Statutory registration of accommodation businesses

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While we are still awaiting detail of the long-promised consultation in England of statutory registration, Visit Wales announced today the Welsh Government’s consultation on statutory registration or licencing. In the Visit Wales case the consultation appears to a more targeted affair conducted by consultants interviewing identified stakeholder groups rather than an open public consultation(?). As every when it comes to activities of this significance, I maintain that colleagues in the different home nations should at least be aware of what’s going on over borders that, for the visitor at least, can often be meaningless, and that there are always transferable lessons to be learnt. The outline can be seen at: News Bulletin: Establishing a statutory registration or licensing scheme for holiday accommodation operators in Wales (

In this case I am slightly puzzled by the reference in the Visit Wales text to “amateur accommodation operators”. I may be entirely wrong but in 30 years of working in the industry I can only recall ever hearing that term used twice: once today and once in the rather grandly titled Airbnb short-term lets registration “white paper” quietly published in June of this year.

Again I may be off track but I am extremely dubious about us all inadvertently accepting, without question, that an amateur status does, should or could be accepted in the provision of paid for accommodation, unless it is an already firmly establish principle that I am just unaware of? For example, I am reasonably reasonable sure that we wouldn’t readily accept the creation of a category of say: amateur taxi driver or amateur publican on the basis that these “amateurs”, however defined, don’t trade with the general public that often or on that large a scale and therefore it is a bit too much of a faff applying the legislative and regulatory controls deemed necessary for, “professionals”, in the rest of the regulated industry. To me this seems like a very slippery slope towards woolly definitions and more, albeit different, opportunities for abuse and confusion at the fringes. If you trade in a regulated area, then surely you should be regulated whether you then chose to trade a little or a lot? Ultimately that your choice and your customers are no more or no less entitled to the same level of regulatory protection as anyone else’s in what is for the customer at least exactly the same circumstances.

Whether you are responding to the consultation in Wales or waiting for the consultation in England it might be a good time to acquaint yourselves with light touch proposal already put forward by Airbnb for short-term let sector and by default potential for all other accommodation providers. Airbnb have a reasonably well-established reputation for resisting regulatory control for as long as possible and when it looks like it is all but inevitable using their not insubstantial recourses to try an minimise the impact. This may not be the case this time, however, whilst all very plausible the “white paper” does appear to propose a very light touch approach that reinforces the principle that whatever happen the liabilities don’t lie with the platform provider. Again, I may be wrong but by publishing the white paper well in advance of the consultation and framing it in the way that they have that there is already a danger there proposals becoming the default starting point for an “industry lead” solution. Whether I am right or not about this, I do think that colleagues should at least read it and drawing their own conclusions before they look to respond to any formal government consultations, now or in future months. You can find the Airbnb paper listed under the research & statistics – by year, menu tab or go direct to the page at:

I would welcome thoughts and direction from members for use in a response to either or both consolations.


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