Treat the operating license and staffing structure as transaction-critical diligence. The licensing law took effect May 3, 2025. DCWP requires a license for the entity controlling day-to-day hotel operations, a separate license for each hotel, and compliance with other applicable operating authorizations. The license does not replace building-use authorization. DCWP licensing notice; application checklist.
The published license schedule expires on September 30 in even-numbered years. As of this report, September 30, 2026 has passed: request the current license and actual expiration date, not just the original application. DCWP application checklist.
Which staffing arrangements need attention before December 1?
Hotels with 100 or more guest rooms face the core-employee direct-employment requirement, with an option for a single hotel operator to employ those workers and manage the relevant operations. For qualifying contractor agreements executed before May 3, 2025, the transition is December 1, 2026 if there is no definite termination date, or 30 days after a specified termination date. DCWP FAQ.
Other provisions address daily cleaning unless affirmatively declined, continuous front-desk coverage with a specified overnight security alternative, panic buttons and training. Smaller room count does not remove all obligations. DCWP FAQ; hotel worker protections.
What should an operator-transition checklist contain?
A new operator must notify DCWP within ten days after the change and before the old license expires, and submit the required documentation. Changes in the licensed operator’s corporate ownership can require prior approval. DCWP FAQ.
Recommended closing deliverables:
- Identify the licensed entity and intended post-closing employer.
- Obtain all core-staffing contracts, execution dates and termination provisions.
- Price any move from contracted labor to the proposed compliant employment structure.
- Assign licensing notices, approvals and submissions to named transaction participants.
- Obtain evidence of staffing coverage, training and protective equipment—not merely a compliance certification.
For a 100–150-room acquisition, request a second operating case if the seller’s staffing model depends on an arrangement that will no longer be available.