travel

GBTS Q4 and provisional 2023 domestic overnight stays results published

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Great Britain Tourism Survey (GBTS) the national survey of domestic overnight stay quarter four (Q4) survey results was published this week alongside the provisional results for 2023.  The headlines figures generally show a decline in trips and value in 2023 as compared to 2022, particular around holiday trips, an especially important trip purpose, for well-established popular rural and urban destinations, not least in the main summer season. This downturn is in line with the mainly anecdotal reports received from our largely well-establish, popular rural and urban inland and coastal destination membership. There are of course outlayers and exceptions to every generalised rule.

The full year results are, as ever, subject to normal review as more information becomes available. Beyond that, this year there are apparently some concerns about the new methodology adopted in 2021 a covid disrupted year and subsequently used for 2022 and 2023. Colleagues will recall that there was no GBTS in 2000 during the peak of the covid restrictions.

As a consequence, the methodology is under review and it is now intended to re-run the 2022 and 2023 results, the first two full post pandemic years, once the review is concluded and the methodology suitable adjusted.  This will impact on GB results and on the subsets for all the Home Nations and English regions, all of which will in due course receive revised statistics for both 2022 and 2023. Receiving revised historic data can be problematic depending on what usage the original has already been put to. Revision is unavoidable and preferable to the alternative options, all of which would involve carrying on regardless and compounding identifiable issues in each subsequent year.

Colleagues will already be aware methodology changes made during the covid period means that post and pre covid (2019 inclusive) GBTS reports and results are not comparable. At best most destination managers view this a regrettable and perhaps a little unhelpful when trying to manage an ongoing post-covid recovery. Again it falls into the unavoidable category as change in methodology was overdue and doing it when tourism was in chaos was a good, if not better, time than any other.

I would urge colleagues reading this year’s report(s) not to skip the “technical stuff” at the head of the document.  The short description of the methodical review, in this instance, is critical to the proper interpretation and understanding of confidence levels.  The more detailed material referenced and linked within it will be of greater use to those more directly involved in the routine use and/or production of local tourism statistics.

The Visit Britain/Visit England (VB/VE) version of the report which majors on GB and English regional results, contains links in its introduction to the VisitScotland and Visit Wales reports which giving a similar GB overview and specific to Home Nation data. 

The VB/VE reports summary states:

  • The current data show a decline in 2023 overnight trips by 7% for both Great Britain and England.
  • These declines seem to be driven by holiday trips, which dropped by 14%, and represent the second largest share of trips (32% in Britain and 31% in England).
  • On the other hand, UK overnight stays as part of an overseas trip show an increase of 14% in Britain and 19% in England (implying an increase in outbound trips).
  • In 2023, a city or large town was a destination type with the largest share, 44% in Britain and 45% in England.
  • 45% of overnight trips in Britain / England included serviced accommodation.

And the text in the accompanying graphic tables states:

2023 domestic overnight trips in Great Britain.

  • 117.3m trips (down 7% vs 2022)
  • £30.9bn total spend (down 6% vs 2022 in nominal terms, down 12% in real terms)
  • £264 spend per trip (up 1% vs 2022 in nominal terms, down 6% in real terms)

2023 domestic overnight trips in England

  • 99.2m trips (down 7% vs 2022)
  • £25.7bn total spend (down 7% vs 2022 in nominal terms, down 13% in real terms)
  • £259 spend per trip (up 1% vs 2022 in nominal terms, down 6% in real terms)

The statement regarding the methodology review in the full report makes it very clear that there are particular concerns regarding the last quarter of 2023 and the scale of declines reported between Q4 2022 and Q4 2023. It gives the example of a 20% GB decline in overall trips and this being thought to be improbably and not supported by other sources.  As a consequence the Q4, the report focuses almost entirely on the more robust full year results.

The summary makes reference to what I believe is a new category of accommodation usage introduced in 2021, “overnight stays as part of an overseas trip”. I have no recollection of any such a category appearing in or before 2019 GBTS or UKTS before it.  Having noted a 14% decline in holiday trips in bullet point 2, the summary goes on to say in bullet 3: “On the other hand, UK overnight stays as part of an overseas trip show an increase of 14% in Britain and 19% in England (implying an increase in outbound trips)”.

The bracketed comment “implying an increase in outbound trips” is intriguing. We would of course concur with the assessment and would probably go much further, regarding the very obvious negative impact of domestic outbound travel on domestic tourism. 

Personally, I was taken slightly aback by the comment and the use of the word “implies”.  Based largely upon historic experience of the pre 2020 GBTS data sets, I would have reasonably expected colleague in ONS and the Tourist Boards to know what the outbound trip figure might be, or at least what they might be looking like at this point in the year. More importantly I would fully have expect the annual GBTS report to include data and specific comparative comment on domestic outbound trips, as they traditional did pre pandemic.   The absence of such comment in the 2021 and 2022 report, I am embarrassed to say seems to have passed me by until now, although I don’t appear to be alone in this. I am assuming this may be down to covid and post covid disruption and not due to any lack of interest in key national data on my part.

The outbound data, I had erroneously assumed, was derived from the GBTS survey itself, a fault in memory.  On reflection and on checking, I was reminded that it actually comes from the International Passenger Survey (IPS) and was indeed routinely included within the old style GBTS annual reporting.  I also believe that the revised IPS is undergoing similar methodological review and that some of the data recently available is likely to be re-run (?).  I am therefore assuming (hoping) that the absence of domestic out bound data is an implication of the ongoing methodology reviews on both new survey methodologies, rather than any conscious decision made by the tourist boards partnership not to include contextually vital outbound domestic (IPS run by ONS) comparison figure in the new GBTS annual reports. 

Rather than delaying circulating a reminder of the availability of the latest GBTS annual report and some brief comment on the detail until I have bottomed out what is or isn’t occurring with the domestic outbound figures, something which could take days or even weeks, I am publishing the reminder and commentary now.  I do so with some reluctance and apologies in advance to colleagues in ONS and the National Boards. I have no desire to set hares running unnecessarily or to fallout with colleagues whose work I have the greatest admiration for. I am very hopeful that I have either got entirely the wrong end of the stick or that there is a very good, preferably tempory reason why outbound figure aren’t or can’t be included in the new style GBTS reports. 

If, however, it does transpire that the use of outbound domestic tourism figure has been dropped within the GBTS annual reporting process, I would hope that most colleagues and certainly those in destination management, would agree that this would be a serious retrograde step. Denying, as it does, tourism practitioners and lay statistics users’ easy access, to a single source of vital headline data which puts the performance of UK/GB, Home Nation and English regional overnight trips in their full and proper context. It also forms an important part of the lobbying tool box when seeking to evidence the need for appropriate support at differing levels for domestic tourism.

I will let you know what I find out and what, if anything, might need to be done as a result to ensure this information is included in future GBTS annual reports or, failing that, is made available in a comparable form elsewhere.

The 2023 VB/VE report, including links to the other board’s reports can be accessed at:

https://www.visitbritain.org/research-insights/great-britain-domestic-overnight-trips-latest-results

Thoughts on headline UK economic performance and domestic GBTS third quarter 2023 results.

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Wednesday’s announcement that January’s inflation rate held steady at 4% against December’s rate, itself an unexpected marginal increase, was somewhat disappointing.  As was yesterday’s announcement that the UK economy had slipped into a technically recession (two negative quarters in succession) in the latter half of 2023, although thankfully at a very shallow level.  As ever these monthly and the latest quarterly estimates are subject to later revision, either way, as more detailed data becomes available.

Despite the disappointing news, the general consensus remains that the economy is still recovering from, among other things: inflation, increased interest rates, higher fuel and energy costs and a cost-of-living crisis, albeit, now it seems, recovering at a marginally slower pace than previously predicted or hoped for.   In response to the inflation rate announcement, and clearly already aware of recessionary announcements about to be made, the Governor of the Bank of England (BoE) suggested on Wednesday that expectations in some quarters of an early cut in the base rate was premature. 

BoE’s base rate remains the key tool in managing inflation and achieving the Government’s and the BoE’s target of 2% inflation. Returning to the glory days, of a pre-mid 2022 sub 1% base rate (2009 to May 2022) isn’t currently even an aspiration, with something in the order of 4% base interest rate being a more realistic 5-year (and well beyond?) ambition.  Interest rates are the key tool in managing the economy because for the vast majority they dictate how much disposable income is left in the average household’s pocket after unavoidable living costs, like mortgages, are covered and, hence, what can be spent on discretionary activities.  In its turn suppressed demand acts as, among other things, a break on inflation and higher wage demands.   As we are all only too well aware, discretionary activities and discretionary spending encompasses every aspect of the visitor economy from a pint or meal out to events, shows, theatre, through to days out, short breaks and longer holidays and much of the ancillary spending that it all entails. The visitor economy unfortunately sits in the eye of the now slowly waning economic storm.

Greater minds than mine and yours can agonise over the detail and the twists and turns of their implications of the headline economic news for the wider UK economy. For our purposes in domestic tourism, it is probably sufficient to note that the recovery is still underway but, as we had long since  determined, it isn’t going to reach the tipping point at which the cost of borrowing and the cost of energy, goods, supplies and services for both consumers and businesses and wage pressures on business are going to fall sufficiently far, or sufficiently fast enough to generate the levels of disposable income needed to trigger a marked improvement in the overall performance for the coming 2024 shoulder and main summer seasons, over and above the performance experienced in 2023. For 2025, perhaps but too early yet to call? Meanwhile, there is attitudinal evidence that main, often overseas holidays, are being prioritized, and increasingly, if necessary, at the direct expense of other, usually domestic based, visitor economy activity. A potential double whammy for the domestic industry?

Less disposable income can but doesn’t necessarily always mean markedly lower visitor volumes but it generally does mean restricted activity, shorter duration and all most always less or more carefully target spending (value). Consumer confidence is also critical factor.  Confidence tends to lag someway behind the economic reality. While this year the certain prospect of general election and the political manoeuvring and uncertainties these generate and then magnifies, also tend to add to public uncertainty and further dent consumer confidence. Unless and until there is much more positive economic news and more political clarity, consumer confidence is likely to remain unusually subdued during 2024.

Certain individual businesses, certain sectors, certain destination types or locations, did of course do relatively well in the internal domestic tourism market in 2023.  While, worryingly and at some yet indeterminant direct cost to the UK’s visitor economy, domestic outbound tourism values and volumes recovered strongly toward, or in some case to, or beyond 2019 levels. This said, it is indisputable that many other (the vast majority?) of domestic tourism businesses did rather less well in 2023 than the during the immediate post-covid domestic spike and certainly less well than they needed to do in order to sustain a fragile recovery to anything like pre-covid levels or, critically, to make good their own more recent additional costs.

The hard evidence to support these assertions, is like much else in tourism, currently thin on the ground, but there is plenty of anecdotal evidence to suggest and hard evidence slowly emerging, that investment in all aspects of business is being curtailed from: promotion through staff numbers and training, to refurbishment and development. Measures like adopting shorter hours, opening on fewer days of the week, deploying fewer staff when open and/or a general return to old patterns of seasonality are all on the increase.  These are the very things that the domestic tourism industry, the National Tourist Boards and Government and Government Departments have worked to try to address and rectify over the last 20 plus years. Worryingly many of these potential “knee jerk” but necessary measures undermine the tourism industry’s contribution to the economy and local employment. That isn’t good news from a national lobbying, let alone from the real world local economic prospective.

If the legacy of the post-covid and recent economic crisis is to catapulting the domestic offer back, even in part, to its pre-2000 (pre mid 1990s?) state, then that would be a local, regional and national social and economic disaster.  Fixing the economy as soon as practically possible is clearly a key part of the solution, but also addressing some well-known and longstanding structural and policy issues that have become more, rather than less critical since the 2020 covid pandemic wouldn’t now go amiss. I will not bore members and others with the full list as hopefully you are as, if not more, aware than I am of the key national strategy and policy weaknesses. If you are unsure, then please ask me.

If the problems of a weaker or truncated and, therefore, less appealing offer are as wide spread as we suspect (know but can’t yet formally evidence), then that this is a serious retrograde step for the domestic tourism industry. Another generally lacklustre season for the average tourism/visitor economy business, in the average destination, targeting the average demographic and average UK customer is not particularly good news for the ubiquitous tourism industry, nor is it, good news for the multitude of local visitor economies underpinned by tourism and, thus, nor is it good news for the UK in general as it struggles with economy recovery. Whether the current or any other Westminster Government will have the wisdom to understand that fixing the economy in general is only the first step needed to fully fix the domestic tourism industry, remains to be seen. 

The very real prospect of a major change in Government does give us a once in a decade or two, opportunity to revisit and refresh some of the longstanding strategic issues.  For example, Treasury’s insistence on regarding domestic tourism as a general economic displacement activity and therefore seldom worthy of targeted publicly funded support.  Or specifically their reluctance to understand that the choice isn’t a simple false dichotomy between spending money somewhere in the visitor economy in the UK or spending the same money on something, somewhere else in the UK economy, ergo no real loss or gain to the UK as a whole and therefore no real grounds for public intervention for domestic tourism.  Since as early as the mid 1970’s it has been a trichotomy with a strongly competing and a far more logical alternative to either spending on tourism or other things at home; that of spending your annually allotted tourism pounds in the visitor economies abroad. The sums involved in outbound domestic tourism have now grown so large that even a few percentage point shift in favour of purely domestic activity would make a significant difference to local and UK’s economic performance.

Accepting, as we must, that some but by no means all of the money spent by UK residents (an estimated £58.5bn in 2022 alone) ended up being retained in the UK by a number of generally large and well placed UK based companies including: travel agents, travel companies and some air and sea transport providers, there remains an obvious and very large economic issue. Surely no sane Government, particularly in a new post Brexit environment, should ignore clear opportunities to try harder to retain more domestic tourism domestically? Unfortunately, to my knowledge at least, largely ignoring it is precisely what has been happening and by slow but fairly regular increments increasingly so over the last three decades.  

By a rather timely coincidence, the key 2023 third quarter Great British Tourism Survey Results (GBTS) have just been published.  Figures for domestic overnight tourism in Scotland, Wales and England taken across the board show that less volume was generally achieved in these key main summer holiday months of July to September in 2023 as compared to 2022. However, notably while year to date volumes held real, as opposed to nominal unadjusted, values generally fared less well.  The performance is worrying, albeit given the thrust of some of my comments above, hardly unexpected.

Rather than me detailing or trying to analysing the GB and home nation variations within that, I would urge colleagues to find the time to look at either the VB/VE statistics for GB and England which include English regional break downs, or the equivalent Visit Wales or Visit Scotland reports as appropriate. As ever I was struck by the scale and, I feel, the underappreciated role and, potentially therefore, the under exploited value of Visiting Friends and Relatives (VFR).  In economically challenging times VFR may have a potentially greater role in driving much needed ancillary spend noting of course that VFR does automatic or always equate to staying with relatives and friends.  

The full report itself (containing links for Scotland and Wales data) can be accessed at: https://www.visitbritain.org/research-insights/great-britain-domestic-overnight-trips-latest-results .

For your immediate reference the summary paragraph from the VB/VE report is copied below: 

In Q3 2023, there was a decline in domestic overnight trips compared to Q3 2022, the trips were shorter and the spend on these trips was lower. 2023 YTD figures show also a decline in visits and real spend vs 2022, although to a smaller extent.

Great Britain

• In Q3 2023, there were 35.7 million overnight trips in Great Britain (down 4% vs Q3 2022) made by British residents between July to September 2023. These trips lasted a total of 112.2 million nights (down 9% vs Q3 2022) and contributed a total of £9.6bn in spend (down 7% vs Q3 2022). • In Q3 2023, British residents spent on average £268 per their domestic overnight trip (down 3% vs Q3 2022) and £85 per night of their trip (up 2% vs Q3 2022). Their trip in Great Britain lasted on average 3.1 nights (down 5% vs Q3 2022). • 2023 year to date (YTD) Great Britain visits were down 1% on 2022 YTD, with spend up 2% in nominal terms, although down 6% in real terms. The number of nights down 7% on 2022 YTD. • In terms of trip purpose of overnight trips in Britain in Q3 2023, visiting friends and relatives remained fairly in line with Q3 2022 (just 1% down), while holiday trips declined by 12% (despite the decline, keeping the largest share, 37% of all Great Britain overnight trips).

England

• In Q3 2023, there were 29.8 million overnight trips in England (down 5% vs Q3 2022) made by British residents between July to September 2023. These trips lasted a total of 92.3 million nights (down 9% vs Q3 2022) and contributed a total of £7.8bn in spend (down 10% vs Q3 2022). • In Q3 2023, Great Britain residents spent on average £262 per trip in England (down 4% vs Q3 2022) and £85 per night of their trip (down 1% vs Q3 2022). Their trip in England lasted on average 3.1 nights (down 4% vs Q3 2022). • 2023 year to date (YTD) England visits were down 2% on 2022 YTD, with spend up 1% in nominal terms, although down 7% in real terms. The number of nights down 6% on 2022 YTD. • In terms of trip purpose of overnight trips in England in Q3 2023, visiting friends and relatives remained fairly in line with Q3 2022 (just 1% down), while holiday trips declined by 15% (despite the decline, keeping the largest share, 36% of all England overnight trips).

Note: All value comparisons are in nominal terms, not taking inflation into account, unless otherwise stated. Great Britain Tourism Survey – VisitEngland, VisitScotland and Visit Wales

Digital Markets, Competition and Consumer Bill (UK wide), Price Drip Feeding and Fake Reviews in Tourism.

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You may have seen a flurry of recent media report concerning the Digital Markets, Competition and Consumer Bill (DMCCB) first introduced last April and making way through Parliamentary with the target date for UK wide introduction (but not necessarily immediate enforcement) later in 2024. This follows a Department for Business & Trade (DBT) press release update issued on 24 January, the key comments of which is that the Department “will officially add fake reviews to a list of banned business practices, outlaw dripped fees that are unavoidable for consumers and ensure that businesses provide clearer labelling for prices on supermarket shelves.” (my added emphasise not DBT’s).   The Bill covers all industry sectors, but it does have particular resonance to travel, tourism, leisure, culture arts, theatre, live performances, events and retail and therefore, to much of the wider visitor economy.

None of the announcement is absolutely new but it serves to confirm, following consultation and some amendments to the Bill in its passage through the two House of Parliament (Lord yet to complete and Commons, final consideration to follow that) what DBT now intend to include, or not, in the final Bill.  A Bill that will dictate what is included in the guidance to all industries that the Competition and Markets Authority (CMA), a non-ministerial government department, must then in due course apply.  The Bill is probably now sufficiently well developed to be swept up in the dissolution of Parliament process, should an earlier general election be called, before the currently anticipated “second half of 2024” date indicated by the PM.

The Bill itself aimed to: introduces a new digital marketing regime, strengthens consumer protections and improve CMA’s investigation and enforcement powers.  Powers that will including the ability to impose penalties directly without, long, slow recourse to the Courts and significantly increased upper limits for penalties for larger players in the digit market place.  What then, if anything, does the latest press release actually tell us or confirm?

Fake review, as expected, are to be “added to the list of banned practice” and critically “with webhosts held accountable for reviews on their pages”.  I doubt colleagues in destination management or in tourism businesses more generally would oppose either of these proposed actions.  However, like me, many would recognise that accountability, is not yet an as well-established general principle for all platforms for all product sold or promoted within digital market place, as it perhaps should be? Many well-known online accommodation platforms having no legal and arguably take little moral responsibility for the accuracy or indeed basic safety of the product they list.  If they can legally list properties without ensuring that they have basic permissions and safety checks in place, then I am not entirely sure what “being held accountable for reviews” might actually means or achieve in practice. My view may be jaundiced by overly long exposure to the long overdue and still unresolved statutory registration of accommodation debate? I remain sceptical of getting this one over the line in England in what remains of this Parliamentary session but that’s another story.

I believe that there is understandable concern that the Bill and CMA’s aims may focus too sharply on consumer protection.  In the case of fake reviews focusing in on overselling or “bigging up” the offer via paid for or other forms of fake or falsely obtained reviews to the detriment of the consumer who is falsely sold a potentially inferior product than that they may otherwise have chosen.  Businesses, are equally and rightly concerned about fake negative review which by default are likely to sit only on third party sites, as businesses are unlikely to tolerate fake negatives about themselves on site they operate and can control.  Being wrongly deterred from purchasing a perfectly good product may be potentially regarded as less of a “consumer protection” issues?  Therefore, more work may be needed to adequately addressed the issue of malicious reviews within the final stages of the Bill and as subsequent CMA guidance is developed?  Regardless of the unjustifiable harm done to businesses, fake negatives can and do distort the market and falsely reducing or limiting informed consumer choice.

Again, as broadly expected following similar update announcements in November 2023, the news that DBT are to “outlaw dripped fees that are unavoidable” confirms that the measures aimed to tackle price drip feeding are going to be far more limited than perhaps first envisage a year plus ago and certainly they will not physically reduce the actual overall cost of some often big-value goods and service, as many consumers hoped for and (still?) erroneously assume.  In essence, the new regulation tackles things like compulsorily handling, booking, delivery or other fees or mandatory insurance on goods and service that are added to the original headline price toward or at the end of the purchase process and are thus “unavoidable” if the purchase is to be completed. In terms of domestic tourism this is likely to impact on current practices in areas like events, theatre, entertainment and public transport and some, mainly smaller (?), accommodation booking arrangements. 

My understanding, and I could well be wrong, is that common practices like promoting “ticket from £XYZ, handling/booking/delivery fee apply”, will no longer be permitted and thus the likes of say the Trainline will no longer be able to headline a ticket from X to Y at say £110.50 and then add a nominal £1.50 booking fee at checkout but will now have to offer the journey upfront at £112.  In many instances that may involve little more than a site redesign?  Most budget airlines, for example, have long since abandoned the practice of adding APD or booking fees as an afterthought to the booking process; it a design not a process issue, albeit for something like rail travel involving millions of potential price points, a complex one.  For other smaller businesses, in particular, it may, and I stress may have some impact on fragile business models, or involve relatively large corrective costs compared to the returns available at the individual business level. 

For the likes of the Trainline and many of the major third-party booking platforms this is something that they will just get on and do and, in due course, inform their business stakeholders and customers what the changes will be.  For individual destinations and businesses running their own digital booking arrangements, or working with others, to sell (digitally promote) goods and services such as event tickets, my considered advise would be that: unless you can make obvious potentially necessary changes now, with little or no effort or cost attached, then sit tight and await the CMA guidance which is at the very least 2 to 3 months away and which in any case cannot and will not come it effect overnight once published.  I would be surprised if the implementation, let alone enforcement date for small businesses would be this side of October 2024 and could well be much later, even into 2025, assuming the guidance does appear in late spring or into the early summer. 

When implemented and an enforcement date is announced I think it likely that CMA’s interests will be fixed initially on major national and international players and will only shift to the “Visit Some Where’s website or question the validity of the “reviews or the headline digital price for the “Some Where Inn” at some later date.  My understanding which again may be wrong, is that the CMA tend toward investigating complaints, having more than enough to do for now, without actively going looking for minor infringements themselves. Minor infringement or infringement of whatever size by minor players will get picked up but not on day one and probably not until the new system is embedded and well understood by both the industry the consumer.    I am not encouraging compliancy, just trying to be pragmatic, especially now as we rapidly approach the start of another critical main summer season.

What the Bill and guidance isn’t going to do is impact on avoidable consumer cost, most notable in the airline industry and things like choice of seating, priority boarding, additional baggage or other “upgrades.”  If it is possible to fly from X to Y clutching your worldly good in a handbag or carrier bag, having queued up at every stage, accepting whatever seat allocated, bring your own food and drink or whatever for £XYZ, then £XYZ remains the headline price that can be promoted and offered at the start of the digital transaction. 

If you then choose to add pre booked meals, priority check in, security lane or boarding, bring more than your keys and wallet; some baggage with you perhaps? then it remains permissible to add those, “avoidable” extras during the booking process and pay a higher final price at checkout than the headline price offered at the beginning of it. On the same basis a hotel or other accommodation provider should be able to offer a standard room at £XZ upfront but then gives the option to upgrade to a better standard of room or add genuinely optional services as the booking process progresses. The bar to offering additional services like a round of golf, transport to the local station or whatever for many smaller providers remains the Package Travel and Linked Arrangements Regulation 2018 not the DMCCB Again that’s yet another regulatory issue for domestic tourism, that has still to be addressed.

These largely reasonable concessions outlined above do tend by default to apply more to often bigger ticket item, outbound international travel, than they do to domestic tourism and domestic goods and tourism services.  On a brighter note, it does seem that DBT have accepted that a B&B (Bed and Breakfast) or similar establishment can offer bed only and thus sell an avoidable breakfast element as an addition. Again, I would advise colleagues and smaller individual business to await the development of the guidance over the coming months, if not the publication of the full guidance itself, before speculating or investing too much time and effort into preparing for expected restrictions or indeed for promised or hoped for concessions which may still be subject to a significant degree of interpretation and detailed definition.  Not unreasonably, most of the major individual trade association are already all over the individual and nuanced issues involved for their individual tourism sub sectors and they will continue to engage with DBT and CMA over the coming months, as I will for destinations and their constituent businesses, where and when the need arises. 

From a destination management prospective, beyond reassuring local businesses that there is no need for any immediate action for the coming main season and only limited prospect for anything major much beyond that, I would be doing a quick “back of a fag packet” assessment of ticketed events and activities that are run internally or facilitated for others through my digital channels.  I would be checking what if any consumer reviews facilities I might have or host for others on any internally run digital platform. In that way I would at least know if the Bill when it comes into force had any direct impact on anything I currently do.  I might also be checking with my website providers, ticketing agents and other digital platforms that offer online sales transactions for me, or through me for my partner businesses, what their take on implications of the DMCCB might be. If at this stage they don’t have one, then I might start to be concerned!  That said I would reiterate I don’t see any possibility of implementation and critically enforcement this side of the start of the main summer school holidays in mid to late July and very little chance of there being much if any this side of October and quite possibly much later.  Only when the guidance has been developed and possibly only when issued in the coming days, weeks or months ahead will we be absolute certain of the intended implementation and associated enforcement dates.  If and when I find out a date or get some further indication members will be the first to know.

If you have any concern, particularly from a destination perspective, or have had concerns raised to you from individual businesses that are not adequately addressed in my thumbnail sketch above then please let me know ASAP.  I can then raise these either with DBT, CMA directly or the appropriate partner, Trade Associations via our Tourism Alliance channels. Equally if you have any specific questions from businesses, I am happy to try to get tailored answers for you, for them, from the colleagues in the relevant trade bodies who are the subject experts on the various sub sectors from beer and pubs through accommodation in all its many and various glorious forms, to heritage railways and much else besides.

DBT press release is at: https://www.gov.uk/government/news/new-laws-set-to-ban-mandatory-hidden-fees-from-online-shopping-saving-money-for-consumers