The short answer

In cities that mostly respond to complaints, most short-term rentals are unlicensed. Audits in Kansas City, Portland and San Francisco found between 77% and 89% operating without a license or registration.

In cities that monitor listings, or that require booking sites to check registration numbers, the share is 10% or less.

What the audits found

Each city counted a little differently. Some counted listings, some counted units and one counted hosts, so the figures are better read as a range than a ranking.

City Source What was counted Not licensed
Kansas City, MO City Auditor, 2022 1,894 listed units against 204 active permits in August 2022 89%
Portland, OR City Auditor, 2018 About 22% of short-term rentals had a permit 78%
San Francisco, CA Budget and Legislative Analyst, 2016 7,046 Airbnb hosts against 1,647 registration applications (hosts, not units, so this is an upper bound) up to 77%
Philadelphia, PA City Controller, 2026 1,327 of 3,734 Airbnb listings in one month had an inactive, expired or ineligible license 36%
Toronto, ON Auditor General, 2024 Platform transaction data from 2021 to 2023 10%
Mount Pleasant, SC Cited by Philadelphia’s Controller Compliance rose from about 20% to over 95% after the town began monitoring listings under 5%
Nashville, TN Cited by Philadelphia’s Controller The city’s own estimate of permit compliance, above 95% under 5%

Kansas City: 11 in 100

In August 2022, booking sites listed 1,894 short-term rental units in Kansas City. The city had 204 active permits.

11 in 100

listed units had a permit

Between 2018 and 2022, sites listed 4,175 residences in the city, and the city issued 296 permits over the same period. The auditor concluded that almost the entire short-term rental market was operating outside the city’s permit program, and that the city had no way to see where those rentals were.

Philadelphia: about 1 in 3

Philadelphia’s City Controller compared one month of Airbnb listings with the city’s license records. Of 3,734 listings, 1,327 had a license that was inactive, expired or the wrong type.

Some listings showed a license number that belonged to something else entirely, including a dumpster license and a towing company license. A license number on a listing only means something once someone checks it against the city’s records.

The Controller noted that the city relies on reports from booking platforms and on complaints, with limited staff to find violations, and recommended monitoring tools like those used in Nashville and Mount Pleasant.

Mount Pleasant: from 20% to over 95%

Mount Pleasant, South Carolina had about 20% of its short-term rentals in compliance. After the town started monitoring listings, compliance rose to over 95%. Nashville, which also monitors listings, estimates its compliance at over 95%.

What it costs in registration fees

Multiplying the number of unlicensed rentals each audit found by the city’s current registration fee gives a floor for what goes uncollected each year.

City Unlicensed Annual fee Missed each year
Kansas City, MO 1,690 units $200 $338,000
Philadelphia, PA 1,327 listings $150 $199,000

Unlicensed counts are from each audit (Kansas City in August 2022, Philadelphia for one month in 2026), priced at each city’s current fee. Philadelphia counted listings, so a home listed twice is counted twice. San Francisco and Portland are left out because their audits don’t give a recent count of unlicensed units.

These figures cover registration fees only. They leave out lodging taxes, which are usually far larger, and fines.

What a city can fine

Every one of these cities can fine an operator who runs a rental without a license, and in most of them each day counts as a separate violation.

City Registration fee Fine for operating without one
Kansas City, MO $200 a year $200 to $1,000 per violation, and each day can count as a separate violation
Philadelphia, PA $150 a year Up to $300 per offense, and each day counts as a separate offense
San Francisco, CA $925 every two years At least $484 per unit per day from the notice of violation, rising to $1,452 for repeat violations
Portland, OR $504 every two years Citations of several hundred dollars or more, with first-time fines capped at $27,513 since May 2025

A fine is what a city can charge, which is different from what it collects. To fine an operator, the city first has to know which property a listing is. Portland’s ombudsman reported in 2026 that the city delists 25 to 40 listings a month for invalid permit numbers, but can’t cite them, because the data it buys doesn’t include addresses.

What this means for cities

  • Without monitoring, most short-term rentals in a city are likely to be unlicensed. Several audits found three in four or more.
  • Monitoring works. Mount Pleasant went from about 20% compliance to over 95%, and Nashville estimates it is above 95%.
  • Enforcement starts with an address. Until a city can match a listing to a property, it can’t send a notice, check a license or issue a fine.

Sources