ASSC and Scottish Tourism Alliance Give Evidence to Welsh Senedd on Visitor Accommodation Bill

The Association of Scotland’s Self-Caterers (ASSC), alongside the Scottish Tourism Alliance (STA), appeared before the Welsh Parliament’s Economy, Trade and Rural Affairs Committee this week to provide evidence on proposals for the Development of Tourism and Regulation of Visitor Accommodation (Wales) Bill.

Chief Executives Fiona Campbell MBE (ASSC) and Marc Crothall MBE (STA) were invited to share the lived experience of Scotland’s short-term let licensing scheme, which has resulted in widespread business closures, reduced accommodation capacity, rising visitor prices, and the growth of an unregulated underground market.

The evidence highlighted that Scotland has become a live case study in what happens when regulation is introduced:

• without a clear policy objective,
• without reliable data,
• and without proportionality or partnership working.

Fiona Campbell told the Committee:

“We fully support regulation that protects guests, communities and responsible operators. Our concern is not regulation itself, but regulation that fails its own purpose. Scotland’s experience shows that licensing has not created housing, has not improved safety, and has caused avoidable economic harm across rural and urban areas.”

Key points raised included:

Licensing cannot fix housing

Housing supply can only be addressed through planning, not licensing, and planning cannot be applied retrospectively without breaching A1P1 property rights. Scotland’s attempt to conflate safety and housing has left no increase in homes, but has removed lawful visitor accommodation from the market.

Registration should come first

Wales is already creating a national registration scheme. Done properly, this will deliver the data that Scotland never obtained. Registration with mandatory Health & Safety documentation would protect guests and support enforcement without crushing small businesses.

£75 licence fees are not credible

The Welsh Impact Assessment assumes a £75 licence. By comparison:

• Rent Smart Wales costs £234–£254 (and is self-certification only)
• Scottish BRIA estimated £214–£436
• Real Scottish fees range from £250 to £5,982

Freedom of Information analysis shows Scottish councils generated £14 million in year one alone. There is no realistic scenario in which Wales can operate a full licensing system at £75.

Consequences in Scotland

• closures of compliant self-catering businesses
• properties sitting empty rather than returning to residential use
• higher prices for visitors due to reduced supply
• tour operators unable to secure beds in key areas
• growth of an unregulated black market of unsafe accommodation
• ongoing legal challenges, including breaches of Provision of Services Regulations 2009 and A1P1

The ASSC and STA stressed that Wales has the opportunity to avoid these outcomes and become an exemplar of proportionate, evidence-based policy that protects guests and communities without harming rural economies.

Watch the Evidence session here from 2.08mins.