Current Consultations and Engagement with Government
Introduction
This page outlines the areas of engagement (formal or informal consultations) in which the WTA Chair and Policy Advocate are engaging with Welsh Government.
If you wish to join the debate, please contact us direct.
We engage directly with the Welsh Government and media and also via:
If you wish to join the debate, please contact us direct.
We engage directly with the Welsh Government and media and also via:
- The Welsh Government Tourism Cross Party Group
- The Wales Tourism and Hospitality Skills Partnership
- The Welsh Government Visitor Economy Forum.
Consultations & Engagement
Consultation on the Visitor Levy
The Wales Tourism Alliance has today submitted its response to the Welsh Government’s Visitor Levy Bill in papers to both the Finance and the Legislation, Justice and Constitution Committees.
In summary the WTA highlights the following issues:
· the Welsh Government’s own Explanatory Memorandum to the Bill and Economic Impact Assessment suggest that this policy will not cover its own costs of administration,
· the Bill extends well beyond tourism visits and includes, for example, stays of less than 31 days for work or education purposes,
· local authorities will have sole control of any net tax take and the Bill’s is drafted such that spend does not need to have a tourism-led focus,
· the data drawn on and assumptions made are unreliable to a concerning degree
· the research provided by the industry, including Wales own fora chairs, has not been given due weight
· no account has been taken of the pressures already exerted on Welsh tourism over the past five years and no recognition is made of the current fragility of the sector.
Closed on 10 January 2025 - the WTA has submitted these responses:
Legislation, Justice and Constitution Committee Response Finance Committee Response
The Wales Tourism Alliance has today submitted its response to the Welsh Government’s Visitor Levy Bill in papers to both the Finance and the Legislation, Justice and Constitution Committees.
In summary the WTA highlights the following issues:
· the Welsh Government’s own Explanatory Memorandum to the Bill and Economic Impact Assessment suggest that this policy will not cover its own costs of administration,
· the Bill extends well beyond tourism visits and includes, for example, stays of less than 31 days for work or education purposes,
· local authorities will have sole control of any net tax take and the Bill’s is drafted such that spend does not need to have a tourism-led focus,
· the data drawn on and assumptions made are unreliable to a concerning degree
· the research provided by the industry, including Wales own fora chairs, has not been given due weight
· no account has been taken of the pressures already exerted on Welsh tourism over the past five years and no recognition is made of the current fragility of the sector.
Closed on 10 January 2025 - the WTA has submitted these responses:
Legislation, Justice and Constitution Committee Response Finance Committee Response
Consultation on the Foundational Economy
The Economy, Trade and Rural Affairs Committee is undertaking an inquiry into the foundational economy. The Committee requested views on any or all of the issues covered in the terms of reference below:
Closes on 27 September 2024 - the WTA has submitted this response.
The Economy, Trade and Rural Affairs Committee is undertaking an inquiry into the foundational economy. The Committee requested views on any or all of the issues covered in the terms of reference below:
- To what extent has the Welsh Government embedded support for the foundational economy into its overall approach to economic development? What further steps should it take to do this?
- Given the cross-portfolio nature of the foundational economy, how should the Welsh Government create a co-ordinated approach to mainstreaming support for foundational economy sectors across government?
- Which of the Welsh Government’s foundational economy policy initiatives have been most successful, and why? Which have worked less well, and why?
- What examples of best practice exist in different foundational economy sectors and places within or beyond Wales? How could the Welsh Government better support partners to deliver best practice, and to scale it up where appropriate?
- What progress has been made in using procurement to strengthen the foundational economy since our predecessor Committee looked at this issue in 2019? What further actions are required to deliver greater progress, and what innovative examples of best practice could be built on?
- How effective have the Welsh Government’s actions to deliver fair work in foundational economy sectors been? What further steps should it take within its devolved powers to progress this agenda, and how can it work with the UK Government to drive improvements in non-devolved areas?
Closes on 27 September 2024 - the WTA has submitted this response.
Proposed Changes to the Welsh School Year Consultation
Jeremy Miles MS Minister for Education’s announcement on proposals to change the school year in Wales have been met with a mixed response. Anecdotally, there is a split between those who wish to see change and those who do not. There seems to be more in favour of no change, with fears about how it could potentially impact the market at a time of great economic uncertainty.
Closed on the 12th February 2024 – The WTA has submitted this response.
Jeremy Miles MS Minister for Education’s announcement on proposals to change the school year in Wales have been met with a mixed response. Anecdotally, there is a split between those who wish to see change and those who do not. There seems to be more in favour of no change, with fears about how it could potentially impact the market at a time of great economic uncertainty.
Closed on the 12th February 2024 – The WTA has submitted this response.
Separated waste collections for workplaces
Following the approval of the Workplace Recycling Regulations by the Senedd the new regulations came into force on 6 April 2024. This will mean that all business, public and third sector workplaces will be required to separate recyclable materials in the same way as households. The Welsh Government’s stated aim is "to increase the quality and quantity of recyclable materials collected from workplaces with less going to landfill. This potentially causes a number of difficulties, particularly with regard to the number of recycling bins that are required to sit outside properties of multiple occupancy; getting guests to recycle in the first place and with issues such as hygiene and the attraction of vermin to open bins.
There is a new Separate Collection of Waste Materials for Recycling Code of Practice for Wales ("The Code") which sets out practical guidance on how to comply with the new law.
Further information and guidance can be found here.
Following the approval of the Workplace Recycling Regulations by the Senedd the new regulations came into force on 6 April 2024. This will mean that all business, public and third sector workplaces will be required to separate recyclable materials in the same way as households. The Welsh Government’s stated aim is "to increase the quality and quantity of recyclable materials collected from workplaces with less going to landfill. This potentially causes a number of difficulties, particularly with regard to the number of recycling bins that are required to sit outside properties of multiple occupancy; getting guests to recycle in the first place and with issues such as hygiene and the attraction of vermin to open bins.
There is a new Separate Collection of Waste Materials for Recycling Code of Practice for Wales ("The Code") which sets out practical guidance on how to comply with the new law.
Further information and guidance can be found here.
Tourism Levy Consultation Group meeting
Thursday 18th January 2024: The Discretionary visitor levy for local authorities
From the outset the WTA has made it clear to the Welsh Government that our members are almost unanimous in their rejection of any form of Tourism Levy being applied to accommodation providers across Wales. The Welsh Government’s Programme for Government, and the Cooperation Agreement between the Welsh Government and Plaid Cymru, both contain commitments to introduce levies.
Rebecca Evans, MS has stated that a levy would enable destinations in Wales to be enjoyed for generations to come and that 'A tourism tax would raise revenue for local authorities enabling them to manage services and infrastructure which makes tourism a success'. Although we have recently been given assurances that any levy would not be introduced for a number of years, 2026 at the earliest, a formal consultation on draft legislative proposals was launched on the 20th September 2022. The WTA responded post engagement with Welsh Govt and private sector engagement. Whilst we remain firmly in-principle against the introduction of a Tourism Levy, we now believe Welsh Government will push ahead regardless.
The WTA membership has agreed that we will engage with the consultation, but we continue to be clear that we do not support it's introduction. Our objections to the tax broadly revolve around:
- Poor timing: In the middle of a cost of living and energy crises, political tension and post pandemic
- Potential economic damage that would be wrought if imposed given the decrease in demand with regard to price elasticity
- The cost of implementing and policing a tax and the unfair nature of doing so without a suitable registration scheme
- The lack of an economic impact assessment that reviews the cumulative impact of a raft of new proposals (see below)
WTA attended the ‘Introductory Meeting of the Visitor Levy Working Group’ (18/01/24). Welsh Government and the Welsh Revenue Authority have invited key industry stakeholders to discuss operational details in respect of the proposed discretionary levy for local authorities (or Tourism Tax). Both WG and WRA are now looking for feedback from us to assist in the development of policy.
Whilst it was made clear that the meeting/s are not about discussing the policy behind the proposed levy, it was made clear from the start that attendance at the meeting did not mean endorsement of the Tourism Levy and that the majority of members still remain opposed. A robust, but cordial meeting then took place, it was however merely an introductory session so was relatively brief. The Welsh Revenue Authority (WRA) shared a look forward and then received questions from the floor on the topics they discussed.
We have agreed to continue to attend to ensure that we can, as much as is possible, steer the course of the policy development to ensure little or no unintended consequences occur. Draft legislation will be introduced into the Senedd in the Autumn for the scrutiny stages.
Evidence Note: Tourism Tax - Independent tourism tax engagement meetings in Cardiff 18th October and Llandudno 20th October 2022
WTA Tourism Tax Commissioned Paper
Tourism Tax Position Statement
Thursday 18th January 2024: The Discretionary visitor levy for local authorities
From the outset the WTA has made it clear to the Welsh Government that our members are almost unanimous in their rejection of any form of Tourism Levy being applied to accommodation providers across Wales. The Welsh Government’s Programme for Government, and the Cooperation Agreement between the Welsh Government and Plaid Cymru, both contain commitments to introduce levies.
Rebecca Evans, MS has stated that a levy would enable destinations in Wales to be enjoyed for generations to come and that 'A tourism tax would raise revenue for local authorities enabling them to manage services and infrastructure which makes tourism a success'. Although we have recently been given assurances that any levy would not be introduced for a number of years, 2026 at the earliest, a formal consultation on draft legislative proposals was launched on the 20th September 2022. The WTA responded post engagement with Welsh Govt and private sector engagement. Whilst we remain firmly in-principle against the introduction of a Tourism Levy, we now believe Welsh Government will push ahead regardless.
The WTA membership has agreed that we will engage with the consultation, but we continue to be clear that we do not support it's introduction. Our objections to the tax broadly revolve around:
- Poor timing: In the middle of a cost of living and energy crises, political tension and post pandemic
- Potential economic damage that would be wrought if imposed given the decrease in demand with regard to price elasticity
- The cost of implementing and policing a tax and the unfair nature of doing so without a suitable registration scheme
- The lack of an economic impact assessment that reviews the cumulative impact of a raft of new proposals (see below)
WTA attended the ‘Introductory Meeting of the Visitor Levy Working Group’ (18/01/24). Welsh Government and the Welsh Revenue Authority have invited key industry stakeholders to discuss operational details in respect of the proposed discretionary levy for local authorities (or Tourism Tax). Both WG and WRA are now looking for feedback from us to assist in the development of policy.
Whilst it was made clear that the meeting/s are not about discussing the policy behind the proposed levy, it was made clear from the start that attendance at the meeting did not mean endorsement of the Tourism Levy and that the majority of members still remain opposed. A robust, but cordial meeting then took place, it was however merely an introductory session so was relatively brief. The Welsh Revenue Authority (WRA) shared a look forward and then received questions from the floor on the topics they discussed.
We have agreed to continue to attend to ensure that we can, as much as is possible, steer the course of the policy development to ensure little or no unintended consequences occur. Draft legislation will be introduced into the Senedd in the Autumn for the scrutiny stages.
Evidence Note: Tourism Tax - Independent tourism tax engagement meetings in Cardiff 18th October and Llandudno 20th October 2022
WTA Tourism Tax Commissioned Paper
Tourism Tax Position Statement
Plans to introduce a statutory registration and licensing scheme
On 9 January 2024 the Deputy Minister for Arts, Sport and Tourism, Dawn Bowden, released this linked statement.
The WTA notes with concern that the announcement makes mention of a phased approach - ‘the first phase will be a statutory registration scheme for all accommodation providers, which will – for the first time – provide a register on the broad range of visitor accommodation’. A second phase being a ‘to follow with a licensing scheme’ and a third which looks at introducing quality standards at a later stage.
Our initial reaction is that this sounds like it is going way beyond the bounds of what was discussed at consultation and worryingly sounds more like a licensing scheme, rather than a registration or licensing scheme lite . This is not what we were prepared to sign up to. There has previously been little or no mention of adding quality assurance into plans for a registration scheme, which sounds like a mandatory ‘grading’ scheme. This may of course, not be the case as detail is limited, in what amounts to a page of quotes, but given the Welsh Government’s form since the last election it sounds like democratic informed input could be thin and be devolved more dictatorially than Ministers will ever admit?
Statement from Dawn Bowden MS, Deputy Minister with Tourism Portfolio:
‘Plans to introduce a statutory registration and licensing scheme for all visitor accommodation in Wales have been announced by the Deputy Minister for Arts, Sport and Tourism, Dawn Bowden today (Tuesday, January 9) with legislation expected to be introduced to the Senedd before the end of the year. The registration and licensing scheme is intended to deliver a register of visitor accommodation types and to enable providers to demonstrate compliance with safety and quality requirements. It is intended to enhance the visitor experience and visitor safety expectations in Wales by ensuring anyone who lets out visitor accommodation meets a relevant set of standards.
This follows a public consultation, extensive engagement with the sector, as well as a recently published survey that found 89% of visitors considered it important the accommodation, they stay in is operating safely. Many parts of the world have already adopted licensing, certification or registration schemes across their visitor accommodation sectors and the Welsh Government has been considering best practice to design one that is simple and easy to use for accommodation providers in Wales. Across the UK, Northern Ireland has had a certification scheme established for all visitor accommodation since 1992, with Scotland having recently introduced a licensing scheme for short term lets. The UK Government is also pursuing a registration approach for short term lets.
In Wales, the first phase will be a statutory registration scheme for all accommodation providers, which will – for the first time – provide a register on the broad range of visitor accommodation available across the country and will include details on who is operating in the sector, where they are operating, and how they are operating.
WTA Position Statement
On 9 January 2024 the Deputy Minister for Arts, Sport and Tourism, Dawn Bowden, released this linked statement.
The WTA notes with concern that the announcement makes mention of a phased approach - ‘the first phase will be a statutory registration scheme for all accommodation providers, which will – for the first time – provide a register on the broad range of visitor accommodation’. A second phase being a ‘to follow with a licensing scheme’ and a third which looks at introducing quality standards at a later stage.
Our initial reaction is that this sounds like it is going way beyond the bounds of what was discussed at consultation and worryingly sounds more like a licensing scheme, rather than a registration or licensing scheme lite . This is not what we were prepared to sign up to. There has previously been little or no mention of adding quality assurance into plans for a registration scheme, which sounds like a mandatory ‘grading’ scheme. This may of course, not be the case as detail is limited, in what amounts to a page of quotes, but given the Welsh Government’s form since the last election it sounds like democratic informed input could be thin and be devolved more dictatorially than Ministers will ever admit?
Statement from Dawn Bowden MS, Deputy Minister with Tourism Portfolio:
‘Plans to introduce a statutory registration and licensing scheme for all visitor accommodation in Wales have been announced by the Deputy Minister for Arts, Sport and Tourism, Dawn Bowden today (Tuesday, January 9) with legislation expected to be introduced to the Senedd before the end of the year. The registration and licensing scheme is intended to deliver a register of visitor accommodation types and to enable providers to demonstrate compliance with safety and quality requirements. It is intended to enhance the visitor experience and visitor safety expectations in Wales by ensuring anyone who lets out visitor accommodation meets a relevant set of standards.
This follows a public consultation, extensive engagement with the sector, as well as a recently published survey that found 89% of visitors considered it important the accommodation, they stay in is operating safely. Many parts of the world have already adopted licensing, certification or registration schemes across their visitor accommodation sectors and the Welsh Government has been considering best practice to design one that is simple and easy to use for accommodation providers in Wales. Across the UK, Northern Ireland has had a certification scheme established for all visitor accommodation since 1992, with Scotland having recently introduced a licensing scheme for short term lets. The UK Government is also pursuing a registration approach for short term lets.
In Wales, the first phase will be a statutory registration scheme for all accommodation providers, which will – for the first time – provide a register on the broad range of visitor accommodation available across the country and will include details on who is operating in the sector, where they are operating, and how they are operating.
WTA Position Statement
Non-Domestic Rating (Amendment of Definition of Domestic Property) (Wales) Order 2022 (Adopted):
Negotiation of exemptions.
The announcement, on the 2nd of March 2022, of the proposal to raise the occupancy criteria by 160% to 182 days came as a shock, particularly to small self-catering businesses (furnished holiday lettings or FHLs) . It was also the start of a whole new raft of proposed taxes and regulation which will over this term of Welsh Government have far-reaching impacts on the tourism industry across Wales.
The WTA believe the first consultation carried out by Welsh Government last year (25 August to 17 November 2021) was deeply flawed, securing only nine responses which agreed with the proposal of 182 days. The majority of respondents to that consultation proposed an increase in line with the HMRC threshold of 105 days occupancy. We have as a sector been unified in our opposition to the 182-day threshold provision Order throughout. In response the WTA, PASC and UKH submitted a body of evidence (link below) containing 400+ private testimonials to the second ‘technical’ consultation. Our body of evidence clearly showing the potential economic and personal impact. Despite these responses which clearly challenge assumptions made on the back of officials’ occupancy data and without any explanation as to why our evidence has been ignored and the Welsh Government drew the amendment into law back in June (13) 2022.
'The legislation in question was subject to a motion to annul (7th July 22) which was debated in the Senedd on 6 July. The Senedd voted against the motion, confirming support for the changes, which will ensure that the properties concerned are classed as non-domestic only if they are occupied for business purposes for the majority of the year. If they are let on a less frequent basis, they will be liable for council tax'. Rebecca Evans MS - Minister Finance and Local Government.
Rebecca Evans MS follow up consultation with regard to exemptions, aside from one small concession in relation to having specific planning permission yielded nothing. We will continue to push for exemptions from both the tax itself and the additional tax up to 300%. The WTA and PASC has met with the Minister and civil servants officials for further discussion on exemptions to the above Order.
WTA Consultation Response - August 2022
Open Evidence Base to Underpin the Industry Response to the Technical Consultation on the Draft Non-Domestic Rating (Amendment of Definition of Domestic Property) (Wales) Order 2022 - WTA, UKHospitality Cymru & PASC UK - April 2022
Letter to Minister - June 2022
Open letter to Minister - March 2022
Negotiation of exemptions.
The announcement, on the 2nd of March 2022, of the proposal to raise the occupancy criteria by 160% to 182 days came as a shock, particularly to small self-catering businesses (furnished holiday lettings or FHLs) . It was also the start of a whole new raft of proposed taxes and regulation which will over this term of Welsh Government have far-reaching impacts on the tourism industry across Wales.
The WTA believe the first consultation carried out by Welsh Government last year (25 August to 17 November 2021) was deeply flawed, securing only nine responses which agreed with the proposal of 182 days. The majority of respondents to that consultation proposed an increase in line with the HMRC threshold of 105 days occupancy. We have as a sector been unified in our opposition to the 182-day threshold provision Order throughout. In response the WTA, PASC and UKH submitted a body of evidence (link below) containing 400+ private testimonials to the second ‘technical’ consultation. Our body of evidence clearly showing the potential economic and personal impact. Despite these responses which clearly challenge assumptions made on the back of officials’ occupancy data and without any explanation as to why our evidence has been ignored and the Welsh Government drew the amendment into law back in June (13) 2022.
'The legislation in question was subject to a motion to annul (7th July 22) which was debated in the Senedd on 6 July. The Senedd voted against the motion, confirming support for the changes, which will ensure that the properties concerned are classed as non-domestic only if they are occupied for business purposes for the majority of the year. If they are let on a less frequent basis, they will be liable for council tax'. Rebecca Evans MS - Minister Finance and Local Government.
Rebecca Evans MS follow up consultation with regard to exemptions, aside from one small concession in relation to having specific planning permission yielded nothing. We will continue to push for exemptions from both the tax itself and the additional tax up to 300%. The WTA and PASC has met with the Minister and civil servants officials for further discussion on exemptions to the above Order.
WTA Consultation Response - August 2022
Open Evidence Base to Underpin the Industry Response to the Technical Consultation on the Draft Non-Domestic Rating (Amendment of Definition of Domestic Property) (Wales) Order 2022 - WTA, UKHospitality Cymru & PASC UK - April 2022
Letter to Minister - June 2022
Open letter to Minister - March 2022
Consultation: Local Variation to Land Transaction Tax Rates for Second Homes, Short Term Holiday Lets, etc
WTA Response to the Welsh Government Consultation – ‘Planning legislation and policy for second homes and short-term holiday lets’ - February 2022
WTA Response to the Welsh Government Consultation – ‘Planning legislation and policy for second homes and short-term holiday lets’ - February 2022
Consultation: Second Homes - local variation to land transaction tax rates
WTA Response to the Welsh Government Consultation ‘Second homes: local variation to land transaction tax rates’’
WTA Response to the Welsh Government Consultation ‘Second homes: local variation to land transaction tax rates’’
Welsh Government Consultation on Amendments to Permitted Development Rights
WTA Response - February 2022
WTA Response - February 2022
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