Short-Term Rentals in Comal County, Texas

W.O.R.D.: a river-recreation district with its own permit and fee

The Water Oriented Recreation District of Comal County (W.O.R.D.) was created by the Texas Legislature in 1987 and confirmed by Comal County voters in a 1988 election, with a mandate covering Canyon Lake and more than 30 miles of floatable water on the Guadalupe River both above and below the lake. W.O.R.D.'s core mechanism is permitting: it issues permits to water-related businesses operating in the district, which lets those businesses collect a district-approved user fee from customers, and every tourism business operating in the Canyon Lake/Guadalupe River area within the district's boundaries needs a permit regardless of what type of water-oriented business it runs -- short-term lodging (under 30 consecutive days), whitewater or fishing guide services, water-recreation equipment rental, camping, day use, parking for water access, and boat slip rental or storage are all named categories requiring a W.O.R.D. permit. For a short-term rental specifically, that means an operator needs a W.O.R.D. permit in addition to anything the county requires -- W.O.R.D. does not replace county-level permitting, it sits alongside it.

The financial mechanism is a Lodging User Fee: a 3% fee assessed on gross rental income from short-term lodging in the district, paid quarterly to W.O.R.D. This funds the district's stated purpose of conserving natural resources, improving public health and water safety, and operating public parks within the district -- in practice, an operator should plan to track gross rental receipts specifically for this quarterly filing, separate from any city or state hotel occupancy tax obligation that might also apply.

The county septic rule that ties directly to advertised occupancy

Converting a single-family home in unincorporated Comal County to a commercial short-term rental is treated by the Comal County Engineer's Office as a "change in use" for on-site sewage facility (OSSF) purposes -- not a purely cosmetic distinction. If the number of guests advertised online for the property exceeds the design capacity the existing septic system was originally permitted for, the owner can be required to obtain a new commercial OSSF permit and install an upgraded system sized for that higher occupancy, which is a real and potentially substantial cost most first-time STR operators don't budget for. This applies specifically to properties on septic rather than a sewer connection -- a meaningful share of rural and lake-area Comal County land -- and it's triggered by what's advertised, not just what the home was originally built to house. Before listing a rural Comal County property for short-term rental at an occupancy above its original design, confirm the system's permitted design capacity with Comal County Environmental Health and budget for a possible upgrade before advertising a higher guest count.

What to check before buying or converting a property for STR use

1. Confirm whether the property sits within W.O.R.D.'s district boundary (Canyon Lake and the Guadalupe River corridor above and below it) and, if so, apply for the required permit before advertising a short-term lodging business.
2. Budget for the 3% W.O.R.D. Lodging User Fee on gross rental income, filed quarterly, in addition to any state hotel occupancy tax or other applicable fee.
3. If the property is on a septic system, confirm the system's currently permitted design capacity with Comal County Environmental Health before advertising a guest count that could exceed it -- doing so can trigger a mandatory commercial OSSF upgrade.
4. Check whether the parcel is inside New Braunfels's ETJ or a platted subdivision with deed restrictions that separately limit or prohibit short-term rental use, since neither W.O.R.D. nor the county septic rule addresses that question.