The Association of Scotland’s Self-Caterers (ASSC) has been engaging directly with the Scottish Assessors Association regarding the self-catering audit process and the evidence being requested from operators. We understand that assessors are aiming to take a pragmatic and proportionate approach to this exercise, focused on confirming whether properties meet the two statutory tests for self-catering status.
The legislation itself is clear. Operators must be able to demonstrate that the property was let commercially and:
The regulations require evidence that is “sufficient to confirm” these requirements are met.
Our understanding is that Assessors are not looking to go beyond what is reasonably necessary. However, operators should help the process by ensuring the evidence they provide clearly demonstrates compliance with the two statutory tests.
Be proactive rather than reactive
Importantly, operators do not need to wait until they are contacted or receive an Audit Request.
Under the regulations, evidence must be submitted
ASSC strongly encourages members to take a proactive approach and submit evidence early where possible.
Audit requests are already being issued across Scotland according to local valuation board timetables, with many councils and valuation joint boards issuing requests during May and June. Dates below.
What sort of evidence is likely to help?
Operators should ask themselves one simple question:
“Does this clearly demonstrate that I meet the 140 / 70 tests?”
In most cases, straightforward operational records should be sufficient.
Examples may include:
Many operators will be able to generate suitable reports directly from systems such as SuperControl or other booking and property management platforms.
A simple spreadsheet may also be perfectly acceptable if it clearly evidences:
It may also assist to provide evidence showing multiple shorter bookings rather than one single extended stay, as this helps demonstrate genuine self-catering use.
What operators do not need to provide
The legislation does not prescribe specific forms of evidence such as bank statements or detailed financial disclosures.
Operators should not feel obliged to submit:
In most cases, Assessors simply need sufficient evidence to confirm the statutory tests are met.
A booking summary with personal and financial information redacted is likely to be entirely appropriate where it still demonstrates occupancy levels and availability.
Why this matters
It is essential that operators provide evidence when requested.
Under the updated regulations, where evidence is not provided within the required timeframe, or is considered insufficient, the assessor must treat the property as not qualifying as self-catering accommodation for NDR purposes.
ASSC has already worked extensively to secure two evidence windows through regulatory change for 2023-24 and 2024-25. Unfortunately, if evidence is simply not supplied, there is very limited scope to challenge removal from NDR at a later stage.
That is why we are encouraging all members to engage constructively and proactively with the process.
Working collaboratively going forward
ASSC remains keen to work positively and collaboratively with Assessors and valuation boards across Scotland.
We are also keen to hear from members about their experiences, particularly:
Please contact membership@assc.co.uk to provide positive or negative feedback, identifying which Assessor area your business falls under. We can then repay this to the Scottish Assessors Association.
At present, however, we are hopeful that Assessors will continue to apply a sensible and pragmatic approach focused on the core statutory tests.
The key message is simple:
Provide clear, proportionate evidence early and make it easy for assessors to confirm compliance.