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When Joey Staerkle purchased Grade II listed Ivy House it was in a state of disrepair. However, its potential as a holiday rental was undeniable, given its prime location just a short distance from Conwy's bustling High Street, renowned for its artisanal treats, luxury hotels and historical landmarks. The transformation from a residential property to a holiday let marked a new venture for the former beauty queen from Llandudno . After being crowned Miss Intercontinental Wales , Joey went on to earn a First Class Honours degree in business. Now in her late 20s, with an impressive following of more than 65,000 on Instagram and another 32,000 on TikTok, she has demonstrated her talent for style too. For more property stories sent to your inbox twice a week sign up to the property newsletter here . Guests at the property have been highly impressed by the quality of the conversion, which seamlessly blends modern living with historical preservation. There are also touches of luxury, such as the hand-carved bed imported from France. READ MORE: 'I have risked absolutely everything to save the Barry Island landmark that I love' YOU MIGHT ALSO LIKE: I spent over £250,000 creating my dream home but now it's time to leave However, she fears that external factors are threatening her business. The main concern is the 182-day letting rule introduced by the Welsh Government , reports North Wales Live. This rule was established to ensure that self-catering holiday lets are recognised as legitimate businesses for tax purposes, addressing concerns about second homes being used as holiday lets to evade council tax. Like many others in the sector, Joey fears genuine holiday lets are being unjustly penalised by a letting threshold that's set too high to be reasonably attainable. She said: "My holiday let was an abandoned, uninhabitable property that we restored and brought back to life. "By turning it into a holiday home, we invested in the local economy, supported tourism jobs and helped to preserve Conwy's heritage, all without reducing housing availability for local people. "The current 182-day rule doesn't reflect the reality of tourism in Wales. Coastal towns like Conwy are vibrant in summer but naturally quieter in winter and even with strong marketing, it's hard to meet the current threshold during off-peak months when demand naturally drops. "Many owners face real challenges staying compliant, and it isn't a sustainable way to run a small business. Holiday lets being 'being scapegoated'." Those who fail to reach the 182-day threshold find themselves liable for punitive council taxation instead of business rates. Amid criticism that the requirement was too demanding, the Welsh Government is now consulting on possible adjustments with the deadline for responses and feedback set as November 20, 2025. However, critics argue these changes don't go far enough – and question whether the entire policy is fundamentally flawed. "The narrative that holiday lets are a primary cause of Wales' housing crisis is simply untrue," said Ben Spier, head of policy and regulation at Sykes Holiday Cottages, a major booking platform. "These businesses are being scapegoated for deeper, structural issues – chiefly, the long-standing failure to meet home-building targets and the tens of thousands of vacant properties lying empty across Wales. "Unlike second homes, which often sit empty for most of the year, holiday lets generate ongoing economic benefit. Yet they have to pay the council tax premiums intended for second homes if they don't meet this high threshold. "The 182-day rule is considered a metric to identify whether a business is genuine or not, but no other business is measured in this way. For example, a pub is still a business however many pints it pulls a year. "So, if such a threshold is to be used fairly, without unintended consequences, it needs to be used solely to differentiate between second homes and holiday let businesses. Clearly, many genuine holiday let businesses can't meet the existing threshold which suggests it's far too high." Such a crude approach fails to recognise the complex difficulties facing short-term rentals, Ben explained. For instance, it doesn't account for the current shift towards briefer stays, which is making it progressively harder for business owners to secure block bookings. The 182-day rule also overlooks the effort required to operate a holiday let, including preparing, maintaining and refurbishing a property. Financial records need managing, reservations must be coordinated and the enterprise requires continuous marketing on social media and other platforms. "Furthermore, the current threshold doesn't consider the other disruptions to running a micro-business," said Ben. "Examples include maternity and paternity leave - no other job would be allowed to not make provision for this. Significant illness to the operator or a family member, or forced business closure for flooding or refurbishment, are other factors." Research that Sykes carried out alongside Oxford Economics revealed that short-term let-related spending contributed almost £3bn to Wales' GDP and supported approximately 67,000 jobs in 2021. Ben argues that many of these positions offer flexibility and are suitable for families and carers. "These businesses are not idle assets – they're engines of employment, supporting cleaners, tradespeople and the small businesses that rely on visitor spend," he said. For more property, renov ation, a nd interior design stories join our Amazing Welsh Homes Facebook group here . Since the regulation came into effect, numerous property owners have found it difficult to reach the demanding threshold despite their best efforts. Briefer typical stays, pronounced seasonal patterns and reduced demand during quieter periods make hitting the 182 letting days target extremely difficult under normal circumstances, especially in countryside locations. Potential changes, which are currently being consulted on, include permitting businesses to calculate average bookings across several years. The aim is to stop owners being disadvantaged by an exceptionally poor year. Charitable stays could also be allowed to count towards booking targets. While the proposals offer some flexibility, critics argue they fail to address the core issues: that the bar is too high and that holiday lets are fundamentally different from second homes. A national email campaign launched by a holiday let owner is pressing the Welsh Government for a lower bookings threshold. In response, Mark Drakeford, Cabinet Secretary for finance and the Welsh language, said Valuation Office Agency data shows 60% of holiday lets in Wales have hit the 182-day threshold. This exceeded the levels predicted by the self-catering sector as well as historical occupancy estimates outlined in a regulatory impact assessment, said the minister. He indicated the policy had already accomplished what it set out to achieve. "The number of self-catering properties now in the ratings list is similar to the number listed in 2019, prior to the substantial proliferation of holiday lets during the early 2020s," he said. "Numbers increased by 60%, from 7,000 to over 11,000, between April 2019 and April 2023. Many properties in all parts of Wales have met the new letting criteria, demonstrating that is achievable where supply does not exceed demand." A 12-week consultation on the criteria was conducted in 2021. Mr Drakeford stated that this provided a clear mandate for a higher threshold, although he acknowledged that the commonly preferred figure was for 105 days. "The Welsh Government is not duty bound to accept the most common specific response to a consultation," he added. The strategy adopted was intended to "incentivise the right balance" between a thriving tourism sector and sustainable local communities, the minister further explained. Joey supports the idea of addressing underused second homes - but she wants to see a significant reduction of the bookings threshold. "Averaging the 182-day requirement over several years is a step forward, but it still doesn't solve the problem as the number itself is unrealistic," she said. "With only around 126 high-season nights in Wales, a lower threshold would be far more achievable for genuine, small-scale holiday lets. Policymakers should be distinguishing between empty second homes and active businesses. "And instead of penalising responsible operators, councils should be supporting them. These are the people who keep heritage properties alive and contribute meaningfully to local tourism." According to Ben, the High Court's ruling on Gwynedd's Article 4 Direction highlighted the necessity for regulation based on solid evidence. He pointed out that the court's decision underscored a wider issue – that well-meaning regulation, when poorly designed or implemented, risks penalising legitimate businesses without addressing the root problems. Ben stated that focusing on holiday lets won't resolve the housing crisis. "Building more homes, tackling land banking by developers and bringing Wales' 22,000 underused or vacant properties back into use would make a far greater difference. "A one-size-fits-all approach to occupancy thresholds overlooks the seasonal nature of tourism, regional variations in visitor demand and the operational realities of running a small rural business. "Lowering the threshold would make the system fairer and more flexible, safeguarding local jobs and preserving the vibrancy of Wales' tourism industry."
