Accommodation registration in England, new review of the British Tourism Authority (BTA [= VB and VE]) and the latest Tourism Minister

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1. In last week’s update I recirculated the Tourism Alliance policy paper on accommodation registration ahead of the looming 7 June consultation deadline (https://britishdestinations.net/2023/05/18/updates-and-news-items/). The policy paper sets out the agreed policy headlines and gives some pointers to how those agreeing with the stance taken, may wish to respond but is light on the detail arguments to be presented. On reflection I should have also distribute the complimentary Tourism Alliance analysis and briefing documents which goes into more detail on the rational behind the policy direction and picks up on the some of the key points and arguments. Critical among these are the points made in support widening the scheme to include all accommodation provision, in order to eliminate a myriad of potential loophole created by DCMS’s proposal to included only short-term letting properties.

It would seem that HMG/DCMS are not aware of the problem of loopholes at the fringes, nor have they been presented with any compelling evidence to suggest that any part of the established accommodation industry might be operation outside current regulation and rules. If the scheme is to be amended to include all accommodation, the need and reasons for doing so will have to be very strongly evidenced. With hindsight the case for introducing registration has been made largely off the back of a need to level the playing field, without necessarily referencing the fact that there may be some poor standards and poor practices already in play in the established market: Statutory_registration_for_short_term_lets_briefing_and_analysis_for_members.pdf (mcusercontent.com).

2. Last Thursday HMG announced the commencement of a second stage review into performance of the the British Tourism Authority. “The review is looking at how the operator of national tourist boards VisitEngland and VisitBritain support places across Great Britain to develop and market high-quality tourist offerings, create jobs in the sector and boost the economy”. Currently the detail available is confined to outline terms of reference, the name and credentials of lead independent reviewer but very little more yet about the how this review will be conducted. This will doubtless follow soon, now that Emir Feisal has been appointed. More at: Review of British Tourist Authority underway – GOV.UK (www.gov.uk) and Debate: Announcing the Public Body Review of the British Tourist Authority – 18th May 2023 (parallelparliament.co.uk).

3. The announcement of the review in Parliament was one of the first substantive acts of the latest tourism Minister, Sir John Whittingdale who, in fairness to all concerned has only taken on the roll as maternity cover for Julie Lopez who it is widely assumed will return to post at some point before the General Election (no later than 23 Jan 25). Sir John is well qualified to fill the post having held DCMS ministerial positions during 2020-21, including tourism and was perhaps more significantly he was Secretary of |State for DCMS in 2015-16.

Coincidently, Sir John was the Secretary of State during the implementation of the last major review of BTA- VB/VE. It was during his tenure as Secretary of State that rather than creating an independent and strengthened VE, as recommended by the independent review, VE was instead reversed back into VB as a department within it. As part of that process the role of managing and marketing domestic tourism was largely (totally?) dropped in favour of a limited remit to manage international visitors to England and develop product that had appeal primarily to the international market. The decision was heavily criticised at the time as a retrograde step that leaves much of the market and much of the industry unsupported.

That is all now water under the bridge. Nonetheless, it is a useful reminder that high level reviews of efficiency and value for public money seldom result in more resource and better outcomes. With that in mind we would all be well advised to jointly think long and hard about how we ensure that we retain and maintain what we currently have, rather than wishing forlornly for more done radically differently. A wish that could inadvertently risk helping HMT cases to further denude tourism support for both the international inbound and domestic markets. More on the review will hopefully follow soon. At which point we can discuss in far greater detail what should or should not be said, assuming of course that the review allows for us to contribute views.


Updates and news items.

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1.  Tourism data. After attending the excellent Tourism Alliance Insights Conference on 23 March, I promised to circulate further detail of two offers of access to commercial data made during the event.  The slide pack, previously circulated, is at: TA_440_473.pdf (tourismalliance.com) . If you have yet to find time to look at it there is much that is still of immediate relevance and interest, particularly I would suggest the information from VisitEngland, ETAO, TripAdvisor and Barclays. 

If you wish to receive monthly hospitality spending updates from Barclays register your details with them via the email: contact-mci@barclays.com (CC in any other you wish to receive the information and they will be added to the distribution automatically).

Unfortunately it transpires that while TripAdvisor are keen to investigate how their commercially sensitive and valuable data can be made more widely available at a national level, this not unreasonably falls short of an offer to give wider open access to all as I had thought.  I did think at the time that what I and others thought we had heard was too good to be true.  Apologies for any misunderstanding or for getting anyone’s hope up.  With luck and a fair wind, this and other commercial data of this type will be made available and used to inform and extend higher level national and regional statistics, data and tourism and visitor economy intelligence.  On reflection that would be as, if not more useful than having direct access to the headline data at the local operational level.

2. Joint annual conference. If you have not done so yet please diary the date of the annual joint Tourism Alliance, Tourism Society and British Destinations’ Annual Conference to be held in London on Tuesday 19 September. As ever the event will cover a range of key strategic and operational issues and bring together a very wide church of industry representatives making it an excellent opportunity to widen your view and to meet and make valuable contact industry contacts. British Destinations main sponsor for this and other activities remains or colleagues in Quality in Tourism.

3. DCMS and DLUHC consultations. The deadline for responses to the DCMS accommodation registration scheme and parallel but linked DLUHC short-term let class orders/planning consultation are now looming (7 June). It would be useful if as many industry interests respond to both and vital that as many as possible respond to the DCMS consultation. It is entirely possible that the views, for or against the various options proposed and any additional thoughts and comments, some of which may be critical to the shape of any scheme adopted, may simply be counted, rather than the validity of the content and the status of the organisation making it, often on then behalf of others, weighed.

Our initial comment and general background on both consultations can be found at: https://britishdestinations.net/2023/04/13/consultation-on-a-registration-scheme-for-short-term-lets-in-england/

In the intervening weeks a Tourism Alliance working group (including ourselves) has developed a short policy statement on the desired shape of a statutory scheme in England.  Destinations and your own local stakeholders may find this useful in helping develop your own positions and comments for the any consultation response to DCMS: https://britishdestinations.files.wordpress.com/2023/05/tourism-alliance-statutory-registration-working-group-final-1.pdf

4. Trains and transport issues. On a completely different tack and while not wishing to overload this update, members might like to note two potentially significant event relating to the restructuring of Great British Railways, that that could easily have passed you by, unless the events were specific to your own particular region or indeed impacted directly on your own regular journeys.

 The first is the two-day closure last week of the East Coast mainline for large scale repairs.  Not a major event in its own right, until you realise that this was the first major short closure conducted mid non- holiday week since c 2014 and the full return to state control of Network Rail which then quietly reimposed the policy of deliberately targeting all major short works for weekends, public holidays and longer works for public holidays and half-term or summer school holiday periods. Prior to 2014 such mid-week or non-holiday period closures were rare but not outlawed as a matter of deliberate public policy as they have been in recent years.  The recent closure has been headlined as a trial of concept and justified on grounds of dramatically changed travel patterns, revenue profiles and consequently business planning for rail operators and infrastructure management.  It doesn’t mean that the policy of targeting peak leisure periods for closures has gone for good, yet but it does mean that there is movement towards achieving that long lobbied for goal which we can now all continue to press for, off the back of the East Coast mainline trial. 

The second piece of recent news is return of the Arriva-run, ultimately German state railways owned, Northern Rail franchise to state control.  Northern Rail joins LNER under the control of the “rail operate of last resort” with, it is suggested, up to a further half-dozen private sector train operating companies (TOCs) in serious danger of following suite.  Meanwhile the strategic review of the UK rail operations has been completed and lodged with DoT but its findings have yet to be published.  However unpalatable some may find the prospect of greater state ownership and state control of the railways, the realities and practicalities do suggest that the current private sector franchise system in its current form, is running out of steam, if not in places fallen off the tracks? 

The publication of the review and the Government’s response to it will be critical in informing the future strategic and operational direction for the railways and by inference for public transport strategy and policy in general. By default, that means it is also critical for significant parts of tourism and leisure industries as constituted now and as necessarily reconstituted in future to accommodate changes to railways and rail delivery and, in parallel, the as yet ill-defined challenges presented by equally ill-defined changes to road transport and private car ownership and usage.  I can’t help thinking the old British Rail advertising slogan “let the train take the strain” might have rather more strategic relevance than was ever original intended?

5. Water companies and the environment. And finally; today’s unprecedented public apology from the water companies and the associated promise of £10bn of extra (?) spending on putting things right that are seriously wrong in the UK’s sewage disposal system doesn’t mark an end to the matter (as they may hope?).  Nor sadly does it necessarily signal a rapid improvement to the quality of the UK’s riverine, lake and coastal waters, most of which play an important part in the visitor economy of many coastal and inland communities.  Such improvements are hugely costly and time consuming, which in my estimation is probably why in some instances the companies, potentially aided and abetted by successive Government’s policies, have avoided making them sooner. 

To be frank the state of affairs is at best not far short of a national scandal, which despite the distracting and arguably somewhat belated cries of “mea culpa”, is now likely to continue to run for many years to come. That’s a problem entirely of their own making for the water industry but also a major problem for us in “tourism”.  We already know from years of point location coastal bathing waters management, that ultimately the wider public’s perception and understanding of such issues tends to focuses on their own consumer usage of and increasingly wide spread interaction with, bodies of water.   For all practical purposes this means its use as a visitor attraction and as a leisure asset and not as something you drink or use at home for multiple purposes. While the water companies may take the blame for environmental damage and happily pass the bill to put wrongs right to their customers, it’s the entirely innocent destinations, their attraction and water-based attractions and local businesses of all types that will bear much of the ongoing collateral damage. By whom and how is that going to be put right?

They say they are hard to polish, but I think in the circumstances it not going too far to make the crude but hopefully memorable point that they are even harder to sell as a positive, occasional addition to your local body of eaux naturelles and as a consequence to general appeal and attractiveness of any destination, in a highly competitive, UK domestic and outbound market. Are the water companies truly sorry enough to make recompense for the past harm knowingly done, or to make amends for harm the are fully aware is yet to be done during the protracted period while they put remedial measures in place.  I think not, but it is something to contemplate, if not to ask of them and of Government?

Short-term let registration consultation in England, Tourism Alliance response paper and webinar 10 May 23.

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A Tourism Alliance working group made up of a number of trade associations and other interested parties, including British Destinations, has produced an initial policy response paper to the DCMS consultation on the registration of short-term lets in England. The paper will form the basis for the Alliance’s response and may help inform the views and responses of others including our own. That paper will be available for circulation shortly.

Meanwhile a Tourism Alliance Webinar has been arranged for 10 to 11 am Wednesday 10 May to brief as many Tourism Alliance members and their member’s members, on the stance adopted by the Alliance and by inference being recommended for consideration by others. The Webinar will include opportunities for Q &A.

I would encourage as many British Destination members as possible take part in the Webinar in order to inform your own thinking and views and to allow you to consider whether to promote the position paper locally among your own members, stakeholders and leading businesses.

You need to register in advance for the free event at: Microsoft Virtual Events Powered by Teams

The Tourism Alliance paper relates to the DCMS registration consultation only and not to the separate but related DLUC consultation on proposed changes to short-term let planning classes. Further work is being undertaken on the potential responses to the latter, which is somewhat more complex and therefore potentially more contentious, particularly when debated across what is a broad tourism church. Both consultations close on 7 June. More detail on both can be found at:

Further and Higher Education for Tourism Hospitality and Events policy direction.

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Colleagues within The Association for Tourism in Higher Education (ATHE), working in partnership with The Council for Hospitality Management Education (CHME) and The Association for Event Management Education (AEME) have produced an Open Letter to government which responds to policy changes affecting Further and Higher Education (FE and HE) in the UK.

They are jointly seeking to extend the number of organisation and individuals co-signing the letter, via the mechanism of a Change.org online petition, before then presenting the letter, duly supported, to relevant departments within the Westminster Government for their consideration.

Regardless of whether as an individual or as an organisation you are able to add your signature, the matters raised in it are I think concerning. Particularly so, because what happens in FE and HE in respect of Tourism. Hospitality and Events (THE) sectors in the future, as a result of changed and changing policy now, will not be something that is necessarily centre and foremost on the minds of the majority of current practitioner. However, if nothing is done to consider revising the new policy direction and done soon, it could (will?) have potentially serious downstream consequences for us all professionally, for the “industry” as a whole and for the visitor economies that we jointly work so hard to foster.

If nothing else, the open letter represents a timely and useful briefing note on, or for some a reminder of, a looming issues in FE and HE, provision for THE, even if for whatever reason, you subsequently find you or our organisation are unable to sign it. Hopefully, having consider the content, at least some of you will be able to sign to add weight to the campaign for revision.

Meanwhile, I will take member’s advice on whether to sign on behalf of British Destinations, or failing that individual in my personal capacity as a long-serving tourism professional. If any member has any views for or against me signing on behalf of the association, then please let me know, preferably by return.

The text of the notification, including the link to the open letter, I receive reads:

The Association for Tourism in Higher Education (ATHE), working in partnership with The Council for Hospitality Management Education (CHME) and The Association for Event Management Education (AEME) have produced an Open Letter to government which responds to policy changes affecting Further and Higher Education in the UK. The letter, which highlights the importance and value of tourism, hospitality and events to the economy, sets out six points which we are asking Government to consider. We would like to ask colleagues to sign and support this letter, and to share it more widely.

The Letter can be found here – https://chng.it/5L6TN2rxhJ

This Letter forms part of a suite of activity the three Subject Associations are working on, in partnership with colleagues from across our industries (too many to mention here) which also include a research commission into the value, volume, impact and trajectory for FE and HE for Tourism, Hospitality and Events, and will culminate with a conference in October 2023, to which you will all be invited. I will also just highlight the work that Claire Steiner at The Institute of Travel and Tourism is leading on around FE qualifications specifically which will form a part of the conference in October.

If you could share this letter with your networks, we will, once we have a reasonable number of signatures, circulate this to DCMS, BEIS, DfE and our media contacts and other stakeholders. This activity will be a precursor to the October conference.

Best regards,


Dr Peter Robinson PhD, PGCert, MA, BA (Hons), FTMI, F.Inst.TT, MTS, PFHEA Head of the Centre for Tourism and Hospitality Management
School of Events, Tourism and Hospitality Management

Leeds Beckett University, G04 Macaulay Hall
Headingley Campus, Leeds LS6 3QW
Email: peter.robinson@leedsbeckett.ac.uk
Tel: 0113 81 24497

Consultation on a registration scheme for short-term lets in England

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The DCMS consultation on the next stages of an accommodation registration scheme in England was issued last night alongside a parallel DLUHC consultation on a potential change to the planning use class for short-term lets in England. Closing on 7 June, both have great significance for tourism and the visitor economy.  I would urge anyone with an interest in the outcome for local and national tourism to address them both and to do so mindful of the impact that each has on the other.

First thing to say is that no one should underestimate the likely level of difficulty faced by Minister and officials in getting proposals to introduce any new or additional “regulation” to this point given the current administrations natural leaning towards small government, minimal regulation and a free market approach.  DCMS have done well and should be congratulated on their tenacity to date and now given every reasonable assistance to help get the best possible scheme available in the circumstances over the line.  That should not preclude us being constructively critical where it is justified, or stop us from proposing necessary changes to the scope of what is on the table, particularly where it might avoid entirely predictable failings or adds major gains, for marginal penalties.  

When you read the proposals and the associated questions, I know from several years of debating this subject that there will be considerable disappointment and associated concerns for many destination managers. For example, the consultation is explicitly about a registration scheme for short-terms lets only. Thus, arguably it misses the opportunity to genuinely level the playing field (not all those operating in the traditional accommodation sectors are saints) and potentially opens up loopholes at the occasional letting end of short-term let market and especially, some major loopholes in the grey, ill-defined areas between short-term lets, B&Bs, guesthouses and smaller hotels.  An area that we are only to aware that is already becoming increasingly muddied by the advent of new technology, new practices new routes to market and the blurring of lines between serviced and non-serviced provision.

The options given within and between the 24 questions posed are wide ranging and ask for views on a scheme that could be entirely self-assed with very few checks and balances or far more ordered and methodical.  We are also asked view on things like what might constitute a breach of the rules and what the penalties for such breaches might look like. Other radical options include a scheme that might only be adopted by individual local authorities, if they so wished, to one that is mandated nationally. In their totality the overall scope of the options given are somewhat more limited than perhaps many of us might have wished?  However, in combination within the parameters given, they still allow room for a number of potentially very different outcomes. You will only get a proper sense  of this once you have read and digested the full document (s) (sorry no shortcuts on this one).

At this early stage I already think it is vital that as many destination management organisations and their stakeholder as possible respond to both consultations. However, other than starting to considering how that might be done by whom and by when, I also think we all need to pause take stock, find time to read both consultations and probably do that more than once. Then perhaps we can consider sharing initial thoughts over the next few days and weeks with a view to developing some shared thoughts for inclusion in any individual and joint responses we feel the need to submit.

The DCMS consultation which includes within it a link to the DLUHC consultation is at:


The DHLUC consultation itself is at:


Anti Social Behaviour Action Plan (England and Wales) – implications for short-term lets and much more?

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1. You may have seen or heard reports of yesterday’s announcement by the PM and Home Secretary regarding plans to “crackdown” on anti-social behaviour in both England and Wales.  Today there has been a lot of mainstream and industry media comment referencing plans to tackling such behaviours in “Airbnb” or more accurately short-term letting properties. Finding the source reference, beyond the PM’s well publicised response to a question from a member of the public in yesterday’s press conference, essentially about their problems with what we would classify as a “party house”, isn’t as simple as googling a few key words. 

In case you having the same problem finding it as I did, the full plan, largely a series of proposals still to be refined and implemented overtime and subject to all the usual vagaries of agreement, consent and Westminster Parliamentary and Welsh Government  process, can be found at: https://www.gov.uk/government/publications/anti-social-behaviour-action-plan/anti-social-behaviour-action-plan

The reference to short-term letting in England (the Welsh Government are ahead of England in this area) can be found at para 31 f).   The paragraph is all but lost in a much bigger chapter, paras 28 to 33 on “evicting anti-social tenants”.   It is so short I am can easily reproduce it here but you might, at some point, like to read it in the context of the full chapter? :

f) preventing short-term lets importing anti-social behaviour into communities, such as noise problems or drunken and disorderly behaviour. We will do this by setting up a new registration scheme giving local authorities the data to easily identify short-term lets in their area. If a let proves problematic, they can take action against guests and owners. We will publish a consultation on the registration scheme shortly.

If there was ever any doubt, the inclusion of the ongoing proposals for the registration of short-term letting within this much more high-profile and more mainstream policy area, makes it all but certain, that registration, in some form, will now go ahead in England (catching up with Wales). Albeit the impetus for doing so in England may well just have shifted away, in part at least, from our association’s main focus on the universal provision of safe, clean and legal visitor accommodation?   

It remains likely that the options to be offered in the long awaited DCMS, hopefully final (?) consultation, will lean towards a light touch registration scheme. From a destination management prospective, at least, the key is to ensure that the solution adopted is not so light touch that it simply serves to sanctions and give official credibility to the current chaotic and largely unregulated and unchecked provision. Joe Public, on the whole rightly assume it is already registered/licenced and thoroughly controlled and this process therefore should be all about making reality match the existing, realistic public perception.  Whatever we end up with must be easily implemented, yet robust enough to be effective in achieving a range of entirely reasonable aims, not least of which are the guarantee of safe, legal and preferably clean provision of visitor accommodation.

We now all await DCMS’s consultation/proposal document.

2. Again from the prospective of destination management there also a rash of other areas of significant direct, or tangential interests, within the proposals, including tackling anti-social littering and graffiti paras 36 b) to 43, anti-social elements of rough sleeping and associated issues 44 to 45 and new proposals for tackling (seizing and using for short-term productive usage) empty shop and other properties 59 to 64. Other parts of the plan may also be of interest.

Lots of “good ideas” here but I already sense, even before anyone has replied to me, that while welcoming the initiative being demonstrated, some colleagues are likely to have immediate and potentially justifiable concerns over application, practicality and implementation thereof.  

Few of the proposals are oven ready, some are to be piloted or are to be funded in selected areas where problems are deemed to be particularly severe. I suspect that there a lot, lot more water yet to go under the bridge before some or all of these proposals actually start to impact, and do so everywhere.

That in itself has its challenges. Among the most worry of which is the likely popular presumption that these high-profile new powers are, or will be place, everywhere soon.  When things don’t appear to be improving, it will be local agencies, including local Council’s and wider destination management interests and not Central Government, that are routinely accused of dragging their feet, when in fact they individually or jointly may not have either the authority and/or the resource necessary to implement this generally populist new policy direction.  Both the public and indeed those expected to implement some of these policies need to learn a great deal more about the detail and, in particular, where and when it may or may not apply, before any firm views can be taken about the effectiveness and the improvement likely to result in their own localities.

Quick up date and one substantive issue

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Yesterday I attended the Tourism Alliance Insight Conference, followed by the English Tourism Week Parliamentary reception. It was an excellent data and tourism intelligence focused conference and a useful subsequent networking event, both attended by a small number of destination managers and few representatives from a couple of the larger destination area marketing partnership, plus a much larger number from a broad cross-section of  industry players and tourism and leisure industry representative bodies. 

I am hoping that the level of attendance from the “DMOs” was more reflective of the time of year and budget cycle (very last gasps of the financial year for many), rather than reflective of the pressures on limited discretionary budgets or just budgets full stop.  Selfishly I keen to seen a good levels of destination management and marketing representation at the Tourism Alliance, Tourism Society British Destination Annual conference to be held later this year, post season being my recommendation.  The detail and specifically the date of which is yet to be agreed by the triumvirate.  Please ink the event in to the 2023/24 budget now and the diary it as soon as we can confirm the date.

Having said that I hope budgets for 2023/24 aren’t a major issue, or at least no more than normal, I am acutely aware that a couple of destination management and/or destination marketing organisations are between a rock and a very hard place with regard to this coming financial year.  What I am not aware of is whether its only a couple and whether those that I am aware of now, or might become aware as a result of this note, wish me to represent concern about continuing funding difficulties too openly or at what level. I am a tuned to the fact that from a local perspective making difficulties too obvious or too public, too soon to local partners and businesses can precipitate the very things you seek to avoid.  If you are having a particularly hard time, please let me know and also let me know if you are happy for that to be flag up just as a generality or as a named specific case.

As to the insights conference itself, it genuinely contained many timely insights, some of more significance than others. As you would expect of me by now, when I do get the slide pack (still awaited) rather than just sending it out, as is, I will do a bit of a synopsis, point out the highlight and any short cuts to getting to the meat of the matters at hand.  That might take a day or two but it will hopefully be worth the extra wait.  Highlights for me already, included a seemingly open ended offers from both TripAdvisor and Barclays to share their always very current tourism and visitor economy data and intelligence with the wider industry.  That I think is more significant than it might at first sound.  I will certainly be telling you how to sign up for that and/or making sure it is embedded somehow into our research and statistic library.   More on the statistics piece next week.

There were a number of big-ticket items aired at the fringes and nuggets dropped in conversation. Most will wait for a while longer or need more work doing on them. The one issue I do want to address and do so now is the one nobody else seems, probably for good reason, to want to raise anywhere too publicly.  So, I guess if no one else will, it falls to me to air the tourism impacts of asylum seekers and hotel usage.  It was not addressed by anyone officially but was discussed without prompting by a good half dozen plus individual with me at the fringes over the course of the full day, including a very senior national tourist board representative. 

Stripping away all the rightly difficult and emotive issue and concerns, and looking purely from a tourism perspective, I think it safe to say everyone who needs to understand within the immediate upper sphere of tourism already recognises that placing non-economically active asylum seekers in to hotels isn’t necessarily a very good idea. But not everyone has the same broad understand of why that might be or the specifics of the impact of seemingly similar usage in differing locations. With that in mind, we can’t be sure that the Home Office, and No 10, the ones who really do need to understand and be persuaded, do either.

For the avoidance of doubt let me rehearse tourism arguments as I understand them:

While filling a hotel with a guaranteed 100% occupancy for a guaranteed period at good rates, with minimal, if any staffing requirement (and guaranteed post contract refurbishment?) might be very good news for a potentially struggling hotel owner or operator, it seldom if ever equates to “good news for tourism” as the uninitiated might very easily erroneously assume. The notion that what is good for an individual hotelier must by default always be good for tourism still needs to be challenged. Indeed, for tourism and the wider visitor economy prospective there will almost certainly be some harm ranging from very little to significant harm, dependent largely on the nature of the usual target market for the hotel and critically the nature of its locality.   

Replacing economically active visitor who have discretionary disposable income, directly with economically inactive individuals who have little or no disposable income and no legal means of generating any, may well have little wider impact on the visitor economy adjacent to, for example, a ubiquitous “bed shed” on the fringe of an industrial estate by the ring road at the edge of a town or city. Doing seemingly much the same thing, in or near the centre of a historic, heritage or market town or city, or in a major seaside resort destination is a very different matter. 

In the latter examples the very act of replacing individual who are there often with the express purpose of spending within the local destination economy, with those who can’t spend anything, is tantamount to Government acting to close the hotels concerned and arbitrarily reducing the destinations staying visitor capacity by edict. And that is before any other considerations and indirect impacts on tourism and the visitor economy are taken into account. Doing so during the off season is questionable, doing so now in the run up to, during or throughout the fast-approaching main season is deplorable and is little short of government funded and directed, economic sabotage.

While it is fully accepted that the Home Office and Government more generally, have little practical alternative but to seek hotel accommodation in the current circumstance, in doing so they, or their contractors must carefully consider and take due regard to where those hotels are situated, the nature of the normal trade and most importantly of all the likely impact on any significant established visitor economy within the locality.  Those place to avoid should be utterly obvious: the well-established inland and coastal visitor destinations, of which there are many.  Those places to target may be less obvious and harder to easily identify but they do number in their thousands.  The process of identifying hotels with no significant associated local economy, could be greatly assisted by the creation of some basic but clear criteria, if indeed these do not already exist. Something we do need to establish as a mater of some urgency is by what criteria do the Home Office currently select hotels and critically their locations? I can’t help thinking tourism and visitor economy probably don’t feature.

If Government does not take steps to avoid further use of accommodation in “popular destinations” the absurdity of most of Government working to support the recovery within the visitor economy, post-covid and investing significant sums to drive new growth in many established destinations, while the Home Office beavers away independently undermining both recovery and growth in other destinations and on occasions concurrently in the self-same destinations.  Highlighting the lack of joined up policy, involving a sensitive and contentious subject like asylum seekers, is not a route down which any destination individually or jointly would willingly wish to go.  Nonetheless, it remains an option of last resort in the resorts and destination’s lobbying tool box.

Any views on the above subject are welcome.  If there is sufficient demand, I am happy to call an informal discussion on the mattes raised and to help bottom out individual destination’s views.

New Minister, new opportunities for domestic tourism?

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1. If you have not already heard the good news, Julia Lopez MP was appointed on 7 March as Minister of State for Media, Tourism and Creative Industries within the recently (7 Feb 23) restructured Department for Culture, Media and Sport (DCMS).  MP for Hornchurch and Upminster in Greater London since 2017, Julia first joined DCMS in 2021 as Minister of State for Media, Data and Digital Infrastructure. With the exception of a brief break in 2022, this was a post and portfolio she held until this week.  The Minister of State’s revised portfolio, and tourism’s inclusion now within it, in practice means an increase in tourism’s profile within DCMS and Government in general.  Tourism has traditionally sat within the portfolio of one of the Parliamentary Under Secretaries and not with the Minister of State who as you will appreciate is second only in the Department to the Secretary of State.

You may have also noticed that Julia was appointed as a Minister of State at the newly created Department for Science, Innovation and Technology (DSIT) on the same day. Dual departmental appointments are not unusual. The responsibilities for the newly created role have yet been publicly announced but it is a reasonable assumption that these are likely to relate to some or all of the Minister’s previous responsibilities for data and digital, recently spun off out of DCMS and into the new DSIT.  If that is the case, then it is an eminently sensible approach, ensuring continuity in the areas of digital infrastructure and data within DSIT, as DSIT finds it feet as a separate department with greatly expanded roles beyond those elements of data and digital previously managed within DCMS. 

It also has the coincidental advantage of putting an experienced Minister of State in to the newly created DSIT, who will soon also have rather more intimate knowledge of all matter’s tourism than the average Minister and Under Secretaries of State in most departments outside DCMS.  In that respect we are also very fortunate that rather than slipping sideway, or out of Government, as can often be the case, several of our more recent former Ministers for Tourism have gone upwards and hopefully will go onwards.  This too can only serve to help broaden government’s communal understanding of the roles and functions of tourism and the wider visitor economy.

Any recent natural concerns about the apparent absence of any reference to tourism, visits or visitors in the restructured DCMS new mission statement are, it would now seem, without foundation.  Press reports at the time made it very clear that, the major reorganisation was being done at pace, behind closed doors at No 10 and, thus, unusually without the benefit or any considered advise or comment from any of the Departments impacted. Its a guess but it seems to me that it is entirely possible that the omission of the word visit/visitors in the latest version of the mission statement, in itself something and nothing, was no more than a slip of the pen.

I would wager that it was something done without the sage advice from anyone in DCMS.  A department only too well aware of our industry’s hyper sensitivity about, names, titles and referencing, all born in large part out of the now historic struggle for recognition and appropriate levels of departmental and Ministerial representation. Things we have actually enjoyed now for many years, even if it isn’t explicitly spelled out in the departmental title, is not the sole responsibility of a dedicated tourism Minister, or that there is currently no “nod and a wink” to it in the mission statement, or indeed any one of a half a dozen past or present, residually perceived slights upon “tourism” that have been aired in the past and doubtless will be aired again in the future.   

Given the latest Ministerial appointments we can rest assured about our current levels of recognition. Even if some might still hope perhaps for a token mention in any future mission statement update to help further salve any unintended injury to sometimes, all too fragile feelings. Personally, if it were ever to happen I would favour, as in some past iterations, the use of the device of referencing tourism, or visits/visitor as a unifying purpose; words to the effect that DCMS looks after things like culture, media and sport in order to help make the UK a better place to visit and enjoy. I favourite because I think the approach neatly encapsulate the fact that tourism isn’t a single entity and that what it does is bring many things and many people together for mutual benefit. If the mission statement ever changes, then hurrah! If it doesn’t no real problem.

Like you I look forward to working with the new Minister and existing team at DCMS to further our shared interests in driving more social and economic value out of tourism. Or more accurately, to drive more value out of the broader visitor economy which is increasingly what destination do and what destination mangers actually manage. 

2. To that end and with our many destination members core interests in the domestic market in mind, we might be well advised to use the appointment of a new Minister for Tourism as a fresh trigger to yet again think long and hard about new ways for Government, at all levels, to support domestic tourism, in order ultimately to help improve both domestic tourism and the domestic tourism v domestic outbound balance of payment deficit.  It is becoming increasingly clear that the fundamental barrier to this isn’t weaknesses in domestic tourism as such, or the strength of the outbound domestic market but challenging the status quo, without accidentally butting head-on into Treasury rules or doctrine. In particular, the brick wall of internal UK economic displacement theory, which dictates that public resource expended encouraging spending in one part of the UK economy, that might otherwise just have been spent in some other part of the UK economy, on whatever, is always a waste of public resource and should be avoided at all cost.   

I remain convinced that in the case of domestic tourism, the spending choices aren’t just between Bournemouth or Blackpool or between Bournemouth, Blackpool or a new bed, more beans, a few more beers in the local, or any other domestic financial transaction you might care to mention. More often than not now, it is a direct choice between Britain or abroad for the average UK resident’s primary holiday and leisure activities.

I also remain convinced that between us the domestic focused part of the industry can evidence, that domestic tourism is no longer just a domestic economic displacement activity. Things in our industry have radically changed and continue to do so.  For example, whatever economists might think, the “main holiday”, now all too often taken abroad, is no longer regarded by many that actual take them, as “a discretionary activity” and spending choices are adjusted accordingly.  That is a fundamental shift and one with fundamental implications for other leisure and visitor economy activities that aren’t “main holidays” and therefore remain discretionary and subject to the vagaries of economic conditions, influenced by fiscal policy direction.    

If the old rules that govern tourism have changed then it is not too unreasonable to suggest some of the rules of national governance and fiscal policies might need to be adjusted too to reflect the new realities. I am just not absolutely certain yet how or when this can all be achieved, other than to know that it isn’t simply a case of articulating the arguments but of evidencing then beyond all reasonable doubt. The domestic v domestic outbound arguments have been doing the rounds for decades, starting I believe not too long after the advent of the popular overseas holiday itself in the mid-1970s.  What has never been assembled, or certainly not in the 30 years I have now been involved, is any attitudinal, qualitive or quantitative evidence to prove what many of us might still naturally believe should be all too plainly obvious. I.E.: that domestic market is often in direct competition with domestic outbound market. There are things which could be done to significantly improve the domestic market’s performance and redress the balance of domestic to domestic outbound. Due in large part to market failure issues, some of those things (most?) are in the gift of government and not just the industry itself.

This feels like a topic for a destination manager’s meeting, if only to scope out the core issues and some of the possible options.  Given the looming main season, this is preferably something to try and squeeze in before or in the short lull post Easter? More detail to follow. Meanwhile views on any or all of the above would be welcomed.

Nudge, nudge say no more, the taxman may be looking.

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There has been a number of media reports and financial services comment on HMRC “nudge letters”, including reports on a recent batch of at least 1,000 such letters targeted at owners of short-term holiday lets or “Airbnbs” as they are often now popularly characterised. 

The typical “nudge letter” gives taxpayers the opportunity to engage with HMRC to remedy any suspected errors in recent self-assessment returns, before an official enquiry into their tax affairs is launched. Those receiving the letters are given a 30-day opportunity to return a detailed and apparently fairly onerous statement of their tax affairs relating to alleged area of potential omission.  Outstanding tax, interest and penalties may be payable but punitive penalties associated with deliberate or negligent evasion are usually avoided. 

Essentially it is an opportunity to prove innocence or come clean, rectify any genuine errors or omissions, whilst also avoiding the prospect of an in-depth examination of all tax affairs, potentially going back over any number of years; typical 4 to 6 but up to 20 years if HMRC deem it necessary.  Even if there proves to have been no errors made, the in-depth investigations are apparently intrusive and expensive in terms of time and energy required to service them and should, if at all possible, therefore be avoided.

Nudge letters are now a commonly used HMRC tool across all business sectors and all areas of taxation. They are set to becoming more so, especially among the online sectors, as from 1 January 2024 the UK are due to bring OECD’s model rules for platform reporting in to force. By law these will oblige all trading platforms operating in the UK to report key information like earnings of all their UK tax paying users, to HMRC.   

A couple of years ago, as part of their own settlement of their UK tax affairs, Airbnb “voluntarily” agreed to provide HMRC with this data for the 2017/18 and 2018/19 tax years, something that many hosts may be blissfully unaware of? In addition, the make tax digital programme is all but complete and HMRC have begun to employ sophisticated systems that can compare and contrast many millions of transactions across thousands of different digital systems, something that simply wasn’t possible to do manually as little as two or three years ago.  

It is entirely possible that evidence from these earlier returns and from other similar agreements with other platforms, will have helped identify those hosts now in receipt of a nudge letter for subsequent tax years.  What is absolutely certain is that we will see much more of it in future years driven by a mix of making tax digital, new automated and AI enabled investigative systems and critically the implementation of the OECD’s rules that will embrace everything from letting rooms, through eBay sales, Ubers and food deliveries income, to the earnings of online influences.

Beyond pursuing those that HMRC have good reason to suspect of having made (significant?) errors, the nudge campaigns have a clear role to play in demonstrating beyond any lingering historic doubt that HMRC now have, not just the will but also the means to crosscheck all actual earnings against those declared via tax returns or in some case, simply not declared at all because no return has been submitted. By doing so, they not only recover lost tax income from a minority but it also serves to scare the hell out of vast majority, who wouldn’t ordinarily dream of being careless, let alone deceitful, enough to try to defraud the taxman. In essence a highly efficient, high public profile but relatively low effort means of ensuring the vast majority continue to abide by the rules and that those that don’t are detected, punished and subsequently deterred from repeat the error.

All those using online platforms to let holiday accommodation need to be aware that HMRC already have new the means to check the detail of earnings voluntarily supplied by a number but not all platforms. Subject to the smooth passage of the necessary legislation that ability should become universal by the beginning of the of 2024, well ahead of the start of 2024-25 tax year and just after the final deadlines for the submission for most returns for the 2022-23 tax year. For those that have always assiduously reported their full earning this isn’t going to be an issue for others it may be a bit more of a problem, especially if they are not ware of rapidly changing circumstances.

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

If HMRC, the central players in the Westminster Government, can see the need for visibility and statutory oversight of areas like the short-term letting market, in order to enforce adherence to necessary rules on, in their case, necessary taxation, that surely adds significant weight to the current case for other statutory bodies to be given the most basic of means to reassert appropriate control over their necessary areas of statutory responsibility?  Especially in this, case where those responsibility largely relate to the provision of clean, safe and legal guest accommodation. Accommodation which in current circumstance can be anything but clean, safe or legal because nobody is empowered or given the basic means to universally check adherence to regulations, let alone to physically check the premises themselves.

If nothing else the current nudge campaign illustrates one of the many potential associated benefits of local destinations being aware of and therefore communicating with all local businesses in the tourism accommodation sector and not just those who are either visible to or voluntarily engage with destination manage. Statutory registration/licencing would help reassert clear lines and routes of communication, that ironically modern means of communication have inadvertently served to complicate or cut entirely.

Statutory accommodation scheme update

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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