The Complete Guide

How to Get a Memphis Short-Term Rental Permit: The 2026 Guide

Everything you need to legally operate an Airbnb or VRBO in Memphis and Shelby County. Written by operators who run Memphis short-term rentals every day.

Ordinance Chapter 5-44 / No. 5631
Effective July 1, 2023
Apply Through Accela Citizen Access Portal
Term 365 days, non-transferable

The 30-Second Version

Initial Fee
$300
Non-refundable application fee under the 2023 amended ordinance
Annual Renewal
$150
Due at least 30 days before expiration
Required Insurance
$1,000,000
Per-occurrence liability minimum
Max Bedrooms
3
Sleeping rooms per permit, per property
Combined Tax Rate
18.75%
7% state + 2.75% local sales + 4% Memphis + 5% Shelby
Typical Timeline
2 to 3 weeks
From submission to approval if inspection passes first time
The 5-stage path to a legal Memphis STR
1
Verify Zoning
2
Bind Insurance
3
Pass Inspection
4
Submit via Accela
5
Register & List

Who needs a Memphis STR permit

If you rent a residential property to transient guests for less than 30 consecutive days inside Memphis or unincorporated Shelby County, you need a permit. Full stop. This applies regardless of platform (Airbnb, VRBO, Booking.com, direct bookings), regardless of ownership structure (individual, LLC, trust), and regardless of whether you occupy the property yourself.

The city ordinance defines a short-term rental as a residential dwelling unit, a portion of a dwelling unit, or a detached accessory dwelling unit containing not more than three sleeping rooms that is rented for transient occupancy of less than 30 continuous days.

What is not considered a short-term rental

  • Hotels, motels, and bed-and-breakfast establishments (governed separately)
  • Boarding houses
  • Campgrounds
  • State-licensed health care facilities and temporary family healthcare structures
  • Properties owned by federal, state, or local government agencies
  • Rentals to the same occupant for 30 or more consecutive days (including month-to-month leases)

LLC ownership is allowed

Memphis permits STR ownership by LLC. This is important because Nashville restricts non-owner-occupied STRs through a permit cap, while Memphis does not. The permit is still issued to a specific property address and a specific responsible ownership entity, so transfers require a new permit. This is one of several reasons Memphis consistently outperforms Nashville for out-of-state STR investors.

The grandfathering rule

Memphis and Shelby County's updated STR framework took effect July 1, 2023. Properties operating as STRs before that date received grandfathered protection from the new permit requirements. That protection is real, but narrow, and conditional.

Grandfathering ends automatically when any of these occurs

  • The property is sold or transferred to a new owner
  • The property ceases operation as an STR for 30 continuous months or longer
  • The property receives three or more violations of local law related to STR operation, noise, disorderly conduct, overcrowding, or similar

Do not assume grandfathered status covers a new purchase

When you buy a grandfathered STR, the grandfathered status does not transfer. You are required to apply for a permit under current rules before re-listing. This is one of the most common traps for new investors acquiring an operating STR from a previous owner.

The complete requirements checklist

Use this as your pre-application punch list. Every item below is pulled from the Shelby County STR application and the operational provisions of Chapter 5-44 / Ordinance 5631.

Documentation you must submit

  • Completed Short Term Rental Property Permit Application signed under oath by the property owner
  • Site plan drawn to scale showing each unit, all other structures on the parcel, and key site features (driveways, parking, access points)
  • Proof of current property ownership(deed, title, or recent property tax statement in the owner's name)
  • Proof of insurance evidencing homeowner's fire, hazard, and liability coverage of not less than $1,000,000 per occurrence
  • Confirmation of final inspection by Memphis/Shelby County Code Enforcement (the Clerk's Office will verify this on file)
  • Responsible Party designation with a current address within 50 miles of the rental property and a 24/7 phone number
  • Property tax certification confirming the owner is current on all taxes for this property and every other Shelby County property owned

Certifications you must sign

  • The STR will not interfere with the quiet enjoyment rights of neighboring properties
  • You have received and understand the Shelby County Short Term Rental Ordinance
  • No citations have been issued on the property by law enforcement or regulatory agencies in the prior 12 months
  • The property complies with all applicable County Technical Codes
  • You have not had a similar permit denied, suspended, or revoked by any city or state agency in the 365 days preceding this application
  • You have no unpaid court fines or court costs related to STR ordinance violations
  • You will comply with all Room Occupancy Tax requirements

The step-by-step application process

Every day you are not permitted is a day you cannot legally list. This is the fastest-to-approval sequence, run in parallel wherever possible.

1

Verify zoning eligibility before anything else

Call the Memphis Planning Department at (901) 576-6619 or the Shelby County Division of Planning and Development at (901) 576-7197 with the exact property address. Confirm the property's zoning designation and confirm that STR use is permitted in that district under the current Unified Development Code. Skipping this step and finding out later that your property is in an ineligible district is a six-figure mistake.

2

Bind your liability insurance policy

Work with a broker who understands short-term rental exposure, not a standard homeowner's carrier. The policy must show at least $1,000,000 per-occurrence liability coverage plus fire and hazard coverage. Primary residence homeowner's policies rarely cover STR activity, and carriers frequently deny claims on unpermitted commercial use. A dedicated STR policy (sometimes called a landlord/commercial dwelling or hospitality rider) is what you actually need.

3

Schedule and pass the code enforcement inspection

Contact Memphis/Shelby County Code Enforcement to schedule the final inspection. The inspector is verifying life safety: smoke alarms, carbon monoxide detectors, fire extinguisher, egress, and no outstanding code violations. If you fail, you correct and re-inspect. Build in two to three weeks of buffer here for a first-time property.

4

Prepare the site plan

It does not need to be architect-drawn. A hand-drawn, to-scale sketch showing the dwelling footprint, other structures, driveway, parking, and property lines is acceptable. Include the street name and address clearly on the drawing.

5

Designate your Responsible Party

Pick a person (owner, co-host, property manager) who lives within 50 miles of the property, is 21 or older, and can answer a phone 24 hours a day. They must be able to be physically present at the property within two hours of a notification from the City or County regarding an issue. Their name and phone number will also need to be conspicuously posted inside the rental.

6

Pull your Shelby County business license

Contact the Shelby County Clerk's Office to register for a combined City of Memphis and Shelby County business license ($15 each, $30 total for properties within Memphis city limits). This is separate from the STR permit and is a prerequisite for operating a commercial activity in the County.

7

Submit the STR Permit application through the Accela Citizen Access portal

Memphis and Shelby County STR permit applications are filed online through the Accela Citizen Access portal at aca-prod.accela.com/SHELBYCO. Create an account, select the Short-Term Rental permit type, complete the application (all certifications initialed, signed under oath), upload your site plan, proof of ownership, and proof of insurance, and pay the $300 non-refundable application fee. This is the same portal the City and County use for all building permits, so if you have done any permitted work on the property, you may already have an Accela account.

8

Register for state and local tax accounts

Register with the Tennessee Department of Revenue via the Tennessee Taxpayer Access Point (TNTAP) for state sales tax. Register with the Shelby County Trustee's Office for the county room occupancy tax. Register with the City of Memphis for the 4% Memphis hotel/motel tax. Do this before your first booking posts.

9

Install and verify all safety equipment

Five-pound ABC-rated fire extinguisher in each unit. UL 217-certified smoke alarms in every sleeping area and along every egress path. Carbon monoxide detectors on every habitable floor. Laminated responsible party contact and house rules posted in a visible interior location.

10

Add your permit number to every advertisement

Once issued, your STR permit number must appear on any advertisement or listing for the property. This is not optional. Failure to display the permit number on a listing is itself a violation.

Memphis STR permit fees and total startup cost

The permit itself is cheap. The actual out-of-pocket to get to your first guest is not. Here is a realistic all-in breakdown for a typical Memphis non-owner-occupied STR.

Shelby County / Memphis STR Permit (initial) $300
City of Memphis business license $15
Shelby County business license $15
Code enforcement inspection Varies
Re-inspection, if needed $100 to $250
Annual STR permit renewal $150
Hard permit costs, year one ~$480

These are hard government costs only. They exclude your insurance premium (typically $1,500 to $3,500 annually for a Memphis STR depending on property value and coverage), safety equipment ($150 to $400 for alarms and extinguishers), signage, and the software stack most operators run. Run your own numbers with our Memphis rental investment calculator.

Memphis STR safety requirements and property standards

These are the non-negotiable life safety items. Inspectors will look for all of them. Missing any single one is grounds for a failed inspection, and a failed inspection is grounds for permit denial.

Required safety equipment

Item Specification Where it goes
Fire extinguisher Minimum 5-pound, rated for Class A, B, and C fires One per rental unit, in a visible and accessible location (kitchen or central hall are standard)
Smoke alarms UL 217-certified Every sleeping area, every room along the egress path from sleeping area to exterior door, and every habitable floor
Carbon monoxide detectors Meeting applicable Tennessee state law standards Every habitable floor
Responsible party posting Conspicuous, readable, laminated is best Interior wall in the main living area

Property condition requirements

  • No outstanding or unresolved violations of building, zoning, health, or fire safety codes
  • Compliance with the County's Technical Codes
  • Compliance with Memphis City Code §22-1 (noise control) and Ordinance 4840 (garbage collection and disposal)
  • The minimum property conditions set forth in Ordinance 4232

Food and beverage prohibition

The ordinance prohibits STR operators from providing food or beverage service to guests as part of the rental. The only exception is packaged, sealed, non-perishable items. No home-prepared breakfasts, no coffee service beyond sealed pods, no fruit baskets with unwrapped items. If you want to operate as a bed-and-breakfast, that is a separate license class with a separate regulatory framework (including health department inspection).

The Responsible Party role

The Responsible Party (sometimes called the Short-Term Rental Agent or Local Contact) is the single most operationally demanding requirement in the ordinance. Misunderstanding this role causes more permit issues than anything else.

Who qualifies

  • A natural person, not a company or LLC
  • At least 21 years of age
  • Resides at an address within 50 miles of the rental property
  • Designated in writing on the permit application

What the Responsible Party must do

  • Answer calls 24 hours a day for the full duration of every short-term rental stay
  • Be physically present at the rental property within two hours of notification from the City or County regarding any issue, complaint, or alleged violation
  • Accept service of any notice of violation related to the property's use or occupancy
  • Use best efforts to prevent disturbances to neighbors including noise, disorderly conduct, overcrowding, alcohol, or illegal drug use by guests
  • Ensure compliance with all noise, garbage, and applicable code provisions

This is where a local property manager earns the fee

If you are an out-of-market owner, the Responsible Party requirement is the single biggest reason to hire a professional. LPS serves as the designated Responsible Party for Memphis STR owners across the city. We answer the phone, we show up, we handle the neighbor call at 1 a.m. before it becomes a code enforcement complaint. Talk to us about adding your property , learn about our full-service STR management , or see how a Memphis STR performs under management.

Memphis STR insurance requirements in detail

The $1,000,000 liability number is a floor, not a target. Here is what the ordinance actually requires and what sophisticated operators carry.

Ordinance minimum

  • Homeowner's fire insurance
  • Hazard insurance
  • Liability insurance of not less than $1,000,000 per occurrence

Tennessee Short-Term Rental Unit Act minimum

Tennessee's state-level STR law (TCA 13-7-603) requires STR operators to maintain liability insurance of at least $500,000 unless the listing marketplace provides equivalent coverage in aggregate. Shelby County's $1,000,000 requirement is the higher bar, so that is the number you need to hit.

What standard homeowner's policies usually exclude

  • Commercial activity on the insured premises
  • Liability from guests injured on the property during a paid stay
  • Property damage caused by paying guests
  • Loss of rental income from covered events

Dedicated STR or hospitality-grade policies from carriers like Proper Insurance, Steadily, CBIZ, and several specialty lines from Lloyd's and Markel address these gaps. We cover the full insurance picture in our Memphis landlord insurance guide. The underwriting question that matters most is whether the carrier treats your property as a commercial dwelling (they will ask nightly rate, max occupancy, annual revenue, and platform). Do not patch a homeowner's policy with an STR endorsement unless the carrier explicitly endorses the commercial use in writing.

AirCover and Vrbo Liability Insurance are not a substitute

Airbnb's AirCover for Hosts and Vrbo's Liability Insurance provide secondary protection, and they only apply to bookings made through those platforms. They do not satisfy the Shelby County proof-of-insurance requirement, they do not cover direct bookings, and relying on them as your only coverage is a coverage gap that ends careers.

Not sure your property is a fit for STR?

We pre-screen zoning, HOA rules, and revenue potential before you close. See why Memphis is a strong STR market and our case study on a managed Memphis STR.

Get a free pre-screen

Memphis STR zoning and the Unified Development Code

Memphis takes a relatively permissive approach to STR zoning compared to Nashville or Chattanooga. STR use is allowed in most residential and commercial districts so long as the property meets the permit requirements. That said, "most" is not "all," and the zoning check is the single most important due-diligence step before you close on a property intended for STR use.

Key zoning facts

  • The Unified Development Code (UDC) serves as the zoning code for both the City of Memphis and unincorporated Shelby County
  • Residential Districts: generally permitted with a proper STR permit
  • Commercial Districts: generally permitted with a proper STR permit
  • Properties rezoned from residential to commercial must wait 18 months before applying for an STR permit
  • Overlay districts (including historic overlays with an "H" suffix) may impose additional restrictions

How to verify your address

  1. Pull the property address on the Shelby County Zoning Atlas (publicly accessible)
  2. Call the Memphis Planning Department at (901) 576-6619 with the address and the question "Is this parcel zoned for short-term rental use under the current UDC?"
  3. For unincorporated Shelby County properties, call the Shelby County Division of Planning and Development at (901) 576-7197
  4. Get the answer in writing (email is fine) before signing any purchase contract

If the property is not STR-eligible in its current zoning, check whether it is a fit for long-term rental management. Same asset, different operating model, and the LTR inventory in Memphis has been strong across most neighborhoods.

Memphis STR business license and tax account registration

The STR permit alone does not make you legal. You also need the business licensing infrastructure behind it and a clear picture of which tax accounts you actually need to register for yourself.

If you're only using Airbnb and Vrbo, your tax registration workload drops dramatically

Tennessee designated short-term rental marketplaces as tax collectors in 2021. Airbnb and Vrbo (the vacation rental arm of Expedia Group) both operate as registered marketplace facilitators, which means they collect and remit the full stack of lodging taxes on your Memphis bookings: the 7% Tennessee state sales tax, the 2.75% Shelby County local option sales tax, the 4% Memphis hotel-motel tax, and the 5% Shelby County hotel-motel tax. In practice, Memphis operators who list exclusively through these two platforms do not need to register for and actively manage their own lodging tax accounts; the platforms handle the collection and the filings on those bookings.

The moment you add any other booking channel(your own website, a Furnished Finder listing, a Booking.com listing, a smaller platform, or a corporate stay inquiry that converts outside a platform), you become responsible for collecting and remitting every layer yourself, which means registering with each taxing authority first. See the platform-by-platform breakdown below for the full picture.

What you need regardless

Two registrations apply to effectively every Memphis STR operator, whether you use platforms or not.

  • City of Memphis Business License($15 fee) through the Shelby County Clerk's Office. Required to conduct business within Memphis city limits.
  • Shelby County Business License($15 fee). Required for any commercial activity in Shelby County.

What you need only if you take direct bookings

Registration Where What it covers
Tennessee Sales Tax Account TN Department of Revenue (TNTAP portal) State sales tax (7%) and local sales tax (2.75%)
Shelby County Room Occupancy Tax Shelby County Clerk's Office, (901) 222-3059 5% county hotel-motel tax on transient occupancy
City of Memphis Hotel-Motel Tax City of Memphis Treasury / Finance 4% Memphis city hotel-motel tax
Tennessee Business Tax TN Department of Revenue Required if gross receipts exceed $10,000 in a county or city jurisdiction

Memphis STR taxes: what you owe and who collects it

This is the section that costs the most operators money. Memphis has one of the highest combined lodging tax rates in the country, and the marketplace-facilitator rules mean different taxes are collected by different parties in different ways. Here is the full picture.

The four stacked tax components on every Memphis STR booking

Tennessee state sales tax 7.00%
Shelby County local option sales tax 2.75%
City of Memphis hotel-motel tax 4.00%
Shelby County hotel-motel tax 5.00%
Combined lodging tax rate 18.75%

Who collects what

Tennessee is a marketplace facilitator state. Under TCA 67-4-1502, short-term rental marketplaces are required to collect and remit lodging taxes on the bookings they facilitate within Tennessee. But not every platform operators use counts as a marketplace facilitator under Tennessee law. The breakdown matters.

Platform-by-platform tax coverage in Memphis

Platform TN Marketplace Facilitator Status What this means for you
Airbnb Yes Airbnb collects and remits the full 18.75% stack on every Memphis booking. No separate tax registration needed for Airbnb-only operators.
Vrbo(Expedia Group) Yes Vrbo collects and remits the full stack on every Memphis booking. Same treatment as Airbnb. Vrbo is the vacation rental arm of Expedia Group.
Expedia.com Yes, through Vrbo Vacation rental bookings flowing through Expedia.com are routed through the Vrbo platform and are covered the same way. Hotel bookings on Expedia are separate and not relevant to STR operators.
Booking.com Partial / verify current status Booking.com collects some Tennessee taxes at the time of booking, but its local occupancy tax collection has historically been incomplete in Tennessee. Verify coverage in your extranet before you list and assume you may need to collect the gap yourself.
Furnished Finder No Furnished Finder is a paid listing directory, not a booking platform. Guests contact you and book directly via a lease, so no taxes are collected by Furnished Finder. Most Furnished Finder stays are 30+ days and are not STRs, but any stay under 30 days is an STR and you are responsible for the full 18.75%.
Direct bookings(your website, email, repeat guests) N/A Zero platform involvement. You are responsible for registering with every taxing authority, collecting taxes from guests, and remitting monthly returns yourself.

The practical rule for Memphis: if Airbnb and Vrbo are your only two channels, tax operations are largely automated. Add a third channel and your tax workload changes materially regardless of which third channel it is.

Other triggers that change your tax obligations

Even if you stay on Airbnb and Vrbo exclusively, the following can still create direct filing obligations:

  • Total gross receipts exceed $10,000 in a Tennessee county or city jurisdiction, which triggers Tennessee business tax registration separately from sales tax
  • A guest stay exceeds 30 continuous days, which may change the sales-tax treatment of that booking
  • A platform changes its collection agreement with Tennessee or Shelby County, which happens periodically and is worth checking annually in each platform's host dashboard

Filing cadence (if you have registered accounts)

  • State sales tax: monthly through TNTAP, due by the 20th of the month following
  • Shelby County hotel-motel tax: monthly, due by the 20th of the month following
  • Memphis hotel-motel tax: monthly, due by the 20th. Returns are required even if $0 in tax is due. Failure to collect or remit, or willful false returns, are subject to a civil penalty up to $50

The direct booking trap

Most Memphis operators start on Airbnb exclusively, where platform-collected taxes mean tax operations are near-zero for the owner. Then they add Vrbo (also covered), then a direct booking site on their own website, then start taking corporate inquiries by email (not covered), then add listings on Furnished Finder or smaller platforms (not covered). By the time a tax audit arrives, they have 24 months of off-platform revenue with no tax registration, no collection, and a compounding penalty. Before you add any booking channel beyond Airbnb and Vrbo, register with each taxing authority and set up collection on the new channel.

Day-to-day operating rules

These are the rules you must comply with for every single stay. They come directly from the ordinance and are enforced through code violations and complaint-driven inspections.

  • Minimum stay: No compensation may be received for occupancy of less than 24 hours. Day-use and hourly rentals are prohibited.
  • Maximum sleeping rooms: No more than three sleeping rooms may be permitted per STR property. A single-family home with four or more bedrooms cannot be permitted as a fully-sleeping STR; extra rooms must be staged and used as non-sleeping spaces (office, den, game room, media room) and your listing must reflect the permitted sleeping capacity.
  • Principal renter age: The principal renter (the person on the reservation) must be at least 18 years old.
  • Occupancy standard: A widely applied working standard across Tennessee is two people per bedroom plus two additional guests. This is not a specific Memphis ordinance figure, but is consistent with Tennessee common practice. Your listing's max occupancy should be stated on the application and reflected in your house rules.
  • Noise compliance: All permit holders and their transient guests must comply with Memphis City Code §22-1 on noise control.
  • Garbage and sanitation: Compliance with Ordinance 4840 is required, including proper container placement and pickup timing.
  • Posted information: Responsible Party name and phone number must be conspicuously posted inside the unit.
  • Non-discrimination: Permit holders, hosting platforms, and responsible parties may not discriminate against any guest based on membership in a class protected by the Tennessee Human Rights Act.
  • Self-reporting: On receipt of a citation for conduct on the property, the owner must notify the Clerk's Office in writing or electronically, and within 30 days of the court's final decision on that citation.

Listing and advertising rules

Once your permit is issued, the way you list the property is also regulated.

  • Permit number on every listing. Your STR permit number must appear on every public advertisement of the property. This includes Airbnb, Vrbo, Booking.com, Furnished Finder, your direct booking site, social media posts marketing the listing, and any other channel.
  • Accurate capacity. Maximum transient capacity per night must match what you stated on the permit application. Advertising higher capacity than your permit states is a violation.
  • Responsible Party accessibility. Even if the Responsible Party is not publicly named in the listing, their contact must be provided to guests at check-in and posted inside the unit.

Memphis STR penalties and enforcement

Enforcement has ramped up materially since the July 2023 ordinance update. The City and County now use third-party monitoring software to cross-reference public listings against the permit database and identify unpermitted rentals.

Financial penalties

  • Operating without a permit:$50 per day per unit plus applicable court costs
  • Advertising without a permit number: Treated as a violation under the ordinance, subject to civil penalty
  • Failure to collect or remit hotel-motel tax: Civil penalty up to $50 plus interest on unpaid amounts
  • Willful false tax return: Separate civil penalty

Non-financial consequences

  • Permit suspension or revocation after persistent violations
  • Loss of grandfathered status after three or more violations (forces immediate compliance with current rules)
  • Denial of future permit applications at that address for up to 365 days
  • Referral to zoning enforcement for properties operating outside permitted districts
  • Voided insurance coverage (most carriers exclude unlicensed commercial use)

Memphis STR permit renewal process

The permit expires exactly 365 days after issuance. There is no grace period. Operating on an expired permit is operating without a permit.

Renewal timing and process

  • File the renewal at least 30 days before expiration. This is not a suggestion. Applications received inside the 30-day window may not be processed before your current permit lapses.
  • Pay the $150 renewal fee. Non-refundable.
  • Verify the Responsible Party is still accurate. Changes since the original application must be updated in the renewal.
  • Provide updated proof of insurance. Carriers change, policies lapse, certificates expire. Renewal requires a current certificate.
  • Self-certify compliance. You will re-sign the same certifications on the original application, including no citations in the prior 12 months and no unpaid fines.

If your permit lapses, you start over

A lapsed permit requires a new initial application (with the initial fee, not the renewal fee), a new inspection, and fresh certifications. During the gap, you may not legally list or host guests. Set the renewal reminder for 60 days out, not 30.

Appeals and the Short-Term Rental Appeals Board

If your permit application is denied, or your existing permit is revoked or not renewed, you have the right to appeal to the Memphis Short-Term Rental Appeals Board established under Section 8 of Chapter 5-44.

How the appeals process works

  • On denial, revocation, or non-renewal, the Clerk's Office notifies you within 15 days of the completed decision
  • The notice includes information on how to request an appeal to the board
  • You must file the appeal within 10 days after receipt of the denial
  • The board hears the appeal at its next scheduled meeting, or within 45 days of receipt if no meeting is scheduled before that date
  • You may present evidence and argue your case
  • The board's decision may be further appealed through the court system

The most common Memphis STR permit mistakes

We run Memphis short-term rental operations every day and review prospective properties across the city constantly. These are the mistakes that cost owners the most.

  1. Buying a grandfathered STR and assuming the grandfathering transfers. It does not. New owner equals new permit.
  2. Listing before the permit is issued. Every day of listing without a permit is a $50 violation. The "I'll get the permit soon" timeline is the most expensive version of this mistake.
  3. Skipping the zoning verification. Calling after closing to learn the property is in an ineligible district is the fastest way to make a six-figure mistake.
  4. Relying on a standard homeowner's policy. Claims get denied at the worst possible moment because the carrier was never told about the commercial use.
  5. Naming an out-of-market Responsible Party. A friend who lives in Nashville is not a valid Responsible Party. They are neither within 50 miles nor capable of being physically present within two hours.
  6. Failing to include the permit number on listings. Every platform treats this differently. Airbnb has a dedicated permit field in most jurisdictions. Vrbo accepts it in the listing body. Direct booking sites require it displayed on the property page.
  7. Not registering for all four tax accounts. Airbnb collects most but not always all of the required Memphis taxes. Missing a registration means back-filing and penalties when you are caught.
  8. Permitting more bedrooms than the property is permitted to sleep. A house zoned for three bedrooms cannot be advertised as sleeping six on a pullout and a futon if it means listing extra sleeping rooms.
  9. Missing the renewal window. Lapsed permits require re-doing the initial application at the initial fee.
  10. Ignoring the first noise complaint. One complaint is a conversation. Three complaints ends grandfathered status, triggers a nuisance review, and can lose the permit.

Memphis STR permit FAQ

Can I operate an STR in Memphis as an LLC?

Yes. Memphis permits STR ownership and operation by LLC. The permit is issued to the owner of record (which may be the LLC), and the Responsible Party is always a natural person designated in the application. Most investor-owned Memphis STRs operate as LLCs for liability and tax reasons.

How long does the permit process actually take?

If your property passes inspection on the first attempt, your documentation is complete, and you submit during a non-peak week, approval typically takes two to three weeks. First-time owners in properties that need minor corrections (a missing smoke alarm, an egress issue, a garbage code issue) should plan for four to six weeks. If you are scheduling a property purchase around an STR launch date, build in a 60-day buffer from closing to first guest.

Do I need a separate permit for each of my STR properties?

Yes. Each property requires its own permit. If more than one short-term rental unit exists within a single dwelling (for example, a duplex being operated as two separate STRs, or a detached ADU in addition to the main house), each unit is treated as its own STR and requires its own permit, application, and fee.

Is the permit transferable if I sell the property?

No. Permits are explicitly non-transferable. They are not assignable to another individual, person, entity, or address, and the permit does not authorize any person other than the named permit holder to operate at that property. A new owner must apply for their own permit under the current rules.

Does Airbnb really collect all the Memphis taxes, or do I still need to register and file myself?

For Memphis bookings made through Airbnb or Vrbo, the platforms collect and remit all applicable lodging taxes: state sales, local option sales, Memphis hotel-motel, and Shelby County hotel-motel. Memphis operators who list exclusively on these two platforms generally do not need to register for and actively manage separate lodging tax accounts. You still need a City and County business license (a one-time $30 total), and you should periodically verify on your Airbnb host dashboard under "Taxes" that the platform is collecting every layer. If you add any booking channel outside Airbnb and Vrbo (direct booking site, email inquiries, smaller platforms), the tax picture changes and you become responsible for the full stack yourself.

Can my property manager serve as the Responsible Party?

Yes, as long as the individual (not the company) named on the application meets all the requirements: natural person, 21 or older, within 50 miles, 24/7 availability, and ability to be on-site within two hours. A local property management company's operations lead or principal can and typically does serve as the Responsible Party on behalf of out-of-market owners.

What happens if a neighbor complains about my STR?

The Clerk's Office is required to notify the owner of any citation for code violation or similar nuisance behavior on the property. Three or more violations trigger loss of grandfathered status and can result in permit suspension or non-renewal. First response is key: a Responsible Party who handles the complaint on-site within the two-hour window usually prevents escalation. An owner who does not respond, or whose contact number rings to voicemail at 2 a.m., usually escalates straight to code enforcement.

Do I need a permit if I am only renting out one room in my primary residence?

Yes. The ordinance defines an STR as a residential dwelling unit, a portion of a dwelling unit, or a detached ADU rented for less than 30 consecutive days. A spare bedroom rented through Airbnb falls within "a portion of a dwelling unit" and requires a permit.

Can I rent to the same long-term guest for 35 days without a permit?

Yes. A rental to the same occupant for 30 or more consecutive days is not a short-term rental under the ordinance, and a standard residential lease or corporate housing agreement applies instead. This is the basis of the "mid-term rental" model some Memphis investors use to avoid the STR permit regime entirely, particularly for traveling nurses, insurance displacements, and corporate assignments.

What about Mud Island, Harbor Town, and Downtown? Any special rules?

Mud Island and Harbor Town are within Memphis city limits and follow the standard Chapter 5-44 permit process. Properties in overlay districts (historic overlays, the Center City Commission district, or HOA-governed condominium associations) may have additional restrictions layered on top of the city permit. HOA CC&Rs in some downtown Memphis buildings explicitly prohibit short-term rentals regardless of whether a city permit is obtainable. Pull the HOA documents before you buy.

Are there any Memphis neighborhoods where STRs are effectively banned?

There is no neighborhood-level outright ban, but some residential condominium buildings and planned communities have HOA restrictions that functionally prohibit STRs. Separately, any parcel rezoned from residential to commercial is subject to an 18-month waiting period before an STR permit can be issued. Verify zoning and HOA restrictions at every specific address you consider.

Is the 2 people per bedroom plus 2 occupancy rule in the ordinance?

The 2-per-bedroom-plus-2 formulation is a widely applied occupancy standard across Tennessee and reflects common practice in Memphis STR operations. The Memphis ordinance itself requires operators to state a maximum transient capacity on the application and operate within that number. Your listing and house rules should reflect what your permit application states. Inspectors and neighbors both pay attention to this number.

Do I need a business license for my Memphis Airbnb?

Yes. Memphis STR operators need both a City of Memphis business license and a Shelby County business license. Both are obtained through the Shelby County Clerk's Office and cost $15 each ($30 total). This is separate from the $300 STR permit itself. Most first-time owners forget this and get caught at tax filing time.

Can I run a Memphis Airbnb without living in the property?

Yes. Memphis permits both owner-occupied and non-owner-occupied short-term rentals with proper permitting. Unlike Nashville, which restricts non-owner-occupied STRs through a permit cap and specific zoning overlay, Memphis does not cap the number of non-owner-occupied STR permits. This is one of the most important structural reasons Memphis has become such a strong market for out-of-state STR investors over the past few years.

What is the minimum stay allowed for a Memphis Airbnb?

24 hours, per the ordinance. No Memphis STR may receive compensation for occupancy of less than 24 hours. Day-use and hourly rentals are not permitted at all. There is no ordinance-mandated minimum beyond 24 hours; many operators set 2-night minimums for cleaning economics and to filter out party-focused bookings, but that is an operator choice, not a requirement.

Is there a cap on the number of Memphis STR permits?

No. Memphis does not have a permit cap or a waitlist for non-owner-occupied STRs. Nashville has a cap and a waitlist; Memphis does not. As long as the property meets zoning, safety, and insurance requirements, a permit will be issued on the standard timeline. This is one of the most important facts for investors comparing Memphis to other Tennessee markets.

Can I get an STR permit for a duplex or ADU in Memphis?

Yes, with separate permits per unit. A duplex being operated as two separate STRs requires two separate permits, each with its own application, $300 fee, inspection, and insurance coverage. A detached accessory dwelling unit (ADU) can be permitted as an STR if it complies with applicable building codes and contains no more than three sleeping rooms. If you are operating both the primary dwelling and a detached ADU as separate STRs, each is treated as its own STR and needs its own permit.

Getting permitted is the easy part.

Making money month after month while staying compliant, answering the 2 a.m. call, and keeping the reviews above 4.8 stars is the harder part. That's what LPS does.

What you handle solo vs with a Memphis property manager

Running a Memphis STR legally and profitably is a full operations job. The permit is the starting line. Here's what the actual workload looks like.

Responsibility Solo operator With LPS
Verify zoning and STR eligibility You LPS pre-screens
Source and bind STR insurance You We refer vetted brokers
Pass code enforcement inspection You LPS coordinates
Submit and track the Accela application You LPS handles
Act as Responsible Party (24/7, 50-mile, 2-hour rule) You or a local contact LPS is your Responsible Party
Install and maintain all safety equipment You LPS stages and audits
Tax registrations (state, county, city) You LPS advises
Annual permit renewal tracking You LPS tracks and renews
Listing setup, photography, pricing You LPS full-service
Guest communication, reviews, turns You LPS handles
Neighbor relations and complaint response You LPS on-call
Compliance audit and violation response You LPS manages

If you want the short-term rental income without the short-term rental workload, that's the gap LPS fills. If your property isn't a fit for STR at all because of zoning or HOA restrictions, we also run a Memphis long-term property management program that pivots the same asset into stable monthly rent.

Official contacts directory

The authoritative sources. When in doubt, these are the phone numbers to call.

Accela Citizen Access Portal

The online portal where Memphis and Shelby County STR permit applications are filed, paid, and tracked.

aca-prod.accela.com/SHELBYCO

(901) 636-6711

Shelby County Clerk - Room Occupancy

Room occupancy tax registration and filing.

150 Washington Ave, Suite 200
Memphis, TN 38103

(901) 222-3059

Memphis Planning Department

Zoning verification for addresses within Memphis city limits.

(901) 576-6619

Shelby County Planning & Development

Zoning for unincorporated Shelby County properties and comprehensive planning questions.

125 N Main St #468
Memphis, TN 38103

(901) 576-7197

City of Memphis Permits Office

General permits, licenses, and regulatory permits questions.

2714 Union Ave Ext. Suite 100
Memphis, TN 38112

(901) 636-6711

Memphis/Shelby County Code Enforcement

Inspection scheduling and code violation resolution.

(901) 222-8300

Tennessee Department of Revenue

State sales tax, business tax, and TNTAP portal registration.

(615) 253-0600

Shelby County Clerk's Office

Business license registration, general licensing questions.

150 Washington Ave, Suite 200
Memphis, TN 38103

(901) 222-3000

Official documents and resources

Explore the rest of our Memphis STR owner library.

About this guide. This page is maintained by LPS (Longstep Property Solutions), a Memphis-based property management company specializing in short-term rental operations. We run Memphis STR properties every day and wrote this guide from the operator's perspective.

Verify before you rely. Memphis and Shelby County ordinances, fee schedules, and tax rates can change. Fees, tax rates, and specific procedural details should be verified with the issuing office before you submit any application or make any financial decision. This guide is informational and is not legal, tax, or insurance advice. Consult a licensed attorney, CPA, or insurance broker for advice specific to your situation.

Last updated: April 2026. Based on Ordinance No. 5631 (Chapter 5-44) effective July 1, 2023, the $300 initial / $150 renewal fee schedule under the 2023 amendment, the April 2025 Memphis city hotel-motel tax increase to 4%, and the current Accela Citizen Access permit portal for Memphis and Shelby County.