Statutory accommodation scheme update
The Welsh Government are undertaking the final consultation on their proposed statutory licencing scheme currently aimed at all accommodation types operating in Wales and not simply “short-term lets”. The approach proposed is far more robust than a simple registration scheme which, in the view of some, is little more than a list of those operating, with the weak sanction of potentially being removed from it, in the event of serious, proven failings.
The Welsh Government’s approach unashamedly aims to create a level playing field for all provides and offers consistent assurance to consumers in order to address issues surrounding standards in accommodation provision, whilst also helping to manage the wider impacts of short-term lets on housing and on host communities. Proposals include; the provision of evidence of conformity to various, mainly safety, provisions before the renewable licence to trade is first issued, backed by a proposed 1:50 confirmatory inspection regime.
The consultation and proposal will be of direct interest to members in Wales, to consumers living in, or visiting Wales. Beyond that it further informs the ongoing debate about DCMS’s, potentially quite different, proposed approach in England that we are still expecting to be published for consultation later this calendar year. The consultation also includes a useful annex summarising the current position in the other home nations and the approach used in the Channel Isles and Isle of Man
Even if you do not intend to respond, it is worth reading the short 36-page consultation to understand the proposed direction and rational being applied to the visitor accommodation sectors in Wales. Clearly, the proposals may be adjusted as a consequence of the comments received. However, having started from a relative robust position, the final version adopted is likely to be a long way from, for example, the ultra-light touch, self-assessed, instantaneous issue of a registration number proposed and subsequently widely promoted in the Airbnb “white paper” on the subject.
My view remains that whatever scheme is adopted, or not in Wales or England, it needs to meaningfully address all the main known issues It must, at all costs, also avoid unintentionally (?) reinforcing the entirely reasonable and widely held but erroneous public view that all commercial accommodation already must conform to the highest possible standards to trade, something achieved through the application of an existing, robust and well enforced system. The fact that that isn’t true is a potential national scandal, or will be the day after those failing are publicly exposed by some small but particularly unpleasant or some shockingly large incident, as they will inevitably be, unless and until Governments block old and more recently created loopholes.
Personally, I applaud the Welsh Government for taking the opportunity to apply their approach to all accommodation which has the advantage of genuinely levelling the playing field, establishing genuine consistency and dealing with potential problems in other established sectors which are not necessarily all operating without omissions or within the expected standard. I also tend towards supporting the argument for licencing rather than simple registration but I also appreciate others might not. Better to aim high and ease off later as necessary than aim low and find soon after that you have failed to actual achieve the intended objectives.
The consultation for Wales, open to all, closes on 17 March: https://www.gov.wales/sites/default/files/consultations/2022-12/consultation-document-statutory-licensing-scheme-for-all-visitor-accommodation-providers-in-wales.pdf
British Destinations 
March 2, 2023 at 1:50 pm
[…] Destination managers can help the nudge campaign and help local businesses by making sure that those short-term, holiday let owners they have dealings with are made aware of the changed and changing circumstance. That of course isn’t always as easily done as it sounds, because as we all know, only too well, this is a developing sector that now involve a multitude of new players, many of whom have tended to operate below the local (and national) radar, for various reasons, not least f which is that they can and there no “rules” to discourage it. Hence, in part the perceived and increasingly urgent need for, at the very bare minimum, a national registration scheme for England, if not a full statutory licencing scheme of the likes of that currently proposed for Wales. […]