ASSC highlights that the council’s consultation lacks even the most basic requirements outlined in Scottish Government statutory guidance. For instance, there is no published draft scheme, no clear objectives or policy design, and no economic impact assessment. Instead, the council references support from the Glasgow City Region Intelligence Hub and offers an income forecast of £1.7 million – an arbitrary figure with no supporting data or context.

The consultation:

• Fails to publish a draft visitor levy scheme, with no detail on how the levy would work in practice.
• Omits any reference to exemptions, reimbursements, or other essential design elements.
• Is not clearly identified as the formal statutory consultation required under the Visitor Levy (Scotland) Act.
• Shows no evidence of engagement with statutory consultees, including local businesses, communities, or the tourism sector.
• Provides no supporting documents such as data, equality impact assessments, or details of how revenue would be used, all crucial for informed responses.
• Lacks transparency and accessibility, failing to present a clear evidence base.
• Offers no commitment to publish a consultation report that summarises and responds to public and stakeholder feedback.

In addition, West Dunbartonshire Council has set a timeline that pushes through the process in haste: the consultation closes later this month (21 October), yet a decision is due as early as November. This raises serious concerns about whether it is intent on pushing through a predetermined outcome under the pretence of consultation. Indeed, the council state: “…the following Draft Scheme has been prepared on the assumption that The Council will be proceeding with proposal to impose a Visitor Levy. The language used therefore reflects that assumption.”

Across Scotland, six local authorities have now postponed work on the introduction of a levy – with more expected to follow suit – recognising the complexity of getting it right first time and the importance of working with affected stakeholders. The Scottish Government has committed to consider granting powers to enable councils to pursue alternative charging models to the current percentage scheme.

Fiona Campbell, ASSC CEO, said: “This is not just a matter of poor consultation practice, it is a failure of governance and respect for due process.

“This botched exercise rests on assumptions rather than evidence, has a timeline of breakneck speed, and is very much consultation in name only. Quite frankly, the small businesses of West Dunbartonshire, who drive its tourist economy, deserve better.

“Right across Scotland, local authorities are taking the sensible and pragmatic step to halt work on the visitor levy. West Dunbartonshire Council should follow their lead rather than rushing ahead with an ill-considered scheme which will undermine the very industry it is intended to support.”