The Association of Scotland’s Self-Caterers (ASSC) has submitted a detailed response to the Water Industry Commission for Scotland’s (WICS) Strategic Review of Charges 2027–33 (SRC27), urging a review of the methodology used to calculate non-household water and sewerage charges.
Drawing on evidence gathered directly from members across Scotland, the response argues that many self-catering businesses are experiencing significant increases in water charges as an unintended consequence of the 2026 Non-Domestic Rates (NDR) revaluation.
To inform its response, ASSC undertook a Water Charges Impact Snap Survey between 9 and 15 July 2026, receiving 147 responses from self-catering businesses across Scotland.
The survey, supported by invoice evidence from multiple licensed water retailers, identified a consistent pattern of substantial increases in water and sewerage charges for businesses whose charges are linked to Rateable Value.
Importantly, members reported that these increases often bore little relationship to actual water consumption, with many seasonal businesses questioning whether the current charging methodology remains appropriate.
Whilst the consultation focuses on non-household water charging, ASSC believes the findings have much wider significance.
The Association has previously raised concerns with the Scottish Government that the effects of the 2026 Non-Domestic Rates revaluation extend beyond the business rates system itself. The survey findings now provide compelling evidence that those same revised Rateable Values continue to influence water and sewerage charges, creating additional financial pressures for many tourism businesses.
Since the revaluation came into effect, the Scottish Government has introduced significant rates relief for the sector, Scottish Assessors have reduced many Rateable Values by 20%, and Ministers have committed to both a comprehensive review of the Non-Domestic Rates system and an Independent Panel examining reports of inconsistent valuations.
ASSC believes the evidence gathered through this survey should help inform that wider work.
The Association’s response makes clear that ASSC supports continued investment in Scotland’s water infrastructure.
However, it argues that the issue is not investment itself, but the methodology used to allocate those costs.
The response calls on WICS to review whether continued reliance on Rateable Value remains the most appropriate basis for calculating non-household water and sewerage charges, particularly for seasonal tourism businesses where water usage may bear little resemblance to property valuations.
“Our members recognise the importance of investing in Scotland’s water infrastructure and are committed to contributing fairly towards those costs.
“The evidence we have gathered suggests that many businesses are experiencing significant increases in water and sewerage charges that arise not from greater water consumption, but from the continued use of revised Rateable Values introduced through the 2026 Non-Domestic Rates revaluation.
“We believe this presents an important opportunity for WICS, Scottish Water and the Scottish Government to work together to ensure that charging arrangements remain fair, proportionate and evidence-based.
“We have also shared our findings with the Scottish Government and hope this evidence will contribute to the comprehensive review of Non-Domestic Rates and the work of the Independent Panel examining the outcome of the 2026 revaluation.”
ASSC has shared its consultation response with both WICS and the Scottish Government and has offered to present the survey findings and supporting evidence to officials, Ministers and the Independent Panel as work on the wider review progresses.
The Association will continue to work constructively with policymakers and stakeholders to ensure Scotland’s regulatory framework supports both sustainable public investment and a thriving tourism economy.