Senedd Cymru | Welsh Parliament
Y Pwyllgor Cyllid | Finance Committee
Bil Llety Ymwelwyr (Cofrestr ac Ardoll) Etc. (Cymru) | Visitor Accommodation (Register and Levy) Etc. (Wales) Bill
Ymateb gan Unigolyn | Evidence from Individual
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I have significant concerns about the impact the bill may have on facilities run by volunteers, The flat-rate levy disproportionately affects low-cost accommodation,which will have a heavy impact on accommodation types which have little or no profitmargins, and for which costs are kept as low as possible. This threatens to make tourism, outdoor recreation, and outdoor education less inclusive and accessible, and push people towards the use of more infrastructure-intensive forms of accommodation which can have a negative impact on Welsh communities such as AirBnb accommodation.
For this reason, I ask for the scope of the bill and the way fees are applied, to be reconsidered, alongside the potential impact of reporting and registration requirements on volunteers. Mountaineering huts, scout huts, campsites, and outdoor education centres already contribute to sustainable tourism goals through environmental and outdoor education and sustainable outdoor practices. If revenue can be effectively ring-fenced for reinvestment in key areas, revenue from the levy could feasibly contribute towards sustainable tourism goals.
The Regulatory Impact Assessment is set out in Part 2 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf). This includes the Welsh Government’s assessments of the financial and other impacts of the Bill and its implementation.
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Scope: ambiguities within the definition of ‘visitor accommodation’ make it unclear whether the bill is targeted at non-commercial providers. It is unclear to those seeking to understand the potential impact of the bill what constitutes. For example, would a mountaineering club cottage (known as a hut) where members and from time to time other club members too can stay at low cost be included. This distinction needs clearer guidance to avoid unintended inclusion, and ambiguity could lead to inconsistent applications of the levy.
Administrative burden: should they be captured within the bill and required to levy fees, volunteer-run accommodations such as scout huts, and mountaineering club huts will struggle to meet 30-day return and payment deadlines. This is not adequately addressed within the bill or its accompanying documents. It contrasts with charity commission timescales, which are 10 months for reporting. Unfortunately many volunteer-run accommodations lack the administrative capacity to fulfil the requirements of the bill as it stands. The resource, time, and financial requirements involved will be prohibitive for many and cause them to close.
Finance: many of these providers do not hold the accounting expertise or financial resources that a commercial provider would hold. This means that the cash-flow requirements of the levy can create burdensome and complex conditions for volunteers who are not trained to create or maintain the procedures needed to correctly report and collect the levy fees.
Equity of levy rates: The flat-rate structure disproportionately impacts low-cost accommodations without sufficiently accounting for their limited revenue generation compared to higher-end providers. For example, the hut fees for the club I belong to are currently £7 per night for members, and £14 per night for guests. Fees are set to cover costs of running the hut, but not generate a profit.
None of these issues are adequately addressed in the Regulatory Impact Assessment, which focuses primarily on commercial providers. The impact of this bill will be felt most heavily by providers which operate with little or no profit margins and for whom the task of administering the levy would fall on those with the least capacity.
A more detailed impact assessment is needed to measure the impact on volunteer run facilities particularly considering the administrative burden and its impact, and the risk tothe viability of these important facilities.
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Volunteer-run accommodations and non-profit facilities may face closure or reduced viability due to administrative and financial burdens. Many of these facilities are already struggling to attract volunteers despite the significant public good they contribute and minimal strain on infrastructure.
Low-cost accommodations such as hostels, campsites, and bunkhouses will pass on the cost of the levy directly to guests, reducing affordability and impacting the inclusivity of tourism and residential stays in Wales. For these types of accommodation, the levy is a far more substantial percentage of the total overnight cost, even with the reduced rates, than for hotel or airbnb type accommodation. Many sites currently only charge a few pounds for an overnight stay. The cost of administering the levy means that it is likely that the price of accommodation would rise by more than the £0.75 or £1.25 fee.
Negatively impacting these types of accommodations will have broad negative impacts, from reducing opportunities for outdoor education, to creating a new financial barrier to the Welsh countryside, to weakening community-based work by youth organisations, to an economic loss to Welsh outdoor tourism, which currently has an annual impact of 1.6 billion, supporting an estimated 31,000 jobs.
For providers running at low or non profit margins, and relying on untrained volunteers to administer the levy, the significant fines referenced in the bill could have a disastrous impact on voluntary organisations and non-profits, causing some to have to cease operations permanently.
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While the financial assessment highlights the potential for increased revenue, it underestimates the impact on small, volunteer-run, and low-cost providers. The costs of compliance, especially for non-profit organizations, and the inequity of a flat-rate levy are not sufficiently addressed.
The powers to make subordinate legislation are set out in Part 1: Chapter 5 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf).
The Welsh Government has also set out its statement of policy intent for subordinate legislation (https://business.senedd.wales/documents/s155951/Statement%20of%20Policy%20Intent.pdf).
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The indicative additional provisions may increase the administrative burden on providers, especially small or volunteer-managed accommodations. Without specific exemptions or support mechanisms for non-commercial facilities, these amendments could exacerbate existing challenges rather than resolve them.
An additional concern is that local authorities may introduce registration/licensing fees – I ask that non-profit accommodations be given an exemption from these.
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Considering all factors, many types of accommodation are currently potentially captured within the scope of the bill which could result in negative impacts on the Welsh Government’s sustainable tourism goals, limiting access to the Welsh countryside, and having a disastrous impact on outdoor education. Commercial and non-commercial accommodations are treated as the same when their impacts could not differ more. This should be resolved in future drafts of the bill.
Iam concerned about the ring-fencing of revenue – clear mechanisms are needed to ensure that revenue is reinvested transparently into services that benefit both visitors and local communities. We propose that councils be required to publish detailed breakdowns of how levy funds are spent including outcomes achieved. This would help achieve buy-in from accommodation providers.
I am also calling for changes to the bill to support non-commercial, volunteer- managed facilities, to avoid potentially disastrous unintended financial and administrative burdens. We are calling for extended administrative deadlines. If fees are to be applied to volunteer-run accommodations, then we would like administrative processes to be made as easy as possible for non-commercial accommodations, and for reporting windows to follow the convention set by existing charity commission rules.
I ask that the Welsh Government reconsider its plans for a flat-rate levy. A proportional levy based on accommodation cost would be more equitable and ensure fairness across all types of providers.