Industry Unites to Demand Revisions to Legislation Before Implementation
The Scottish Licensed Trade Association (SLTA) and nearly 80 co-signatories representing thousands of tourism and hospitality businesses across Scotland, have today submitted a joint letter to the Scottish Government expressing serious concerns about the Visitor Levy in its current form.
The letter organised by the Scottish Tourism Alliance (STA), calls for urgent legislative changes to ensure the levy is simple, fair, and workable – and warns that, without reform, it risks harming Scotland’s visitor economy, placing unnecessary burdens on businesses, and undermining the country’s international competitiveness.
Backed by industry leaders, representative bodies, and local business voices, the letter outlines practical, legally viable solutions – and urges the Scottish Government to act swiftly and collaboratively to deliver a visitor levy that is truly fit for purpose.
Dear Minister for Public Finance,
Thank you for your recent meeting and follow-up correspondence (dated 19th May 2025), which sets out your commitment to ongoing engagement with the tourism and hospitality industry on the visitor levy.
The Scottish Tourism Alliance (STA), together with the undersigned industry collective and business colleagues with a direct interest in the sector, are writing to share our commitment to the Scottish Government’s positive partnership working through the New Deal for Business, to which the STA was a key contributor. This approach can and should ensure that the purpose, content, and timing of regulations always consider the potential opportunities and impacts on business and investment.
However, the sector and its partners firmly believe that, without urgent changes, the visitor levy will fail at the first hurdle of implementation, causing harm to both Scotland’s economy and individual businesses.
When the First Minister spoke at STA’s annual conference in March, the industry was heartened by his message which was loud and clear – stating that the visitor levy must be as simple and straightforward as possible to avoid damaging businesses and Scotland’s competitiveness and appeal as a destination.
At the Scottish Government’s invitation and keeping closely in mind the First Minister’s messaging about the importance of simplicity and getting things right, we have invested significant resource in identifying and creating a detailed set of constructive proposals to strengthen the levy framework.
As part of this work, key industry representatives came together via the STA to:
-Identify a potential legal route to amend the legislation through Section 78 of the Visitor Levy (Scotland) Act.
-Develop a simple, proportionate fixed fee approach for discussion.
-Identify a 21stcentury digital-first solution to remove the burden from accommodation providers collecting a levy by introducing a visitor QR code system paid directly to local authorities, aimed at reducing the time and financial burden on accommodation providers and avoiding the risk of small businesses being pushed over the VAT threshold.
However, following the meeting on 12th May we have been left disappointed that rather than exploring these ideas further, the Scottish Government currently plans to take no further action. We strongly believe that we cannot wait for the required three-year report on the operation of the Act.
It is frustrating and disheartening for a nationally significant sector that making any significant changes to the legislation is seen to be too challenging to deliver – despite the damage it risks inflicting on the business community, sector, and wider economy.
Building on the New Deal for Business, the Scottish Government has asked industry to tell them when they are getting things wrong and to present potential solutions.
The majority of the signatories were engaged in the pre-legislative discussions that took place. We remain committed to continuing to work constructively with you, other political parties, local authorities, and key stakeholders. Our primary aim being to ensure that we have a successful visitor levy scheme that ensures the right application at the right place and right time, if it is to act as a force for good that enhances our visitor offer and appeal.
Urgent legislative changes needed.
We share the Scottish Government’s ambitions to build a stronger economy and to make Scotland a world-leading visitor destination but are frustrated and very concerned that the visitor levy in its current form risks undermining that success. Taking a different approach to the rest of the UK on this policy is putting the sector at a competitive disadvantage and causing considerable complexity and unnecessary cost to businesses. Unfortunately, it is another example of a well-intentioned policy being badly implemented.
The STA will continue to gather the views of the industry and local authorities across all parts of Scotland to make the strongest and clearest case to the Scottish Government that it is essential to fix the legislation in its current form, which risks doing more damage than good for the sector and the wider Scottish economy.
Following our recent meeting, the STA and the Association of Scotland’s Self-Caterers have jointly sought legal opinion from Hazel Moffat, Partner at Burness Paull LLP, who heads up their public law and regulatory team.
Burness Paull LLP have advised that there is the option to introduce an Emergency Bill if it can be clearly demonstrated “that real harm will be caused to providers and/or guests in the absence of urgent changes to the 2024 Act.”
This could include issues relating to consumer pricing transparency, VAT thresholds, and the risks of inaccurate calculation and misinterpretation, which we know are all real challenges that are facing the sector because of the legislation as it currently stands.
The sector is also concerned that there is a risk of conflicting with UK Government legislation on price transparency and drip pricing under The Price Marking Order 2004 and The Digital Markets, Competition and Consumers Act 2024.
There are already precedents in the Scottish Parliament of passing legislation in under a year, for example COVID-19 emergency bills, Budget Acts, and correctional legislation following major stakeholder concerns or legal risks.
In a demonstration of the Scottish Government’s continued work to encourage better cross-party working, a Bill could also be introduced by an opposition party MSP to make changes to the charging and collection model, with the Scottish Government stepping in to legislate to give effect to the proposal, effectively “taking over” the Bill.
A third option would be to approach a Scottish Parliament Committee to propose a Committee Bill on the issue, although we acknowledge that this kind of Bill is rare.
Next steps
While we appreciate the time constraints of the parliamentary process, with strong political will, cross-party cooperation, and a streamlined legislative timetable, there is sufficient time if work begins soon to make these changes. Our discussions with opposition parties and local authorities indicate that there is a strong appetite to ensure we get this legislation right, with some councils indicating to us their preference for a fixed fee charge.
To avoid inadvertently damaging Scottish businesses and our economy at a time when we face a new set of emerging global economic threats, it is in the interests of the Scottish Government to deliver on its New Deal for Business commitment to listen to the sector and act on the issues we bring to you to protect and grow our economy.
With strong cross-party support, a Bill could be fast-tracked to address the most critical flaws and create a fit for purpose visitor levy framework, aligned with digital-first ambitions and Scotland’s wider economic goals.
If no changes are made to the legislation, there remain issues with the implementation of the Edinburgh levy for businesses by the 1st of October 2025. As was agreed with businesses and written into the original legislation, an 18-month implementation period was necessary to ensure preparedness for all parties. Without immediate intervention from Scottish Government, this date remains a cause of acute concern.
We welcome there are plans for VisitScotland to hold a series of stakeholder sessions to discuss practical concerns, and reiterate our call (correspondence dated 16 December 2024) for you to urgently convene a summit with the original members of the Visitor Levy Expert Group, alongside online booking platforms and destination management companies, to address the significant operational and commercial complexities that have and continue to arise in applying a visitor levy in practice.
We are aware that officials in local authorities are also raising similar concerns and calling for clarity. With Edinburgh’s proposed ‘go live’ date fast approaching, it is imperative that the existing guidance is urgently amended. Furthermore, Edinburgh accommodation providers including agencies and supporting channel managers have no dedicated guidance, leaving them in an untenable position as they prepare for implementation.
Without swift and coordinated action, we risk an unworkable system that will damage confidence and compliance across the sector.
Going forward, we ask you and the Scottish Government officials to:
1.Urgently explore in more detail the recommendations previously proposed in ‘Strengthening Scotland’s Visitor Levy Framework Proposal.’
2.Commit to make urgent improvements to the visitor levy by taking a joint party approach to identifying a legal vehicle to address outstanding issues, and work in collaboration with industry and local authorities to avoid causing unintended damage to the sector and wider economy.
3.Prioritise reconvening the Visitor Levy Expert Group to address the emerging issues in implementing a visitor levy scheme in Edinburgh, prioritising guidance for business.
4.Continue to work proactively on a timely basis with the sector and local authorities to take a collaborative path to ensure we have a visitor levy that is fit for purpose.
We are committed to continuing our close work with the Scottish Government on delivering for our nation’s economy and we look forward to progressing this urgent issue further with you.
It should be noted that the undersigned 78 signatories between them represent thousands of tourism and hospitality businesses across Scotland, and many in the sector’s vital supply chain.
STA Council members:
-The Scottish Tourism Alliance (STA)
-Association of Scotland’s Self-Caterers (ASSC)
-UKHospitality Scotland
-Scottish Bed & Breakfast Association (SBBA)
-Historic Houses Scotland
-British Holiday & Home Parks Association
-The Caravan, and Motorhome Club (CAMC)
-The Camping and Caravanning Club
-Hostelling Scotland
-UKinbound
-Scottish Destination Management Association (SDMA)
-Scottish Independent Tour Operators Association (SITOA)
-Scottish Inbound Golf Tour Operators’ Association (SIGTOA)
-Scottish Golf Tourism Development Group (SGTDG)
-Scottish Passenger Agents’ Association (SPAA)
-Scottish Tourist Guides Association (STGA)
-Wild Scotland
-Association of Scottish Visitor Attractions (ASVA)
-Association of Leading Visitor Attractions (ALVA)
-Scottish Agritourism
-Scottish Licensed Trade Association (SLTA)
-Scottish Beer & Pub Association (SBPA)
-Country Sport Scotland
-Sail Scotland
-Green Tourism
-National Outdoor Events Associations (NOEA)
Other business organisations:
-Scottish Financial Enterprise (SFE)
-Scottish Chambers of Commerce
-Institute of Directors (IoD) Scotland
-Aberdeen City & Shire Hotels Association (ACSHA)
-Edinburgh Hotels Association (EHA)
-Greater Glasgow Hoteliers Association (GGHA)
-Highland Hotels Association (HHA)
-Cairngorm Business Partnership
-Caithness Chamber of Commerce
-Inverness Chamber of Commerce
-Lochaber Chamber of Commerce
-Mid Argyll Chamber of Commerce
-Ayrshire Chamber of Commerce & Industry
-Scottish Hostels
-Scottish Hospitality Group (SHG)
-Argyll & the Isles Tourism Cooperative Ltd (AITC)
-VisitArran & The Arran Trust
-Visit Inverness Loch Ness
-Explore Islay and Jura
STA Board support:
-Booking.com
-Loch Melfort Hotel Ltd
-Abbey UK
-DF Concerts & Events
-P&J Live
-Coruisk House, Skye
25 independent tourism and hospitality businesses:
-This includes extended membership of the trade and business organisations listed, including corporate and independent hotel groups and individual operators. Following the submission of the letter to the Minister, note we continue to receive signatory support from hotels and smaller accommodation providers from across the country.
-This information has been anonymised in this version of the letter to protect the identities of private businesses that may not want their details in the public domain.