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 Sanctuary Coalition Cymru (formerly Welsh Refugee Coalition) | Evidence from Sanctuary Coalition Cymru (formerly Welsh Refugee Coalition)
(We would be grateful if you could keep your answer to around 500 words).
The Visitor Accommodation (Register and Levy) Etc. (Wales) Bill aligns with the Welsh Government’s goals of fairer cost-sharing between residents and visitors, increased revenue for tourism-related infrastructure, and promoting sustainable tourism. These objectives are commendable and position Wales as a forward-thinking destination. The general principles of the Bill also align with the spirit of the Well-Being of Future Generations Act. However, the proposed levy raises significant concerns regarding its potential impact on homelessness charities and the vulnerable individuals they serve.
The principle of requiring visitors to contribute to local services is sound, addressing the current imbalance where residents bear costs for amenities enjoyed by tourists. The discretionary nature of the levy empowers local authorities to adapt its implementation to local needs, enhancing its effectiveness. Additionally, the establishment of a visitor accommodation register is a progressive measure that will improve transparency, support better tourism management, and inform future policymaking.
However, the levy risks unintended consequences for homelessness charities that rely on temporary accommodation to provide essential services such as emergency shelter, meals, and counselling. These organisations already face severe financial constraints, and added costs from the levy could force service reductions and staff cuts. This would go against the Welsh Government’s stated ambition of ending homelessness. Smaller charities are particularly vulnerable, while larger ones may need to divert resources away from frontline services to cover administrative costs or fundraising efforts. This would exacerbate challenges for vulnerable groups and conflict with broader social welfare objectives. Fundamentally, we believe that this is not the intended purpose of the legislation, yet, in its current form, this will be a very real unintended consequence.
Recommendations: We have three suggestions to mitigate these risks and ensure the Bill’s success:
Exempt temporary accommodation for vulnerable groups: Temporary accommodation used by homelessness charities should be explicitly exempt from the levy. A clear and straightforward exemption process would prevent undue financial and administrative burdens on these organisations.
Streamline levy administration: Simplify the process for temporary accommodation providers, particularly charities, to minimise inefficiencies and ensure resources remain focused on essential services.
Clarify social welfare impacts: Amend the Bill to explicitly account for the impact on temporary accommodation for vulnerable groups, ensuring alignment with Wales’ wider social welfare goals.
While the Bill offers significant potential benefits for sustainable tourism, its implementation must carefully balance these goals with the needs of vulnerable populations. By introducing targeted exemptions and streamlining processes, the Welsh Government can ensure the levy supports tourism without undermining critical social welfare efforts.
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.
(We would be grateful if you could keep your answer to around 500 words).
The implementation of the Visitor Accommodation (Register and Levy) Etc. (Wales) Bill faces several potential barriers that must be addressed as soon as possible to ensure its success.
Key Barriers:
Administrative burdens: Local authorities and accommodation providers may face significant administrative demands in implementing the levy and maintaining the visitor accommodation register. Ensuring consistency across local authorities and compliance by providers could strain resources and hinder effective enforcement.
Economic and stakeholder concerns: Budget travellers may view the levy as a deterrent, potentially affecting tourism levels. Wales' tourism industry, which contributed £6 billion annually to the economy pre-pandemic (Welsh Government: Tourism Strategy), could experience a dip if tourists perceive the levy as an added cost. Accommodation providers might oppose the levy due to its potential to reduce their competitiveness in a crowded market.
Impact on Homelessness Charities: Homelessness charities providing temporary accommodation are at significant risk. Already operating under tight financial constraints, these organisations could face additional costs that reduce bed availability, shorten stays, and force cuts to essential services such as meals, counselling, and rehabilitation programmes. Between April 2023 to March 2024, the number of households assessed as homeless and owed a duty to help secure accommodation (Section 73) increased by 8% on the previous year to 13,539, the highest figure since the legislation began.
Charities play a critical role in meeting this need and preventing the figures from increasing, and further financial pressures may compromise their ability to deliver vital services.
Case studies highlighting risks
Nancy’s* Story: Nancy, a vulnerable asylum seeker, faced the devastating prospect of homelessness after fleeing conflict in her home country. Arriving in Wales with limited resources and no local support network, she urgently needed emergency accommodation to avoid sleeping rough. A homelessness charity stepped in, offering her a temporary place to stay along with meals, mental health support, and assistance in navigating the asylum system.
Without this intervention, Nancy would have been exposed to severe health risks, including the physical dangers of rough sleeping and the psychological toll of isolation and trauma. However, under the proposed visitor levy, organisations like the one that helped Nancy would face additional financial pressures, potentially reducing their ability to offer similar support. Higher operational costs could result in fewer available beds, shorter stays, and a reduction in critical wraparound services, leaving people like Nancy with nowhere to turn.
Assef’s* Story: Assef arrived in Wales as an unaccompanied minor after fleeing violence and instability. Initially placed in adult Home Office accommodation in England, he found himself isolated, frightened, and struggling with his mental health. With no family or trusted support system, Assef’s vulnerability intensified, particularly as he believed he was a minor but had not been treated as such.
Recognising the urgency of his situation, a coalition of organisations, including the Welsh Refugee Council and a youth advocacy charity, intervened. They helped secure a formal age assessment, legal advice, and temporary emergency accommodation. This safety net provided Assef with stability and a chance to begin rebuilding his life while local authorities assessed their responsibilities.
Without these charities’ ability to act quickly and collaboratively, Assef might have remained in unsafe and unsuitable conditions. The proposed levy, however, risks imposing additional administrative and financial burdens on such organisations, limiting their ability to respond effectively to cases like Assef’s.
*Names changed for safeguarding
(We would be grateful if you could keep your answer to around 500 words).
The Visitor Accommodation (Register and Levy) Etc. (Wales) Bill aims to promote sustainable tourism and ensure a fairer distribution of the costs of public services. However, it risks creating unintended consequences that could significantly impact homelessness charities and other third-sector organisations in Wales.
Key Concerns:
Complexities arising from the Renting Homes (Wales) Act 2016: The Act’s tenancy reforms have created challenges for supported accommodation providers. While direct access hostels offering emergency accommodation for stays of 24 hours or less are exempt from certain provisions, other forms of supported housing face increased administrative burdens. This has disrupted service delivery for vulnerable individuals and adds further strain on homelessness charities already navigating tight budgets.
Financial pressures from National Insurance contribution (NIC) increases: Recent rises in employer NICs (from 13.8% to 15%) have exacerbated financial difficulties for third-sector organisations. Charities in Wales warn these changes are unsustainable without corresponding increases in funding. For example, Turning Point estimates the NIC hike will cost it an additional £1.1 million annually, a burden echoed by many Welsh organisations delivering vital public services.
Impact on commissioned services: Homelessness charities often deliver public programmes through commissioned services on behalf of local authorities. The combined financial pressures of increased NICs and the proposed visitor levy risk reducing their capacity to provide essential services such as emergency shelter, counselling, and mental health support. This threatens the stability of a critical safety net for Wales’ most vulnerable populations.
Additional recommendations
To address these barriers, the following measures should be considered:
Conduct post-implementation reviews: Establish regular reviews to assess the economic, social, and administrative impacts of the levy, ensuring unintended consequences are addressed promptly.
Engage stakeholders through effective communication: Launch an inclusive communication strategy to explain the levy’s purpose, benefits, and exemptions, fostering greater understanding and support among affected parties.
While the Bill aims to support sustainable tourism and fairer cost distribution, its success depends on addressing potential barriers, particularly for homelessness charities. By introducing targeted exemptions, simplifying processes, and reviewing impacts post-implementation, the Welsh Government can ensure the policy achieves its goals without undermining vital social welfare efforts.
(We would be grateful if you could keep your answer to around 500 words).
We commend the Welsh Government for its thorough evaluation of the financial and broader impacts of the Visitor Accommodation (Register and Levy) Etc. (Wales) Bill. The objectives to strengthen local economies and improve tourism management are laudable. However, we strongly recommend adjustments to ensure the Bill does not disproportionately affect vulnerable groups or the organisations that support them.
Key concerns and recommendations:
Exemptions for social welfare accommodation: Charities providing emergency housing for sanctuary seekers and homeless individuals play a critical role in supporting those in crisis. These organisations already operate under significant financial and administrative strain. Without targeted exemptions, the proposed levy could increase their operational costs, reducing their ability to deliver essential services.
We urge the Welsh Government to introduce a clear and straightforward exemption process for accommodation used for social welfare purposes, ensuring vulnerable groups remain protected.
Transparency and inclusivity in levy revenue allocation: Funds generated through the levy for "destination management and improvement" should support inclusive initiatives that benefit diverse communities, including those hosting refugees or providing emergency housing.
To enhance transparency, we recommend extending consultations to third-sector organisations and charities involved in social welfare. This would ensure that the perspectives of marginalised groups are considered in decisions on revenue allocation.
Monitoring and regular impact assessments: Effective implementation of the Bill requires close monitoring of its financial impacts, particularly on organisations providing affordable and emergency accommodation.
We recommend regular impact assessments to evaluate the legislation’s effects on vulnerable groups and to mitigate any unintended consequences promptly.
Commitment to collaboration: We are committed to working collaboratively to ensure the Bill is implemented in a way that balances tourism growth with social welfare priorities. By introducing targeted exemptions, promoting inclusivity in levy fund usage, and monitoring impacts on vulnerable groups, the Welsh Government can achieve its objectives while safeguarding critical social services.
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).
(We would be grateful if you could keep your answer to around 500 words).
While the Visitor Accommodation (Register and Levy) Etc. (Wales) Bill includes broad principles designed to promote sustainable tourism, significant concerns arise regarding its lack of explicit provisions for temporary accommodation used by homelessness charities and vulnerable groups. The reliance on subordinate legislation to address critical details risks creating ambiguity and unintended consequences, potentially undermining both social welfare objectives and the Bill’s effective implementation.
Key concerns:
Financial strain on homelessness charities: Without clear exemptions, the levy could impose additional costs on charities providing emergency accommodation. Many of these organisations operate on limited budgets, and the levy may force them to reduce available beds, shorten stays, or divert funding from essential services such as counselling, mental health support, and job training programmes. Smaller charities, already under financial pressure, are particularly vulnerable, with some facing potential closure. Larger charities may be forced to shift resources from frontline services to fundraising, reducing their capacity to assist those in crisis.
Administrative burden: The levy’s administrative complexity risks overwhelming charities and local authorities. Organisations may face inefficiencies, such as charities paying levies on accommodations they operate or local authorities collecting levies from their own funded services, diverting resources away from their core missions.
Ambiguity in subordinate legislation: The Bill does not explicitly address how the levy applies to temporary accommodation for vulnerable groups. This uncertainty creates operational challenges for homelessness charities and local authorities, reducing the affordability and availability of emergency shelter.
Recommendations:
Introduce explicit exemptions for temporary accommodation: The Bill must clearly exempt temporary accommodation used by homelessness charities from the visitor levy. A straightforward exemption process would alleviate financial pressures and ensure critical services remain available for vulnerable individuals.
Simplify administrative processes: Establish a streamlined verification mechanism for charities at the point of booking to avoid unnecessary bureaucratic hurdles. Simplifying the levy’s administration would minimise inefficiencies for both local authorities and third-sector organisations.
Align the Bill with social welfare goals: The legislation should allocate a portion of levy revenues to initiatives addressing homelessness and supporting vulnerable populations. Such an approach would ensure the levy reinforces broader social welfare objectives rather than conflicting with them.
Engage stakeholders in drafting subordinate legislation: Involve homeless charities and local authorities in shaping subordinate legislation to ensure exemptions and administrative processes are practical and effective. This collaboration would reduce unintended consequences and foster stakeholder confidence.
Implement regular impact monitoring: Establish a framework for ongoing evaluation of the levy’s effects on vulnerable groups and third-sector organisations. Regular impact assessments will enable evidence-based adjustments, ensuring the policy balances sustainable tourism objectives with social equity.
To ensure the Bill achieves its objectives without compromising social welfare, the Welsh Government must provide greater clarity within the primary legislation, particularly concerning temporary accommodation for vulnerable groups. By introducing targeted exemptions, streamlining processes, and involving stakeholders in subordinate legislation, the Bill can balance sustainable tourism with a commitment to protecting Wales’ most vulnerable populations.
(We would be grateful if you could keep your answer to around 500 words).
The Visitor Accommodation (Register and Levy) Etc. (Wales) Bill provides a forward-thinking framework to promote sustainable tourism and fairly distribute local service costs, aligning with Wales' goals to enhance infrastructure and protect the environment. However, the legislation as currently drafted raises several concerns that merit attention to ensure its successful implementation without unintended consequences for Wales’ most vulnerable populations.
A key concern is the lack of explicit provisions for temporary accommodation used for social welfare purposes. Charities providing essential services, such as emergency housing for homeless individuals, could face significant financial and administrative burdens under the visitor levy. Already operating on tight budgets, these organisations may be forced to reduce bed availability, shorten stays, and cut back critical support services such as counselling and mental health care.
The lack of clarity around exemptions for temporary accommodation creates unnecessary uncertainty for both charities and local authorities. Without clear guidelines, homelessness charities may find themselves navigating a complicated and costly administrative process to comply with the levy, further diverting resources from their core mission. Additionally, local authorities, often serving as both levy administrators and service providers, could encounter inefficiencies that waste resources and slow the delivery of essential services.
To mitigate these challenges, the legislation must include targeted exemptions for temporary accommodation used for social welfare purposes. This simple yet essential provision would ensure that charities can continue providing critical support without disruption. Streamlining the levy’s administrative processes is equally important. A straightforward mechanism to exempt bookings made by charities would minimise bureaucratic hurdles, enabling these organisations to focus on their vital work.
Moreover, the Bill’s implementation could be significantly enhanced by mandating that a portion of the levy’s proceeds supports social welfare initiatives, such as homelessness prevention programmes. This allocation would not only demonstrate the Welsh Government’s commitment to inclusivity but also reinforce the message that economic development and social equity can coexist harmoniously. Regular impact assessments and ongoing engagement with charities and local authorities should also be built into the legislation to ensure it remains aligned with its objectives and responsive to unintended outcomes.
The Bill holds great potential to strengthen tourism in Wales while addressing the growing need for sustainable development. However, its success hinges on ensuring that its design does not inadvertently penalise the organisations and individuals working tirelessly to support society’s most vulnerable members. By incorporating targeted exemptions, reducing administrative burdens, and prioritising social welfare within its implementation, the Welsh Government can create a balanced and inclusive policy that truly serves all of Wales.
(We would be grateful if you could keep your answer to around 500 words).
The proposed registration and enforcement provisions in the Visitor Accommodation (Register and Levy) Etc. (Wales) Bill pose significant challenges for Welsh charities providing accommodation services. While the intent to enhance oversight is commendable, the potential administrative and financial impacts on non-commercial, charity-run organisations require further consideration.
Administrative burdens: Smaller charities, often reliant on limited resources and volunteers, may face difficulties meeting registration requirements and maintaining accurate records. This could divert attention and funds away from their core mission of supporting vulnerable individuals.
Penalties and financial impacts: The penalties for non-compliance, such as a £300 charge per premise and £60 per day for continued non-registration, disproportionately impact charities operating on tight budgets. While provisions for waiving penalties in special circumstances are welcome, excluding financial hardship as a qualifying factor seems inequitable. This should be reconsidered to reflect the realities faced by charities.
Flexibility and guidance: The inclusion of a "reasonable excuse" clause is a positive step, but clearer guidance is needed to ensure charities understand their obligations and can comply consistently. The appeal process, while vital for fairness, may still deter smaller charities due to its complexity and potential costs. Simplifying this process and providing accessible support would help address this issue.
Recommendations:
Tailored provisions for charities: Introduce explicit exemptions or reduced obligations for charity-run, non-commercial accommodation to avoid unnecessary strain on these organisations. Consider a tiered penalty structure that accounts for the scale and purpose of providers, ensuring penalties are proportionate and fair.
Enhanced support for compliance: Provide clear, accessible guidance and training tailored to charities, simplifying the registration process and helping them meet their obligations. Offer proactive outreach to smaller charities to ensure they are aware of the requirements and support mechanisms available.
Ongoing engagement: Engage meaningfully with Welsh charities at Stage 2 to refine these provisions, ensuring they are equitable and practical for organisations with limited resources.
The success of the Bill depends on balancing robust enforcement with fairness and accessibility. By tailoring registration and enforcement provisions to the needs of charities, the Welsh Government can uphold its social welfare objectives while achieving its goals for sustainable tourism. This approach would foster greater compliance, reduce unintended consequences, and ensure the legislation works in harmony with Wales’ broader social and economic priorities.
(We would be grateful if you could keep your answer to around 500 words).
The Visitor Accommodation (Register and Levy) Etc. (Wales) Bill is a welcome step towards sustainable tourism and fair cost distribution, but it risks causing unintended harm to homeless charities and vulnerable groups. Without exemptions, charities providing temporary accommodation face financial strain, reduced capacity to deliver essential services, and increased administrative burdens, jeopardising their ability to support those in crisis. Smaller charities are particularly at risk of closure, while larger ones may have to divert resources away from frontline services to meet compliance demands.
In Wales, homelessness remains a significant issue, with 6,135 households identified as unintentionally homeless and in priority need, an increase of 20% on the previous year. Many charities supporting these individuals operate on tight budgets and face growing financial challenges. Research highlights that 80% of small charities in Wales report financial instability, compounded by rising demand for their services (WCVA: State of the Sector).
Furthermore, Wales has been a leader in innovative homelessness prevention initiatives such as Housing First, which has achieved a 91% tenancy sustainment rate (Cymorth Cymru). However, these successes are at risk if the financial and administrative pressures on homelessness charities increase under this Bill.
To address these concerns, we reiterate our key recommendations: the Bill must explicitly exempt temporary accommodation used for social welfare purposes. A clear and straightforward exemption process is essential to ensure charities avoid unnecessary costs and administrative hurdles, enabling them to continue their vital work uninterrupted. Furthermore, allocating a portion of the levy’s proceeds to homelessness prevention and other social welfare initiatives would align the policy with Wales’ broader commitment to equity, reinforcing inclusivity while supporting tourism objectives.