Rochester, MN Short-Term Rentals: Occupancy Limits (2026)
Key Facts
- Single-family/duplex/triplex/fourplex
- 1 STR unit allowed
- Buildings over 4 units
- Up to 25% of units
- Occupancy assumption
- Max 10 total (2-unit buildings)
- Lodging trigger
- 5+ beds needs separate license
- Enforcement
- Section 7-9-12 daily violation penalty
Summary
Rochester's short-term rental table in section 7-10-2(b) caps how many units in a building may operate as short-term rentals by property type, and assumes occupancy in two-unit buildings does not exceed 10 people total. A structure renting five or more beds crosses into lodging or hotel territory and needs a separate health department license.
(b)Short term rentals in multi-family buildings with three or more units would be prohibited as a primary use (these would be considered hotels). Structures with three or more units require building code classification change from an "apartment building" where occupants are primarily permanent in nature to "hotel/transient housing". Structures with five or more beds would be classified by the department of health as "lodging" or "hotel" and require a lodging license. ... For the purposes of this table it is assumed that the number of occupants within the two dwelling unit does not exceed 10 total.
Official source re-checked September 7, 2026: no newer edition of the code had been published (publisher’s edition: Code of Ordinances: Supplement 8 Update 1).
Full Breakdown
The table attached to section 7-10-2(b) sets a maximum number of short-term rental units allowed per property type: one unit for a single-family building, duplex, triplex or four-plex, rising only for buildings with more than four units, where up to 25 percent of the dwelling units may operate as short-term rentals before the project is treated as a change of use requiring full review. Footnote 2 to that table states that, for the purposes of the table, it is assumed that the number of occupants within a two-dwelling-unit building does not exceed 10 total, the code's own ceiling for how many people it expects in a duplex, triplex or four-plex short-term rental before the classification assumptions break down.
Bed count is the other lever: section 7-10-2(b) requires any short-term rental structure that rents five or more beds to be classified by the health department as "lodging" or "hotel" and to hold a separate lodging license, on top of the short-term rental registration required by section 7-10-2(a). Buildings with more than four units that convert more than 25 percent of their units to short-term rental use trigger both a change-of-use review by community development and a state building code reclassification to R-1 with two percent accessible units.
None of these thresholds set a nightly per-guest headcount limit inside a single unit; the code regulates scale through unit counts and bed counts instead.
Violations & Fines
Exceeding the unit-count cap for a property type, or the 25 percent threshold for larger buildings, without going through the required change-of-use review is enforced the same as any unregistered rental use, through section 7-9-12's daily-violation penalty. Operating a five-or-more-bed short-term rental without the separate lodging license required by section 7-10-2(b) is a violation subject to adverse license action under section 7-9-17.
Frequently Asked Questions
Is there a guest limit for a Rochester short-term rental?
How many short-term rental units can a duplex have?
When does a short-term rental need a lodging license instead?
Sources & Official References
Other rules in Rochester
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