The controversial regulations could also make it a lot more expensive for tourists who will have to pay more for accommodation.
French legislation will focus initially on owners who let property in Paris, Lyon and Marseille, due to begin shortly. Depending on the outcome, the programme of obtaining licences from the local council could be rolled out across the country.
There are some 200,000 British-owned holiday homes in France, mostly in Provence, the Dordogne, Normandy and Brittany.
Spain is also due to introduce licensing. Owners will have to pass regular safety inspections and obtain hygiene certificates. They will also have to meet strict conditions, such as being contactable 24 hours a day to deal with any problems, such as water leaks or power cuts.
Spanish authorities are expected to ban any unlicensed rentals next spring.
Until now, in most parts of Spain, anyone could rent out their homes provided they pay full tax and declare all revenues.
The new licences will no doubt come with a fee attached and failure to comply with the new regulations could incur large fines.
Although the rules will hit any number of expats, they apply to everyone who rents for any period of time. Rentals of even short duration can be deemed to have changed the use of the property.
One million Spanish properties are estimated to be British owned, of which hundreds of thousands are second, or holiday, homes.
Many of these are mortgaged, with owners renting them out to help with upkeep expenses but shy of making a profit.
Private rentals have long been popular with the 12 million Brits who holiday in Spain every year.
According to La Caixa bank, around three-quarters of overnight stays in Spain last year were in ‘unregulated premises’ such as privately-owned villas or apartments.
This has not been lost on the hotel sector, which has been lobbying for change.
Catalonia, the Canary Islands and the Balearics already have tough restrictions. In the past year, thousands of apartment and villa owners in these areas have been fined up to £15,000 each.
Germany is to vote on similar laws in the next fortnight.