The DCMS’s call for evidence on the development of a tourism accommodation registration scheme in England closes today 21 Sep 22. There is still time, just, to get a brief online response submitted and/or a slim possibility given the recent momentous events and there impacts on administrative activities, some potential leeway on online or emailed replies. No guarantee but a possibility nonetheless.
The British Destinations response can now be found on our original consultation website page at: https://britishdestinations.net/consultation-responses/open-consultations/developing-a-tourist-accommodation-registration-scheme-in-england-closing-12-sep-22/
As is often our way we have taken the opportunity to submit a far more detailed, long and wide ranging set of comments in the hope that some or all may lodge. Each comment is designed to be used or quoted standing on its own if necessary without reference to the whole response. Among the comments and opinion expressed the most critical are: the lack of visibility and consequential lack of guaranteed regulatory compliance are a reputational disaster in waiting, the blame for which in changed circumstances will now fall at HMG’s door. Airbnb’s concept of amateur provision is a dangerous nonsense as is there proposal to automatically issue registration numbers on the basis of the completion of a simple self-assessment online registration. User reviews have no part to play in ensuring regulatory safety compliance and the public rightly already assume we have a first world first-rate regulatory system and means of ensuring compliance before anyone may trade. Visibility and transparency is key and the current sharing economy accommodation sector’s deliberately opaque business model must now be effectively tackled to avoid an now increasingly overdue reputational disaster. The established accommodation industry is not itself without fault and there is an opportunity and need and a for the first time a wider acceptance amongst them to expand the proposed scheme to all providers.
We have reluctantly given caveated support for a registration scheme with light check, but indicated that licensing scheme is probably what is actually needed.