VAB106 Individual

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

General principles

1. What are your views on the general principles of the Bill and the need for legislation to deliver the Welsh Government’s stated policy objective, which is to:

§ ensure a more even share of costs to fund local services and infrastructure that benefit visitors between resident populations and visitors;

§ provide local authorities with the ability to generate additional revenue that can be invested back into local services and infrastructure to support tourism;

§ support the Welsh Government’s ambitions for sustainable tourism?

(We would be grateful if you could keep your answer to around 500 words).

I support the aims of the Visitor Levy Bill to promote sustainable tourism and invest in local services, but have serious concerns about its potential impact on volunteer-run and non-commercial accommodations

The Bill’s implementation

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.

2. Are there any potential barriers to the implementation of the Bill’s provisions? If so, what are they, and are they adequately taken into account in the Bill and accompanying Explanatory Memorandum and Regulatory Impact Assessment?

(We would be grateful if you could keep your answer to around 500 words).

Impact on Volunteer-Run Accommodations

•           Facilities such as mountain huts, scout huts, and residential outdoor education centres rely on volunteers and operate on extremely tight budgets. The administrative and financial burden of the levy could threaten the survival of many.

•           The requirement to submit levy returns within 30 days creates an unreasonable expectation for volunteer-managed facilities such as mountain huts and scout huts. This contrasts sharply with the 10-month timeline allowed by the Charity Commission.

3. Are any unintended consequences likely to arise from the Bill?

(We would be grateful if you could keep your answer to around 500 words).

Impact on young people and other marginalised groups

•           Facilities such as outdoor education centres and other affordable accommodation play a vital role in enabling young people, low-income families, and other marginalized groups to access the outdoors. These types of accommodation are low impact, not-for-profit, and deliver essential services in the form of outdoor and environmental education. They will be disproportionately affected by a flat rate levy and by the administrative burden

4. What are your views on the Welsh Government’s assessment of the financial and other impacts of the Bill?

(We would be grateful if you could keep your answer to around 500 words).

The flat-rate structure disproportionately affects low-cost accommodations. I urge the Welsh Government to consider a proportional levy rate to protect budget-friendly options that contribute to inclusive tourism. This would ensure fairness while maintaining affordability.

In the current form of the legislation, there is a very real risk that revenue raised will not be ring-fenced for tourism-related purposes. I would like to see robust mechanisms to ensure funds are used to address visitor pressures and improve local infrastructure.

Subordinate legislation

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).

5. What are your views on the balance between the information contained on the face of the Bill and what is left to subordinate legislation? Are the powers for Welsh Ministers to make subordinate legislation appropriate?

(We would be grateful if you could keep your answer to around 500 words).

Other considerations

6. Do you have any views on matters related to the quality of the legislation?

(We would be grateful if you could keep your answer to around 500 words).

7. On 26 November, the Cabinet Secretary wrote to the Finance Committee with some indicative additional registration and enforcement provisions (https://business.senedd.wales/documents/s155952/Letter%20from%20the%20Cabinet%20Secretary%20for%20Finance%20and%20Welsh%20Language%20Indicative%20Stage%202%20amendments%20that%20.pdf) he intends to bring forward at Stage 2 of the legislative process (https://senedd.wales/NAfW%20Documents/Assembly%20Business%20section%20documents/Guide%20to%20the%20Legislative%20Process/Guide_to_the_Legislative_Process-eng.pdf).

Do you have any views on the indicative additional registration and enforcement provisions the Welsh Government intends to bring forward at Stage 2?

(We would be grateful if you could keep your answer to around 500 words).

8. Are there any other issues that you would like to raise about the Bill, the accompanying Explanatory Memorandum and Regulatory Impact Assessment, or any related matters?

(We would be grateful if you could keep your answer to around 500 words).

I would like to suggest the following amendments would improve the proposed legislation

•           Exempt non-commercial, volunteer-run accommodations from the levy.

•           Extend levy return deadlines for volunteer-managed providers to align with Charity Commission timescales.

•           Introduce proportional levy rates to reduce the burden on low-cost providers.