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Letter to Housing Minister Paul McLennan Requesting Clarification on Policy Change to Exempt Home Swaps from STLL

ASSC Chief Executive, Fiona Campbell writes to Housing Minister requesting urgent clarification from the Scottish Government in response to a report in the Times newspaper today (20th September 2023) reporting that the Scottish Government is seeking to allow home swaps to be exempt from Short-Term Let Licensing.

Good afternoon,

I am contacting you requesting urgent clarification further to reports in today’s Times that the Scottish Government is seeking to allow home swaps to be exempt from short-term let licensing.

Please can you confirm whether the Scottish Government has agreed to this policy change, or is actively considering it? If so, will further exemptions be offered to other forms of accommodation captured under licensing such as self-catering and B&Bs? For clarity, the ASSC is not against addressing unintended consequences, of which there are many, and we and other tourism industry stakeholders have highlighted them to you and your colleagues.

If the Scottish Government is able and willing to act on unintended consequences at this late stage, we believe similar concerns can also be addressed. As you are aware, we proposed a range of policy recommendations which would create a fairer, more proportionate and legally sound regulatory framework.

If it is the case that the Scottish Government is not rectifying unintended consequences more widely, we believe this is unreasonable in two main respects. First, the home swap exemption would critically undermine the policy objective of licensing upholding health and safety standards. It runs contrary to the legislation. Second, it would be iniquitous and not offer a level playing field for tourist accommodation.

With this latest development, the ASSC return to one of the points we have raised throughout the regulatory discussions: is this about basic health and safety or not? What is the mischief that licensing is addressing?

Given the reaction of many in the sector to this news, I would appreciate a reply as soon as practically possible.

All the very best,

Fiona Campbell
ASSC Chief Executive

In a letter from the Housing Minister to Jackie Baillie MSP on 20th September, the Housing Minister wrote: 

“In terms of home-sharing of which B&Bs and guesthouses are a form of, this is included because safety matters – whether a visitor staying in Scotland is letting a room/s in a host’s house, using a B&B/guesthouse or self-catering accommodation. As most of the mandatory licensing conditions are based on existing legislation and best practice, the expectation is that licensing should not be onerous for existing hosts and the benefit is guests using all types of short-term let accommodation will be assured that consistent standards are being complied with.”

This response makes the exclusion of home swaps yet more confusing. 

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