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 ScoutsCymru | Evidence from ScoutsCymru
(We would be grateful if you could keep your answer to around 500 words).
While the Bill’s objectives have the potential to ensure costs for local services are shared more equally between those using them, we have significant concerns about its broad application.
The current scope fails to distinguish between commercial tourism operations and small, non-profit, volunteer-run facilities that provide low cost accommodation as part of non-formal youth development and outdoor education programs.
Most critically, this Bill directly contradicts key objectives of the Welsh Government's Child Poverty Strategy. The Strategy emphasises maximising household income and reducing living costs for families in poverty, yet this levy would increase costs for activities currently kept deliberately low (£3-£4 per night) to ensure accessibility. The Strategy specifically prioritises all children having access to play, leisure, and cultural activities as crucial tools for breaking the cycle of poverty, objectives that we strongly support but would be undermined by additional costs.
The levy will apply even to Scout groups holding sleepover events in the Scout Halls and Community facilities within their own locality, which surely can't be the intended impact. These events operate on minimal budgets specifically to ensure accessibility for all young people. These facilities provide essential opportunities for skills development, team building, and environmental education, all key elements identified in the Child Poverty Strategy as crucial for improving future prospects. These simple overnight experiences offered to young people as part of Scouting, are often children's first experience of staying away from home within their local community, a crucial developmental milestone that could be jeopardised by these additional costs and associated administrative burden.
The limited income from these premises already appropriately offsets their minimal impact, as Scout groups practice low-impact, environmentally conscious activities by their very nature. While the sustainable tourism objective is laudable, Scouts, Guides and other similar organisations, already actively support it through environmental education and sustainable outdoor practices.
For this reason, we are calling 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. It is far more productive to the Welsh Government’s ambitions for supporting sustainable tourism, for these low cost accommodation sites used primarily for activities and sleepovers for young people to be exempt, however in its current form, the levy and its impact threatens their continuation.
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).
We believe there are a number of potential barriers, particularly concerning non-profit, volunteer-run facilities, which do not appear to be adequately addressed in the Bill or its accompanying documentation:
Scope: ambiguities within the definition of ‘visitor accommodation’ make it unclear whether the bill is targeted at non-commercial providers, causing confusion and unintended consequences. Our understanding, following any inquiry, that the levy applies to overnight stays provided ‘in the course of business or trade’, irrespective of the type of organisation (e.g., private companies, or non-profits). It is still unclear to those seeking to understand the potential impact of the bill what constitutes operating "in the course of trade or business." For example, would a scout hut charging a nominal fee for a sleepover qualify as a business? This distinction needs clearer guidance to avoid unintended inclusion, and ambiguity could lead to inconsistent applications of the levy.
Administrative and technical capacity in Volunteer organisations:
• Volunteer-run facilities like Scout halls typically lack professional administrative support
• The proposed 30-day window for returns and payments is particularly challenging for volunteer run sites who often meet monthly or quarterly. It contrasts with charity commission timescales, which are 10 months for reporting, a much more reasonable expectation for volunteers to deliver.
• Volunteers running these sited, often have full-time jobs or other commitments elsewhere
• Current systems for recording bookings are often simple and informal, to keep running costs low and designed for simple and essential only record-keeping
• Volunteer-run facilities may lack the necessary IT infrastructure for systematic levy and registration recording and collection
• Cost of implementing new systems would be prohibitive for sites operating on minimal non-profit budgets
• Training requirements for volunteers would create an additional resource burden
Seasonal and irregular usage patterns:
• Scout facilities often have irregular usage patterns based on school terms and events
• Some sites may only be used for overnight stays on an adhoc or for only a few times per year
• The quarterly reporting requirement doesn't align well with typical usage patterns
• Seasonal camping activities may cross reporting periods, creating complexity
Financial management complexities:
• Many sites and organisations will operate on annual budgeting cycles
• Cash flow management becomes more complex with levy collection requirements
• Additional banking and accounting procedures would be needed
• Cost of compliance could exceed the levy collected in many cases
These barriers are not adequately considered or addressed in the Regulatory Impact Assessment, which appears to focus primarily on commercial accommodation providers. The assessment does not fully consider the unique operational challenges faced by small, non-profit, volunteer-run facilities, where the primary purpose is not visitor accommodation provision.
A more detailed assessment is needed of the implementation impact on volunteer-run organisations and sites, particularly considering their limited administrative capacity and resources. The current proposals will create disproportionate burdens and costs, which outweigh the financial contribution to local services and infrastructure and will risk the future viability of these important and vital youth development facilities.
(We would be grateful if you could keep your answer to around 500 words).
We have identified several unintended consequences:
Financial Impact:
• Many sites currently charge only £3-£4 for camping
• The proposed levy would represent an 18-25% increase before any additional discretionary fees from Local Authorities
• Potential to create a two-tier system where only those who can afford additional costs can participate
• Scout groups from outside Wales may be deterred from visiting, reducing cultural exchange opportunities
• 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.
Administrative burden on Volunteers:
• The 30-day period for compiling returns and making payments is particularly onerous for volunteer-run sites
• Quarterly returns with only one calendar month for submission create additional unreasonable pressure
• Limited volunteer time would be diverted from youth development to administrative tasks
• Many volunteer-run organisations lack administrative capacity for the requirements suggested
Health and Wellbeing impact:
• Reduced access to outdoor education opportunities directly affects young people's health and wellbeing
• First-time experiences of staying away from home could be lost for many young people
• Crucial developmental opportunities for building independence and confidence could be compromised
• Community cohesion could be weakened as local youth activities become less accessible to those who need it most
• Particular impact on rural communities where alternative youth activities are very limited
Broader social impact:
• Scout groups from outside Wales deterred from visiting due to increased costs
• Weakening of community-based much needed youth work organisations providing essential services
• A reduction in affordable residential facilities for school groups and other youth groups
• Reduced participation in activities that build confidence, resilience and independence, much needed life skills for future employment.
• Diminished opportunities for environmental education and sustainability awareness
(We would be grateful if you could keep your answer to around 500 words).
While the financial assessment highlights the potential for increased revenue, it is unclear if small organisations such as Scouts, who charge nominal fees for overnight stays, were considered.
The statement in the Bill that 'The levy will represent a small proportion of a visitor’s overall spend'. Is clearly not the case for scouts paying £3 for a sleepover experience in a hall within their local community.
We believe the assessment underestimates the impact on small, volunteer-run, and low-cost providers, particularly those, where providing accommodation is not their primary purpose.
The costs of compliance, especially for non-profit organisations, and the inequity of a flat-rate levy are not sufficiently addressed. Additionally, there is limited discussion of how funds will be transparently managed and reinvested within local communities.
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).
The balance of information between the face of the Bill and subordinate legislation raises significant concerns, particularly for non-profit, volunteer-run youth organisations like ScoutsCymru.
The Bill's current framework lacks sufficient detail regarding exemptions and considerations for non-profit, volunteer-led accommodation providers where overnight stays are not their primary purpose.
While flexibility through subordinate legislation is important, core protections and exemptions should be established in the primary legislation rather than left to ministerial discretion. The current approach creates uncertainty for non-profit, volunteer-run facilities like Scout halls that operate on minimal budgets with limited administrative capacity.
Now more than ever we need to protect essential youth development services and programmes, therefore a more detailed criteria and exemptions should be specified in the primary legislation rather than delegated to subordinate legislation.
(We would be grateful if you could keep your answer to around 500 words).
In our view the bill does not accurately reflect the diversity and unique needs of all of the varying types of accommodation providers in Wales, nor does it appropriately consider the capacity of all of them to deliver revenue via the visitor levy.
(We would be grateful if you could keep your answer to around 500 words).
The additional provisions for registration and enforcement, particularly the number and severity of the penalties suggested, are very concerning and do not consider the administrative burden the Bill places on small, non-profit, low cost, volunteer managed accommodations.
The proposed 30-day window for returns and payments, demonstrates a clear lack of understanding of volunteer-run organisations' operational realities.
Imposing registration and enforcement provisions as outlined in the statement of policy intent, could have the unintended consequence of forcing some small providers, particularly those where accommodation is not the primary purpose, such as Scout Hall and Community centres, to cease offering this facility permanently.
(We would be grateful if you could keep your answer to around 500 words).
The Bill needs to include specific exemptions that recognise the unique nature of small but vital non-profit, volunteer-run youth facilities and ensure their sustainability for future generations.
We are calling for the following exemptions:
Primary purpose: Facilities whose primary purpose is not accommodation provision, for example, Scout halls and huts, church and community halls when used for sleep overs and camping. We are asking that these type of facilities are excluded from the Bill.
Children and Young People: The negative impact of this bill on young people and types of accommodation specifically catering to young people, are likely to be considerable. We ask that the decision to include children within the scope of the levy be reconsidered, and for those under the age of 18 to be excluded in all instances.
We also ask that facilities that are for the sole purpose of delivering youth services or accommodation to young people under 18 years be excluded from the Bill.
Administrative and financial burden: We are 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 non-profit, volunteer-run accommodations, then we would like administrative processes to be made as easy as possible for non-commercial accommodations, with limited IT infrastructure, and for reporting windows to follow the convention set by existing charity commission rules.
These exemptions would protect vital youth services while having minimal impact on the Bill's revenue objectives, as these facilities often do not provide accommodation as their primary purpose, currently charge minimal fees and have low environmental impact.
It is crucial that the Welsh Government acknowledges that a distinction needs to be made between commercial visitor tourism operations and small volunteer led community-based, non-profit organisations providing essential services and facilities for outdoor experiences and appreciation of the Welsh Countryside.
The benefits of the Scouting adventure, are well-known, and I am sure that it is not Welsh Governments intention, to place these vital development opportunities for future generations of young people of Wales at risk.