The Association of Scotland’s Self-Caterers (ASSC) has responded to Argyll & Bute Council’s proposed approach to short-term let licensing fees, following the publication of the Council’s Budget Pack. Proposals seek to increase short-term let licensing fees by 10% and, more concerningly, to recharge licence income across wider Council services.
While we fully recognise the importance of a properly resourced licensing system, any use of licensing fees must remain strictly within the boundaries of the law.
The current statutory framework only permits licensing authorities to set fees on a cost recovery basis directly linked to the administration of the specific licensing function. The proposal to divert income to other Council services moves beyond this remit and risks transforming a regulatory fee into an unlawful revenue-raising mechanism. This approach exposes the Council to significant legal and reputational risk and undermines trust with compliant operators.
We have made clear that this proposal is ultra vires and legally defective. We have therefore formally requested that Argyll & Bute Council:
Our position remains clear. We support a fair, lawful and proportionate licensing system that protects communities while enabling responsible self-catering businesses to operate with certainty and confidence. A transparent and compliant cost recovery model provides the only sustainable route forward.
We have invited Argyll & Bute Council to confirm that the proposal will be amended in line with statutory requirements and have reiterated our willingness to engage constructively to support a lawful and balanced solution.
We will continue to keep members informed as this situation develops and will take all appropriate steps to protect the integrity of the sector and the legal position of self-catering operators across Scotland.