On 27 September 2021, the Local Government, Housing and Planning Committee launched an online survey to gather views on the Scottish Government’s plans to require local authorities to introduce a licensing scheme for short-term let accommodation. The closing date for submissions was Friday 29 October 2021.
The responses were published today. The analysis was undertaken by SPICe, the independent research unit at the Scottish Parliament.
1237 of the 2578 responses were from owners of short-term lets.
- Most of the respondents opposed the licensing scheme.
- When those who opposed the scheme were asked how it could be improved, some highlighted the ASSC’s registration proposal.
The largest single group of respondents within the “other” category, accounting for 60 (22.3%) of responses, were the owners/operators of bed and breakfast accommodation or guest houses. Of the 60 owners/operators of bed and breakfast or guest house accommodation that responded under “other”, 27 (45%) are strongly opposed to the proposed licensing system and 11 (18%) are opposed.
848 respondents who were opposed or strongly opposed to the proposed licensing system also gave additional reasons to support their view. The key themes were:
- The proposed licensing system is wholly disproportionate to the problems it is trying to solve, which are mainly limited to a small number of urban locales (principally central Edinburgh).
- There is no robust data to support the proposed licensing system.
- The proposed licensing system should not apply to traditional Bed and Breakfast accommodation, including small Guest Houses, as these comply with relevant legislation and do not cause issues for neighbours or surrounding communities.
- Many short-term let premises are already registered and inspected by Visit Scotland, the proposed licensing scheme introduces unnecessary duplication and cost.
- The proposed licensing scheme should not apply to traditional self-catering accommodation, which already complies with the relevant health and safety requirements.
- The proposed licensing scheme should not apply to properties built specifically as short-term lets.
- The proposed licensing scheme places an additional burden on already stretched local authority budgets and staff.
The loss of short-term lets caused by the proposed licensing scheme could limit choice for travellers and result in job losses amongst tourism businesses and companies that support short-term letting, such as cleaning, laundry, and property maintenance.
In response to the question regarding how the scheme could be improved, key themes included:
- The proposed Scotland-wide licensing regime should be scrapped, as it is:
o disproportionate to the problems it claims to tackle
o duplicates work already undertaken by VisitScotland
o unfairly penalises the vast majority of short-term let owners, who provide a high level of service and comply with or exceed current regulatory requirements.
o unclear what problems the proposed scheme is actually trying to address. - The registration scheme suggested by the Association of Scotland’s Self-Caterers (ASSC) should be taken forward instead of the proposed licensing system.
- The proposed licensing system should not apply to traditional Bed and Breakfast accommodation, including small Guest Houses, as these comply with relevant legislation and do not cause issues for neighbours or surrounding communities.
- Any licensing or registration system must take account of the different challenges facing short-term lets in urban and rural areas.
- A license should not be required for any property managed by a professional owner/agent and/or accredited by an established trade body such as Visit Scotland or the AA.
- Licensing of short-term lets should only be introduced in those areas experiencing problems, principally central Edinburgh.
- Licences should automatically renew, unless there is evidence of non-compliance with licence conditions.
- Licensing fees should be as low as possible and set at a national level, preventing local authorities from using the system to raise additional revenue.