Your cleaner's hours matter because the 100-hour test has two halves. Treas. Reg. §1.469-5T(a)(3) asks whether you participated for more than 100 hours and whether any other individual participated more than you did. A cleaner who handles every turnover is an individual participating in the activity, so their hours are the number yours have to beat. Most owners track their own time carefully and then guess at the cleaner's, which leaves the second half of the test undocumented.
The comparison includes people you pay
The regulation says "any other individual (including individuals who do not own any interest in the activity)." There is no carve-out for contractors, for people you pay, or for people who never set foot in a meeting about the property. A 1099 cleaner is squarely inside the comparison. So is an unpaid neighbor who lets the plumber in.
This surprises owners because the cleaner feels like a service rather than a participant. For the 100-hour test, the distinction does not exist. What exists is a count of hours per individual, and one of those individuals is the person doing three-hour turnovers every week. IRS Publication 925 describes the participation tests in the same terms, and the 100-hour test guide walks through the two halves in general. This post is about the half that depends on someone else's calendar.
Individuals, not companies
If your turnovers are handled by a cleaning company that sends whoever is available, the comparison is still made individual by individual. A company that sent four different cleaners across the year does not have "company hours"; it has four people with separate totals, and you are compared to each of them separately.
That is a real difference from a single independent cleaner who does every turnover alone. Sixty turnovers at three hours is 180 hours for one person, and it is 45 hours each if four people split them evenly. The regulation cares about the per-person number, not the invoice total.
It also means you cannot answer the question from your bank statement alone. Two owners with identical cleaning spend can be in completely different positions depending on how many people did the work.
Estimating a cleaner's hours you can defend
You are not going to get a timesheet from most cleaners, and you do not need one. You need a number with a method attached to it. In rough order of strength:
- Time stated on the invoice. If the invoice says "4 units, 3.5 hrs," the estimate is the invoice.
- Invoice count times a typical duration. Count the paid turnovers from your records and multiply by a per-turnover time you can explain. Sixty turnovers at three hours is 180 hours.
- Booking calendar times a typical duration. If invoices are bundled monthly, count the checkouts instead. Every checkout that was followed by a check-in had a turnover behind it.
- A written estimate from the cleaner. A short note or text at month end — "about 12 hours this month" — dated when it was sent.
Write the method next to the number. "Cleaner: 180 hours, 60 turnovers at 3 hours each from the 2026 invoices" is a figure someone else can check. "Cleaner: around 150" is not. The same discipline applies to your own entries, and what a credible hours log entry looks like covers the format on your side of the ledger.
Deep cleans, linen runs, restocking trips and post-guest damage checks belong in the estimate too. If the cleaner did it for the property, it is participation in the activity, whether or not it was on the turnover invoice.
The vendors owners forget
Cleaners get the attention because the hours are large and regular. The rest of the vendor list is easy to overlook and, individually, rarely large enough to beat an engaged owner:
- Handyman. Occasional, but a multi-day repair project can be a big block of hours for one person.
- Landscaper or snow removal. Often a company with rotating crews, so per-person hours stay low.
- Pool or hot tub service. Short weekly visits that add up across a season.
- Property manager. A different problem entirely, because an individual manager's hours are usually well ahead of the owner's. We covered that case in the STR loophole with a property manager.
You do not have to reconstruct all of these to the minute. You do need to be able to say, for each individual who worked on the property, roughly how many hours they put in and where that figure came from.
Ask for time on the invoice
The easiest fix is to ask vendors to state hours on their invoices. Most will, because they usually know. A line reading "turnover, 2.5 hours" costs the cleaner nothing and turns your estimate into a contemporaneous third-party record.
Ask at the start of the engagement rather than in March. A request made mid-year changes nothing about what already happened, and a request made after year end produces reconstruction. If a vendor will not itemize time, fall back to the invoice-count method and note that the number is your own estimate, built on invoice dates.
Rotating cleaners is a fact, not a strategy
Owners hear that multiple cleaners keep any single person's hours below theirs and treat it as a lever to pull. Be careful with that framing. Substance governs: if the work is genuinely spread across several people, the per-person hours are genuinely lower, and that is simply what happened. If the arrangement exists on paper while one person still does all the work, the paperwork is not what gets counted.
Rotating cleaners also does nothing about the first half of the test. You still need more than 100 hours of your own participation, documented as you go. Winning the comparison with 40 hours of your own time does not qualify you for anything.
Keep the comparison current
The comparison is a year-long number, and it is much easier to maintain monthly than to rebuild in the spring. Once a month, add the cleaner's hours for that month from the invoices, add anyone else who worked on the property, and look at the gap between their largest total and yours. STR Tracker keeps an other-participants tracker per property, so each vendor's running hours sit next to your own and the gap is visible before it becomes a problem rather than after.
What to have in your file at year end, for each property:
- Your own hours, logged with dates, tasks and durations.
- One line per individual who worked on the property: their total, and the method behind it.
- The invoices or calendar exports the estimates were built from.
- A note of anyone whose hours you could not estimate, and why.
If the largest third-party total is climbing toward yours in August, you have four months to do something about it — take back some of the work, or stop relying on this test. In March you have only the record you kept. The does cleaning count guide covers the related question of whether your own cleaning time counts as participation, which is a separate issue from whose hours are larger.
None of this is tax advice, and the tests are more particular than any summary can capture. Bring your records and your per-person totals to a CPA or EA who works with short-term rentals, and let them tell you what the numbers support.