Scottish Government Changes Grant Funding Eligibility For Self-Caterers

Following lengthy discussions between the Association of Scotland’s Self-Caterers, Scottish Government and other stakeholders, the ASSC can now report that the guidance for self-catering eligibility for grant support has been amended.

“Self-catering accommodation and caravans are considered eligible for grant funding if receipts represent a primary source (for example, one third or more) of earnings for the ratepayer and the property has been let out for 140 days or more in financial year 2019-20.”

The ASSC has been in high level discussion with the Scottish Government throughout today to ensure that this new amendment would work for the sector.

We highlighted several issues with the criteria and requested that these were considered.  We also suggested that Local Authorities were provided with guidance as to the evidence they could request.

Following conversations throughout the day, we now understand that the Scottish Government are not being prescriptive in guidance to local authorities about how meeting the income criteria can be evidenced, nor are they minded to relax the criteria any further.

Local Authorities may specify any additional evidence they require (e.g. records of bookings, a copy of public liability insurance cover or a website) in order to confirm eligibility.

We have now assessed current guidance across a variety of local authorities:

Some have not updated the new guidance, some are asking for self-assessment tax returns for 2019-20, and some are asking for proof of occupancy from 6th April 2019 to 5th April 2020. Others are asking for additional evidence….

As you can appreciate, the financial year has not ended, and bookings for March/April 2020 are non existent.

We had hoped to issue a supportive and celebratory statement this evening.

Unfortunately, what we are left with is:

  • A lack of parity of support with other self-caterers in the rest of the UK,
  • Self-catering requires additional eligibility compared to any other small business in Scotland,
  • In addition we are now looking at a lack of parity on eligibility criteria across 32 local authorities.

We have advised that local authorities are already experiencing unprecedented levels of pressure in terms of resource and in implementing new initiatives. Having to audit these additional eligibility criteria will add further unnecessary burden to both local authorities and operators.  We will continue to discuss these issues with the Scottish Government tomorrow.

Fiona Campbell

Chief Executive

Association of Scotland’s Self-Caterers

Self-Catering Support: Update for Members 29th March

The ASSC has been working tirelessly over the last few days to promote the requirement for equitable and vital support for the self-catering sector in Scotland, which includes looking at all possible options available.

We acknowledge that this is an horrendously worrying time for hard working, professional self-catering businesses, and that many feel that the eligibility requirements for the grant scheme for self-catering operators in Scotland is discriminatory.  For the benefit of our members and the tourism industry, we are committed to working constructively with the Scottish Government to reach a workable solution.

Many people have asked us the following questions:

Q1. What is your understanding of the support package from the Scottish Government? How much will be available and who will be eligible to claim?

Having originally excluded self-catering from the grant support scheme, on Friday, the Cabinet Secretary for Finance, Kate Forbes MSP set out the following for self-catering:

“…the ratepayers for self-catering accommodation and caravans will be eligible for both the one-off £10,000 grant for small businesses and the one-off £25,000 grant for businesses in the retail, hospitality and leisure sectors announced on 18 March by the Cabinet Secretary for Economy, Fair Work and Culture. The grants will be available on the condition that:

  • this property is each ratepayer’s primary source of earnings and that
  • the property is let for 140 days or more in the financial year 2019-20
  • Applicants will be required to provide evidence of this and grants will be restricted to one per ratepayer.”

Q2. Does the ASSC believe that this support package is sufficient? How does it differ from the support to self-caterers in England?

We do, of course, welcome the announcement of financial support, and recognise that it is a step in the right direction.

However,  the caveats and additional conditionality applied to self-catering are unreasonable, inequitable and damaging to an already fragile sector – especially as we have been responsible and backed the Scottish Government in endorsing the temporary (for the foreseeable future) closure of self-catering units.

We have two principal concerns with the proposal:

  • The lack of parity of support with other self-caterers in the rest of the UK. In England, each business on Non-Domestic Rates is eligible for a grant. In Scotland, this will be limited to one per ratepayer. In Wales, there is a limit of two grants per ratepayer. In Scotland, it is restricted to one grant per ratepayer. This penalises a key component part of Scotland’s tourism offering compared to others in the UK.
  • Self-catering requires additional eligibility compared to any other small business in Scotland. Many other small businesses in Scotland are increasingly reliant on multiple sources of income so why should self-caterers be treated any differently?

In addition, we believe that the current approach shows a lack of understanding of how many rural economies are made up, especially in the Highlands. Many people rely on multiple income streams and will struggle to evidence that self-catering is their primary source of income; however, it is still critical to their overall income. For many, with diversified business models, as well as Ltd Companies, there will now be no support at all. We believe that sadly this will not benefit many responsible, professional operators and these are the people who are inundating us with desperate messages just now.

Q3. Why the Scottish Government has taken this approach?

Of course we understand the issue with second homes, who may have managed to apply for the SBBS in the past in order to avoid paying council tax or business rates. We absolutely understand that the Scottish Government has a duty to support those with active businesses that have been damaged by the Covid-19 crisis, and doesn’t want to benefit those with second homes or those that are not commercially active.

The Barclay review set out recommendations that from 1st April 2020, operators will have to evidence 70 nights of commercial activity to be eligible for the SBBS. As an association we fully support this.

However, this is perhaps not the time to rectify the situation retrospectively.

Q4. What efforts will you be making to ensure the support package is revised?

These are really tough times for our sector. We have already faced the OTAs unilaterally changing their cancellation policies so that all bookings are refunded in full, despite individual T&Cs. As an industry, we simply don’t have the reserves to cope with this alone, and now we face zero future income, but our outgoings remain.

There is huge concern that the caveats associated with Friday’s announcements will render many ineligible for any grant support.

Fergus Ewing MSP, Cabinet Secretary for Rural Economy and Tourism, called the exclusion an ‘anomaly’ prior to the package being extended to self-catering. We look forward to working with the Scottish Government to further amend the anomaly.

As ever, we want to work constructively to reach a compromise. A relaxation of the caveat would be most welcome:

  • Either ratepayers must evidence that self-catering is a part of an active income stream
  • Or, ratepayers must provide evidence of nights occupied (perhaps basing it on the Barclay recommendation that the property has been commercially occupied for over 70 nights). 

Self-catering generates £723m to the Scottish economy. Visitors are increasingly opting for self-catering as a holiday of choice, to experience the hospitality that Scotland can offer. To disadvantage this key element of Scotland’s tourism offer would discriminate self-catering against the rest of the UK and further afield, which has the potential to have a disastrous impact on the sector.

As an industry, we aren’t asking for 80% of anything. We are just asking for a small cushion to get us through the next few months. Our sector is on its knees, and people are angry.

Q5. There has been a push for self-catering accommodation to be made available to key workers during this period of national emergency – is this something the Association supports?

We recognise the need for accommodation for key workers and those that are stranded in Scotland.

We also recognise the benefits of self-catering accommodation to deliver this.

We have sought guidance from Scottish Government on this. It needs to be a considered approach, where people are not commercially benefiting from the crisis. We also have to be mindful of other residents, who may be uncomfortable with higher risk people staying in close proximity.

In Spain, the trade associations worked with the Spanish Government to deliver a scheme whereby only entire buildings are being used to house key workers:

  • Key workers are charged a nominal fee to cover utilities (or nothing at all) by owners, so there is complete parity
  • Embassies are allowed to house stranded nationals for a vastly reduced fee.

This has to be a considered approach, not a free for all – which it is fast becoming.

We have been overwhelmed by people requesting reassurance at this awful time. I can only apologise that we are struggling to reply individually to people.

We have also been humbled by the huge support people have expressed for what we are doing as an association to support self-catering in Scotland. Rest assured, we will continue to do so night and day.

We would encourage you to contact your MSPs and ask for a relaxation in the eligibility criteria. Your voice matters.

Stay Safe and Stay Positive.

Fiona Campbell

Chief Executive

Association of Scotland’s Self-Caterers

Eligibility Criteria for Access to the Grant Funding Scheme for Self-Caterers

Over the past few days, the ASSC has engaged in discussions with the Scottish Government over the eligibility criteria for access to the Grant Funding Scheme for self-caterers.

The ASSC received a letter from the Cabinet Secretary for Finance Kate Forbes MSP this afternoon.

In it, Ms Forbes outlined that “the ratepayers for self-catering accommodation and caravans will be eligible for both the one-off £10,000 grant for small businesses and the one-off £25,000 grant for businesses in the retail, hospitality and leisure sectors announced on 18 March by the Cabinet Secretary for Economy, Fair Work and Culture. The grants will be available on the condition that this property is each ratepayer’s primary source of earnings and that the property is let for 140 days or more in the financial year 2019-20. Applicants will be required to provide evidence of this and grants will be restricted to one per ratepayer.”

We have already responded setting out our topline concerns with what has been proposed. We will continue to press the Scottish Government to ensure that there is parity of support for Scottish self-caterers compared to others in the UK and that our industry is not treated any differently from others in the small business community.

These are extremely challenging times for our industry and we understand that you will be anxious for a swift resolution on the issue. We hope to reach an amicable solution with the Scottish Government in due course but rest assured that we are fighting your corner to try and safeguard your business and livelihood.

Here are our two principal concerns at what the Scottish Government have proposed:

  • The lack of parity of support with other self-caterers in the rest of the UK. This penalises a key component part of Scotland’s tourism offering compared to others in the UK and is something our membership could never support.
  • Self-catering has been designated as requiring additional eligibility compared to other small businesses in Scotland. Many other small businesses in Scotland are increasingly reliant on multiple sources of income.

With that in mind, we would like to understand the policy rationale for: (a) the differentiation applied in Scotland in terms of the grant support for self-caterers compared to the rest of the UK; and (b) why self-catering units are treated differently in respect of this grant compared to other small businesses with similar financial models.

We firmly believe that as this is a scheme that the UK Government is financing it should, therefore, be applied in a consistent manner throughout the UK, ensuring that Scottish self-caterers are not disadvantaged compared to others in the UK, or indeed other important sections of the small business community who need help in these challenging times.

If you have not already done so, we would strongly encourage you to contact your local MSP to highlight your concerns on this matter.

Fiona Campbell

Chief Executive, ASSC