Zanzibar Holiday Lets: The Licence an Owner Needs

What licence does an owner need to let a house by the night in Zanzibar?#

A house let to tourists in Zanzibar needs registration with the Zanzibar Commission for Tourism, and the rent is exposed to the Hotel Levy at 15% of rental value. The first rests on regulations announced on 4 July 2024 under section 31(1) of the Zanzibar Tourism Act No. 6 of 2009 (The Citizen, 6 July 2024, press-reported). The second is stated by the Zanzibar Revenue Authority (ZRA) on its Hotel Levy page, which reflects the Hotel Levy Act No. 1 of 1995 as revised in 2025 (ZRA, official summary).

The instrument is narrow and has a name. A non-hotel tourist accommodation is, in the reporting, a private residence used to lodge tourists outside a hotel licence. Registration is the Commission's entry of the provider on its books, followed by an inspection and, if the premises pass, a licence. The formal title of the regulations and their gazette reference were not located for this article. Every statement about the registration half is therefore press-reported, and is graded directional throughout.

The question has two halves, and they sit in different offices. Registration and licence belong to the Commission. The levy belongs to the revenue authority. The principal should keep them apart. One is a permission. The other is a running cost. A permission can be refused or revoked. A cost recurs for as long as the house is let.

This piece explains how the rules read. It does not say what any house will earn. No yield is stated or implied, and nothing here is personal advice. The sources run from 2023 to 2026, and a rule can change. As of 16 October 2026, the text of the 2024 regulations remains unlocated by this review, so the principal should ask the Commission for the current instrument before relying on any figure below.

What do the 2024 non-hotel accommodation regulations say?#

The regulations were announced at a stakeholders' meeting on 4 July 2024. The Ministry of Tourism and Heritage and the Zanzibar Commission for Tourism presented them, and the minister said they apply to “both locals and the diaspora” (The Citizen, 6 July 2024, press-reported). The legal basis reported is section 31(1) of the Zanzibar Tourism Act No. 6 of 2009, which empowers the minister to make regulations.

The trigger was the spread of ad hoc letting in private homes. The same article ties the rules to a rise in tourist stays in private residences and quotes the Commission's executive secretary saying that some tourists prefer independent accommodation. That they wrote these suggests the volume had become visible to them (directional reading, not a measured count).

The mechanism has four reported steps. The provider registers with the Commission. The Commission inspects the premises against business standards. A licence follows if the premises pass. The licence may be revoked if it was obtained fraudulently, used for activities the regulations prohibit, or held in breach of its terms and conditions. The article does not describe the application form, the inspection criteria or any appeal route.

Four outlets repeating one announcement are one source. Mwananchi (6 July 2024), ATTA (8 July 2024) and Travel News (31 July 2024) carried the same registration fees and the same framing. That corroborates the announcement, not the text. The Guardian (Tanzania) report of 4 July 2024 could not be reopened for this review, and nothing in it is relied on. The principal should read the whole set as a single, widely circulated, press-reported datum.

Licence validity is a separate and older rule. In July 2023 the Commission announced that tourism business licences run for 12 months from the date of issue, with renewal on the original issue date (Mwananchi, 16 July 2023, press-reported). Whether that rule carries over to the 2024 non-hotel licence is not stated in the sources found, so it is treated here as unestablished.

Which parts of Zanzibar are approved for a non-hotel let?#

Only some areas are approved, and the list reported is short. In Mjini Magharibi Region the approved areas are Stone Town, Mlandege, Fumba, Bububu, Chukwani and Mbweni (The Citizen, 6 July 2024, press-reported). The article gives no approved areas for the other regions. A house outside a listed area is not covered by that list.

The north and east coasts do not appear in the sources found. Nungwi, Kendwa, Paje and Jambiani sit outside Mjini Magharibi, and no article reviewed says whether they are approved. Absence from a press summary is not a prohibition. It is, however, a gap the principal cannot underwrite around. The status of a specific plot is a question for the Commission, in writing.

The fee schedule hints that other regions are contemplated. The registration fee is set for “other regions” as well as for Mjini Magharibi (see the next section). A fee for a category with no approved location would be odd. This is an inference, graded directional, and it does not substitute for an approved-area schedule.

A list of areas in a news article is a summary, not a legal text. The regulations may define approved areas by reference to zoning, to a schedule or to a ministerial order. The article does not say. Zoning is a separate layer from registration, and it can change without any change to the fee.

The practical test is documentary. The principal should hold the Commission's written confirmation, dated, that the specific plot sits in an approved area before treating any listing income as underwritable. If that document cannot be obtained, the line in the model is zero, not an estimate. The same logic applies after any resale, because a registration attaches to a provider and a premises, and the sources do not say whether it transfers.

How much does registration cost, and what does inspection check?#

The reported registration fee is TZS 150,000 in Mjini Magharibi and TZS 250,000 in other regions. The figures come from the Commission's announcement as reported by The Citizen on 6 July 2024 and repeated by other outlets (press-reported). The fee schedule in the regulations themselves was not located.

The fee is small beside the levy. As illustrative arithmetic only, not a market rate, a house producing TZS 10,000,000 of rental value in a year would owe TZS 1,500,000 of Hotel Levy at 15%. That is ten times the 150,000 fee, and it recurs every year the house is let. The registration fee is a threshold cost. The levy is the operating cost.

Inspection is reported as a check against business standards. The Citizen says the Commission will inspect accommodations to confirm they meet those standards before a licence issues. It does not publish the standards. The principal should ask the Commission for the inspection standards in writing before fitting out a house.

Renewal and reinspection are not reported. The sources do not say whether the fee is paid once or yearly, or whether a second inspection follows a change of owner or manager. Given the 12-month rule for tourism licences generally, annual renewal is plausible. Plausible is not established, and the model should carry the fee as annual until the Commission says otherwise.

The fee is the least of the compliance questions. Time, access to the Commission and the sequencing of inspection against the high season are costs the sources do not price. They are real, and none of them has a measured value in the material reviewed.

Can a foreigner run a holiday let in Zanzibar on their own account?#

No legal text found for this article settles whether a foreigner may run a non-hotel let personally. The minister said the 2024 rules apply to “both locals and the diaspora” (The Citizen, 6 July 2024, press-reported). None of the sources reviewed mentions non-resident foreigners as a class. The honest answer is that it was searched for in a text and not found.

There is a reservation list that may touch the question. The Citizen reported on 10 January 2026 that the Tourism Act No. 6 of 2009 reserves tour companies and tour guiding for Zanzibaris (press-reported). No page opened for this review lists guest houses or let houses as reserved, so whether a let house falls in a reserved category is not established.

A press report on the Zanzibar Investment Promotion Authority (ZIPA) and BnBs could not be reopened. A Citizen article headlined “ZIPA warns of illicit foreign land acquisition, unregulated BnBs” exists, but its text could not be read for this review and its date was not confirmed, so nothing in it is relied on here. How a BnB relates to the investment certificate route is therefore not established.

Enforcement against proxies is documented. On 10 January 2026 the Commission issued a notice that locals were being used to front tourism businesses owned by foreigners who do not meet investment requirements, called the practice unlawful, and gave until 20 January 2026 for voluntary disclosure before a special inspection (The Citizen, press-reported). The reserved activities named in that notice were tour companies and tour guiding, which the article says the Tourism Act reserves for Zanzibaris.

The lesson for a foreign owner is structural, not tactical. A nominee arrangement is the pattern the Commission has called unlawful. The principal should assume that who holds the registration matters, that the answer sits in the Tourism Act and the 2024 regulations, and that a lawyer admitted in Zanzibar must read those texts. Practitioner guides are not a substitute where the law is silent.

How does the Zanzibar Hotel Levy treat a house let to tourists?#

The Hotel Levy charges 15% of rental value on residential houses rented for tourism. The ZRA summary lists the category as residential houses rented for tourism, including online platforms such as Airbnb, with the base “rental value” (ZRA, Hotel Levy page, official summary). Hotels, guesthouses, restaurants, tourist vessels and tour operations are listed at 12% on the “chargeable value of services”.

*The Hotel Levy is a Zanzibar levy under the Hotel Levy Act No. 1 of 1995.* ZRA publishes a consolidated version incorporating amendments up to June 2025 (ZRA, Hotel Levy Act consolidated 2025). The 15% line is the part relevant to an owner. This review read the ZRA summary page. It did not obtain the text of section 3 of the Act, so the summary is the authority cited and the Act is the document to check.

The base is different, and that matters. For a hotel the base is the chargeable value of services. For a house it is the rental value. A hotel's rate is 12% and a house's is 15%, a gap of three percentage points (arithmetic on the ZRA table). Whether “rental value” means gross booking value, a figure net of platform fees, or an assessed figure is not defined on the page.

The page is silent on who bears the levy in the guest's bill. It does not say whether the owner may show it as a separate line on the invoice. The principal should model it as borne by the owner until the point is confirmed. Filing frequency and deadlines were not found on the page either.

The rate sits in a table with other categories, which is itself informative. The authority has chosen to name houses let to tourists as their own line, separate from hotels. That is a statement of intent to collect from this category. It is a reading of the table's structure, graded directional, and it is not a statement about enforcement intensity.

Does the Hotel Levy reach Airbnb and other platform bookings?#

The ZRA table names online platforms in the 15% category, using Airbnb as the example. That is the extent of the text found. It places platform-booked houses inside the levy's scope, so a listing on a platform is not an escape from the levy on the face of the table. It does not describe how the levy is collected on a platform booking (ZRA, Hotel Levy page, official summary).

Who remits is the open question. Tax systems generally use one of three models. The owner files, the platform withholds, or both do. The sources found do not say which applies in Zanzibar. The principal should not assume a platform deducts anything, and should not assume it does not. Neither assumption is safe.

A separate hotel charge shows how charges can stack. The 2023-24 budget replaced a flat $1 levy with rates graded by star rating (The Citizen, 19 June 2023, directional, press-reported). The charge is the infrastructure tax in section 20(3) of the Finance (Public Revenue Management) Act No. 9 of 2015. In the ZRA's 2025 compilation, the rates are $5 per person per day for guests of four- and five-star hotels, $4 for two- and three-star hotels, $2 for one-star hotels and others, and $10 for a hotel on a small island or a room under water (measured, statute text). The text is written for guests staying in hotels, and its lowest band reads “1 Star hotel and others”. Whether any equivalent reaches a registered house was not established, and the principal should obtain a written answer from ZRA and the Commission before assuming it does not.

VAT and income tax were not researched for this article. ZRA administers a Value Added Tax Act No. 4 of 1998, consolidated to June 2025, but how it applies to a short let was not read. Income tax on rental profit was likewise not researched. These are known unknowns, and the net figure of any let cannot be built without them.

Records are the control. Whatever the collection model, the owner is the party the Commission and ZRA can find. Booking records, payout statements and guest registers are the evidence of rental value. The principal who keeps them from the first booking has a defensible base. One who reconstructs them later has an estimate.

What are the penalties for an unregistered let in Zanzibar?#

The reported penalty is a fine of not less than $1,000 and up to $5,000, or imprisonment of three months to five years. The Citizen puts these at about TZS 2.6 million and TZS 13.2 million (The Citizen, 6 July 2024, press-reported). ATTA gives only the $5,000 ceiling, and the regulations' text was not located, so the amounts are the Citizen's figures, not a reading of the instrument.

The licence itself is also at risk. Revocation is reported for fraud, for prohibited activities and for breach of terms. A revoked licence ends the lawful basis for letting and, in practice, for platform listings that depend on it. The second half of that sentence is inference.

Enforcement posture in 2026 is active in adjacent areas. The Commission's January 2026 notice threatened immediate closure and legal action for proxy-registered businesses (The Citizen, press-reported), and on 22 August 2026 The Citizen reported the arrest of three foreign nationals over tour and excursion operations reserved to Zanzibaris. Neither concerns non-hotel lets directly. Both show a regulator willing to act on ownership and licensing.

The pattern is a signal, not a forecast. Enforcement in tour operations does not predict enforcement on houses. The principal should read it as evidence that the Commission checks who owns what, which is the point where a foreign owner's structure would be tested.

The downside is asymmetric. The registration fee is small. The penalty band spans a fine measured in thousands of dollars to custodial terms. For an allocator that asymmetry is a matter of sequencing, registration before listing, and it is stated here as a reading of the penalties, not as advice.

What does the net cost stack of a Zanzibar holiday let look like?#

The cost stack has at least seven layers, and only two have a source here. Registration (TZS 150,000 or 250,000, press-reported) and the Hotel Levy (15% of rental value, official summary) are sourced. Licence renewal, VAT, income tax, platform fees and management are not priced in the material reviewed. A net figure built on two layers is not a net figure.

The levy bites on revenue, not profit. Because the base is rental value, the 15% applies before any cost is deducted. A house with thin margins carries the same levy as one with fat margins. That is the structural reason gross headlines overstate what reaches the owner. Victaura's earlier work on gross headline and net residue in resort rentals sets out the general method.

Illustrative arithmetic shows the direction. Take TZS 10,000,000 of annual rental value, a round number chosen for the sum and not a market figure. The levy at 15% is TZS 1,500,000, and a first-year registration at TZS 250,000 is a further 2.5%. Together they take 17.5% of that revenue before VAT, tax, platform fees or operating cost. This is a calculation, not an expectation.

Costs outside the regulatory stack still land on the owner. Utilities, maintenance, insurance and management are real inputs on an island, and none is priced here. The principal should keep regulatory costs and operating costs in separate lines, because the first set is fixed by authorities and the second by the market.

Occupancy is the variable no source here measures. No occupancy, rate or yield figure is used in this article, because this review did not research them. The omission is deliberate. A number without a source would be worse than a gap.

How does a holiday let sit beside title and the Investment Act in Zanzibar?#

Letting rights follow from what the owner can lawfully hold. The question of what a foreigner can own on the island is separate and is covered in Victaura's note on what a foreigner can own in Zanzibar. Registration for letting does not create title, and title does not create a licence. Each has its own authority.

The investment statute cited in 2026 reporting is the Zanzibar Investment Act of 2023 (The Citizen, 10 January 2026, press-reported). The document reachable for this review was the bill gazetted on 23 August 2023, published on the site of the Zanzibar House of Representatives, which proposed to repeal the Zanzibar Investment Promotion and Protection Authority Act No. 14 of 2018 and enact the new Act. The enacted text should be reopened before reliance.

The investment route to land is not settled here. The Citizen article on ZIPA, land and BnBs could not be reopened for this review, so its reported statements on investment certificates and land leases are not relied on. Whether a foreign-owned house and a foreign-owned let route through different offices is an open question for a lawyer admitted in Zanzibar.

Victaura's Zanzibar project is in active development. The public page for Secret Zanzibar Hotel & Villas is the reference. This article does not say whether any project will be let, and it adds nothing to that page.

Where the Act and the regulations meet is where the work is. Registration, reservation, investment certificate and title are four separate permissions touching one house. A principal underwriting a Zanzibar let should list all four and tick each against a document, not against an agent's summary.

What this article does not establish, honestly disclosed#

The text of the 2024 regulations was not located. Every registration detail rests on The Citizen of 6 July 2024 and on outlets repeating the same announcement. Fees, areas, penalties and the section 31(1) basis are press-reported. Public sources were searched for the gazetted instrument and did not return it.

The Tourism Act text was not reopened. No page opened for this review reports guest houses as reserved, and the Act itself was not read. The Zanzibar Investment Act 2023 was reached as a bill, and section 3 of the Hotel Levy Act was not read. The ZRA summary page was.

Whether a foreigner may run a non-hotel let personally was searched for and not found. This article therefore states no rule on it. The press report on ZIPA and BnBs could not be reopened and is not relied on. The notice dated 10 January 2026 names tour companies and tour guiding, but its closure warning covers any tourism business registered through a local proxy.

Not researched at all. VAT on short lets, income tax on rental profit, the collection model for platform bookings, occupancy, daily rates and yields. No figure on any of them appears here. Practitioner and agency guides were not used for any rule.

Status is dated. As of 16 October 2026 this review did not establish whether any rules on non-hotel lets beyond the 2024 announcement have been issued. A rule reported in 2024 may have been amended since.

Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), develops projects on Lake Como (Italy), in Nungwi, Zanzibar (Tanzania), on Gili Air and in Uluwatu, Bali (Indonesia), and holds an off-plan capital position on Al Marjan Island, Ras Al Khaimah (UAE). Readers should assume commentary may be influenced by, or benefit, these positions. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.