rentals because it is they, not the owners corporation, who will bear the cost of this fire compliance within their apartment / townhouse.
Which brings me to the register. The appropriate body to maintain the short-term rental providers register is surely the local council – after all, they are the planning authority who can check if the use is permissible, and they are the responsible authority for fire compliance. Of course, they need to be paid for this, and so an annual fee of $250 (as in other cities) would be appropriate.
Leave the Code of Conduct to Fair Trading, whose idea it was and who have more expertise than the Local Council in conduct matters.
I’ll be making a submission along these lines to the NSW Government and encourage other Flat Chat readers to do so!