Memphis Is Using Software to Find Unpermitted Airbnbs: What the Develop901 Letter Means
Memphis now uses Rentalscape software to match Airbnb listings to addresses and flag missing licenses. What the Develop901 letter asks for and how to answer it.
Memphis is using software to find short-term rentals, and the letters are already landing in mailboxes. We have one in hand. It is dated September 24, 2026, it comes from the Memphis and Shelby County Division of Planning and Development (Develop901), and its last page is a screenshot of the owner's Airbnb listing stamped "Rentalscape" with a capture time of September 22. Rentalscape is a compliance product sold to local governments by Deckard Technologies. Updated September 29, 2026.
If you host in Memphis, here is what that service does, what the letter asks for, and what to do if one shows up at your address.
How the software finds an Airbnb
Airbnb does not show a street address until a guest books. For years that was enough to keep most listings out of view of a city permit office. It is not anymore.
According to Deckard's own published material, Rentalscape:
- Reviews more than 15 million listings across more than 10,000 rental websites every day.
- Ties each listing to a specific parcel and street address, using the listing text, the photos, and county property and sales records.
- Compares that address against the license on file, and flags the ones with no match.
- Is in use by more than 400 cities and counties.
So a listing with no address, a vague title and a map pin a few blocks off can still be matched to the house. The letter we have named the exact street address of a listing that shows no address publicly.
What the Develop901 letter asks for
The letter cites the city's short-term rental ordinance (Ordinance 5856, codified as Memphis City Code Chapter 5-44). It says any short-term rental that began operating on or after July 1, 2023 must hold a license to advertise or operate, and it lists what to send:
| Requirement | What the city asks for |
|---|---|
| License fee | $300 to apply, $150 to renew each year |
| Term | License runs 365 days, renew every year |
| Floor plan | Showing every room at the address or unit |
| Proof of ownership | Deed or mortgage |
| Taxes | Proof you are current on property taxes |
| Insurance | Fire, hazard and liability of at least $1,000,000 per occurrence |
| Listing display | License number on every ad and listing, and posted inside the property |
| Local contact | A responsible party available to handle complaints |
You get 45 days to apply before a second notice. After that the letter warns of enforcement action, added fees, penalties and suspension. Applications go through the Develop901 Citizen Portal, and staff may schedule an inspection. If the house is no longer a short-term rental, the city wants a notarized letter giving the date it stopped.
Before you pay anything, confirm the letter is real: call the Division of Planning and Development at 901-636-6619 or email zoning@memphistn.gov. The city says it only takes payment in person, by mail against a city invoice, or online through the Develop901 portal, never by wire.
Why a permitted host can still get one
Software matches a listing to a license record. It does not know about the renewal sitting on a staff desk. The letter we have went to a property that already held a license and was mid-renewal. The renewal was approved the day after the letter was dated. The city's first email reply to the owner's "we already have one" was a one-line instruction to apply on Develop901.
So a letter is not proof you did anything wrong. It is proof the record the software checked did not show an active license on the day it looked. That can happen when:
- Your renewal is filed but not yet approved.
- Your license lapsed a few days before the renewal cleared. The ordinance says renewals are due 30 days before the license expires, and the software will not wait for a late one.
- Your license number is missing from the listing, so the match runs on the address alone.
- The license is under a different owner name or entity than the one on the county deed.
What to do if the letter arrives
1. Look up your record first. Log into the Develop901 Citizen Portal and check that your license shows as issued and not expired. Download a copy of the license. 2. Reply in writing with the record number and the license attached. Email zoning@memphistn.gov, name the address, give the record number, and attach the license. A reply that says "we already have a permit" with nothing attached is easy to answer with a form response. 3. Put the license number on every listing. Airbnb, Vrbo, Furnished Finder, your own site. It is required, and it is the cheapest way to keep the match from missing you. 4. Renew 30 days early, every year. The license runs 365 days and the renewal is $150. A calendar reminder costs nothing. A second notice costs time. 5. If you do not have a license, apply inside the 45 days. The ordinance charges double fees to anyone who was operating unpermitted when they finally apply.
Our Memphis short-term rental rules and enforcement guide covers the rest of the ordinance, and our short-term rental page covers what hosting in Memphis takes day to day.
What this means for Memphis hosts
This kind of software does not get tired and does not stop after one pass. Listings in Memphis are now being matched against the license file by software, and the vendor markets it as a daily check. Hosts who have their paperwork in order have little to worry about beyond answering a letter now and then. Hosts who have been running without a license have far fewer places to hide than they did two years ago.
If you want a second set of eyes on your license, your listing or what the house should earn, send us the address and we will take a look.
If you would rather hand the whole thing off, see our management service.
Quick answers
How is Memphis finding Airbnbs without a permit?
The Develop901 letters include a screenshot of the host's listing stamped Rentalscape, a compliance product sold to local governments by Deckard Technologies. Deckard says it reviews more than 15 million listings a day and ties each one to a parcel and street address, then checks it against the license on file.
I already have a Memphis STR license. Why did I get a letter?
The software matches listings to license records. If your renewal was pending, your license had just lapsed, your license number is missing from the listing, or the license is under a different name than the deed, the match can miss you. Reply to zoning@memphistn.gov with the record number and a copy of the license.
How much does a Memphis short-term rental license cost?
The letter lists a 300 dollar application fee and a 150 dollar annual renewal. The license runs 365 days and the ordinance asks for renewal 30 days before it expires. You also need at least 1 million dollars per occurrence in fire, hazard and liability insurance.
How long do I have to respond to the letter?
The letter gives 45 days to apply before a second notice, after which it warns of enforcement action, added fees, penalties and suspension. If the house is no longer a short-term rental, the city asks for a notarized letter with the date it stopped.
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