Written evidence submitted by Airbnb

Promoting Britain abroad: Airbnb response

Introduction

Airbnb welcomes the opportunity to contribute to this inquiry. COVID-19 has significantly impacted the tourism sector, and while we have seen progress towards a recovery, the Omicron variant makes it clear that the industry will face further challenges in the months - or even years - ahead. However, we look forward to working closely with the Government, policymakers in the UK, and the rest of our sector to ensure that we take advantage of the opportunity to shape a resilient and sustainable recovery.

The past two years have been incredibly challenging for everyone in the UK tourism and hospitality sector. We would like to thank the Committee for the opportunity to share the proactive steps we have taken throughout this crisis, as well as plans for the recovery of our business in the future.

As such, we have structured our response around the following areas: 

●        The impact of COVID-19 on our business and the Airbnb community

●        The UK as a world leading travel destination

●        Working in partnership with communities

●        The Tourism Recovery plan

●        Airbnb’s short-term lets registration proposal

As we hopefully look towards a stronger year for tourism, we’d like to request the Committee’s attention to the following:

●        Barriers to inbound international visitors must be resolved in the short-term - Tourism has been disproportionately affected by the COVID-19 recovery and the road to recovery is still fragile. The operating environment for tourism and travel continues to be uncertain and inconsistent across the UK, disrupted by changing government guidance on testing requirements. This has affected inbound and outbound travel in particular, and we ask the Government for more clarity on planning for future restrictions in 2022. 

●        The Government must increase resources to aid tourism recovery in urban areas - Airbnb is committed to focusing on the country’s urban recovery and the need to attract visitors to the UK’s great cities, which have suffered from major tourism shortfalls throughout 2021. However, Government assistance is vital to get cities back on track. Joined up and consistent action is essential to promote London - as both an important market in its own right and a gateway to the rest of Britain.

●        Large scale events play a key role in promoting Britain abroad - the UK must retain its ‘open for business’ approach if tourism is to flourish in post-Brexit Britain. With upcoming large-scale sporting and cultural events in 2022, we ask that the UK Government work in partnership with the whole tourism industry, as early as possible, on accommodation capacity programmes, to ensure that the UK does not experience accommodation shortages for large scale events (as was evident in the run up to COP26). Airbnb would be pleased to work with governments and event organisers to help scale up accommodation capacity where necessary, giving the UK access to a more flexible and sustainable accommodation supply.

●        Future regulation plays a role in the sustainability of accommodation capacity - Airbnb believes that a national registration system for short-term lets is a vital step that the Government should take. This would give the Government a solid evidence base, enabling them to make sensible policy decisions about this sector in local communities, and contribute positively to both housing supply challenges and economic growth. Airbnb’s Whitepaper, published in June 2021, proposes that a registration system should be targeted, proportionate, transparent, accountable and consistent. The licensing system as proposed in Scotland would constitute a barrier to trade, significantly reducing accommodation capacity across the country.

As travel looks to return, we know that both domestic and international consumers are looking for places to travel that are local, affordable and safe. This crisis has sharpened our focus to get back to our roots and focus on what is truly special about Airbnb - everyday people who host their homes and offer experiences. We would like to keep the Committee updated on our work to promote the recovery of UK tourism, working in partnership with communities, destination marketing organisations, and policymakers.

Introduction to Airbnb

Airbnb was born in 2007 when two Hosts welcomed three guests to their San Francisco home, and has since grown to 4 million Hosts who have welcomed more than 1 billion guest arrivals in almost every country across the globe. Every day, Hosts offer one-of-a-kind stays and unique Experiences that make it possible for guests to experience the world in a more authentic, connected way.

Airbnb has helped millions of hospitality entrepreneurs monetise their spaces and their passions while keeping the financial benefits of tourism in their own, local communities. Travellers (who we call “guests”) and providers of accommodation and local experiences (who we refer to as “Hosts”) meet, connect and transact directly with one another via our website. Across the UK, the majority of Hosts share a space in their own home and nearly a third of UK Hosts say that the additional income is an economic lifeline.

Hosts on Airbnb can take advantage of the platform in several ways. Some choose to share their entire home; this may be their primary residence that they make available to Airbnb guests when they themselves go on holiday, or it may be a second home in a city or a more rural location, which would not be utilised otherwise. A large proportion of hosts on Airbnb share their home by listing a private bedroom in their primary residence. This allows hosts the flexibility to maximise space in their home, benefiting from the additional income, and social interaction, without having to commit to a full-time tennant. Shared rooms are also popular among flexible travellers looking for new friends and budget-friendly stays. In addition, countless boutique hotels and bed and breakfasts are now using Airbnb to offer the kind of local, unique and authentic travel experiences that Airbnb is known for. The variety of listings available on the platform helps travellers visit the UK by offering flexibility in destination, accommodation and costs.

We also learned that people want to travel around their interests and so we built a platform that offers a wide range of activities offered by local experts. Airbnb Experiences are one-of-a-kind activities designed and hosted by locals. Unlike a typical tour or workshop, experiences go beyond the activities themselves. They offer a deep-dive into the local Host's world through their passion.

To put the sharing platform industry into context, it has been found that 23% of the UK population use sharing platforms like Airbnb and 78% of 18-24 year-olds use sharing economy services.[1] The ONS estimates that 28% of adults have used an intermediary app to book accommodation from another private individual.[2]

The impact of COVID-19 on our business and the Airbnb community

Airbnb is built on the foundations of helping people afford their homes and making communities stronger. Across the UK, nearly a third of UK Hosts say that the additional income is an economic lifeline. We believe our success is tied to that of our stakeholders and to making a positive contribution to the communities that Hosts on Airbnb call home.

The United Kingdom is a key market for our business. We want to serve and strengthen local communities by growing our people-to-people model of sustainable tourism right across the UK, particularly in areas outside of traditional tourist hotspots.

The recovery from COVID-19 will take time and will be challenging. But we are committed to working with government, tourism organisations and local communities to preserve the positive changes in travel that have emerged over the last year and restore tourism in a way that works for communities and visitors alike.

Despite the rise in local staycations in the UK in the summer months, Oxford Economics does not predict tourism in the UK to return in full to 2019 levels of volume and expenditure until 2025/6.[3] If the tourism sector is not supported in its recovery then it is possible that this return to pre-pandemic levels is delayed further. This would have a large impact on local businesses and the hospitality sector around the UK that rely heavily on tourism to support livelihoods.

As such, regulation must support the sector and promote the swift return to pre-pandemic traveller numbers and corresponding revenues by ensuring that travel into and around the UK remains as easy and as enjoyable an experience as possible.

Airbnb plays an important role in the UK’s COVID-19 tourism recovery by delivering positive, safe travel experiences and ensuring the benefits of tourism are spread to local communities. In 2019, Hosts and guests on Airbnb generated an estimated £5.1 billion for the UK economy. In addition, up to 97 pence of each pound spent on the platform is paid directly to Hosts, benefiting local economies directly.[4] This direct benefit to local economies will be vital in supporting the sector to recover and exceed pre-pandemic levels.

The impact of the COVID-19 pandemic puts the regulation of our industry into a new context. The sharing economy, including Airbnb and our Hosts, has been hit hard. In the UK, COVID-19 regulation on accommodation providers themselves and uncertainty around international travel and inbound visitors has caused significant disruption to the sector over the past 18 months.

During the crisis we took a number of steps in the UK to help Hosts and guests comply with COVID-19 legislation. You can find more about the steps we took over the lockdown periods here. Despite the impact of the COVID-19 pandemic, there are an increasing number of new Hosts joining our platform to generate additional income from their spare rooms and properties and UK guests are using our platform to travel both domestically and internationally. In summer 2020, Hosts in the UK earned more than £225 million, with the average Host pocketing nearly £1,000 on average.[5] As we know, Brits readily embraced domestic holidays again in 2021, with nearby travel making up 82% of nights booked in the UK in 2021.[6]

Now, more than ever, everyone engaged in the tourism industry in the UK needs continued support from the Government to help the sharing economy, and in Airbnb’s case, the tourism economy, recover fully from the pandemic. We see consistently from our data that, where there is clear guidance and timeframes, consumers are confident to travel. For example, in late February 2021 we saw that all searches by guests or potential guests in the UK nearly tripled week-over-week (compared to Feb 16th 2021), following the February 22nd government announcement that self contained accommodation could open up by 12 April 2021.[7] However, recovery is still fragile and barriers to international travel continue to impact the tourism industry - evidenced by the sudden increase in cancellations when the Government changes guidance on testing requirements. While we wholeheartedly agree that public health should remain the nation’s priority, going forward the tourism industry needs clarity, certainty and stability.

The UK remains a world-leading travel destination

We know that the UK, and London in particular, remains one of the most attractive holiday destinations in Europe for inbound tourism. This section will focus on how tourism innovation can inspire micro-entrepreneurs across the tourism, hospitality and cultural sectors, making Britain’s destinations more accessible for all.

Airbnb is committed to enabling travel that is local, authentic, inclusive and diverse, allowing visitors to explore and experience thousands of unique communities across the UK. While there are plenty of businesses out there offering tours and activities, there has been very little offline innovation. We’re focused on making these experiences themselves better, showcasing the best of what Britain has to offer.

Airbnb Experiences was created out of the belief that we want to offer something more authentic and less mass-produced by unlocking a different side of destinations through the eyes of locals. Defined by access, expertise, and human connection, Experiences give visitors unprecedented access to communities, places and things to do that you’d never discover through traditional tourist travel. From Afro-portrait workshops[8] to vegan taxidermy[9], to becoming a whisky distiller[10] for a day, or a bookshop owner[11], Airbnb Experiences support communities and diversify tourism by creating a new wave of entrepreneurs. In February 2019, we announced[12] a match-funded partnership with VisitBritain to work with businesses and destinations, to promote local experiences, and we would be pleased to work with destinations and organisations in the future, to help economic recovery thrive in an innovative way that supports the best of British hospitality.

We want to make all experiences on Airbnb more accessible. In November 2021, Airbnb announced new innovations to help guests find and book travel that meet their needs including 13 accessibility filters including step-free bedroom access, guest entrances wider than 32 inches, and an accessible parking spot. Our goal is to set a new standard in our industry. Accessibility features for Experiences are now clearly displayed on each listing page. Guests can also select from 11 filters to find Experiences where Hosts offer sign language, no stairs or steps, and free admission for caregivers who assist people with disabilities, among other features. We will continue working with our community and experts within the disability community to improve accessibility across our platform and products.

An accessible accommodation supply is vital when planning for large-scale events which will attract international visitors in 2022. Helping solve short-term accommodation issues around big events is something Airbnb has done since its earliest days - providing a scalable solution for cities, from Hull City of Culture through to the Rio 2016 Olympic Games, and acting as an economic lifeline for homesharers.

For example, our partnership with Hull City Council encouraged residents with spare rooms to open their doors and welcome guests to the city as it celebrated its year as UK City of Culture in 2017. As a result, listings on Airbnb in Hull increased by 227% over a year-long period - accommodating an extra one million visitors in total without having to build a single new hotel.[13]

The UK must retain its ‘open for business’ approach if tourism is to flourish in post-Brexit Britain. With upcoming events set to shine a spotlight on the UK (such as the Queen’s Platinum Jubilee, the Commonwealth Games and UnBoxed Festival), considering accommodation capacity as early as possible in these destinations is critical. The lack of a joined up approach was clear in the run up to COP26, where event organisers had to rely on last minute, environmentally damaging alternative accommodation options such as cruise ships. Homesharing is a scalable and flexible solution that can help solve these issues.

To help address the accommodation shortage in the run up to COP26, Airbnb offered a £100 welcome bonus to new Hosts who hosted a qualifying stay during the event - with thousands stepping forward to make their place available. Hosting on Airbnb significantly increased accommodation capacity in Glasgow, helping keep costs down and reducing the need for guests to travel from further afield. The stays were a welcome boost in economic activity for Hosts and Glasgow with the majority of the financial benefits generated through travel on Airbnb staying local in the community. During the two weeks of COP26, Glaswegians earned an average of £3,000 through hosting, equivalent to more than a month’s median pay in Scotland. BiGGAR Economics estimates that Airbnb guest arrivals during COP26 generated over £2 million GVA (Gross Value Added) for the Glasgow economy and supported over 80 local jobs.

By asking locals to open their doors, communities across the UK can increase tourism capacity without the cost and environmental impact of building new infrastructure. Building new hotels is a resource intensive solution to scaling up accommodation supply for key events. As society moves towards a net zero future, we would ask cities and destinations to explore ways to use resources more effectively by using public messaging around major events to encourage residents to open their doors when large-scale events come to town.

Working in partnership with communities

As the country and tourism industry seek to recover from the COVID-19 pandemic, we want to encourage people to use our platform as Hosts and guests, to help protect livelihoods of local businesses and hospitality spaces who most need the additional income, whilst balancing the needs of local communities that may want more control over domestic tourism.

Successful inbound tourist attraction is built on a number of interrelating factors - but we know that the places that visitors are able to stay and the options that that opens up for them is incredibly important. The UK is a popular tourist destination due to the variety of attractions and locations available to tourists, and notably due to the diverse range of culture, arts, and heritage destinations across Britain.

As outlined in the Tourism Recovery Plan, the Government must focus on supporting inbound and domestic tourism by making it easy and enjoyable to travel to and around the UK. This can be done by ensuring regulations allow and support redistributive tourism, while working closely with tourism organisations and organisations such as Airbnb to promote the UK’s tourism sector.

We need to ensure that visitors have access to a variety of different accommodation options in order to make the most of what the UK has on offer. At Airbnb, we are focused on engaging with local tourism organisations and community groups to promote areas outside of traditional tourist hotspots. Our accommodation marketplace plays an active role in redistributing tourism around the UK by providing access to unique places to stay in over 2,700 cities, villages, and towns.

We want to continue to work with local authorities and sector bodies across the UK to promote some of the UK’s lesser known destinations. For example, in April this year, we launched a campaign to promote the overlooked stays and experiences in the South of Scotland - backed by VisitScotland and the Scottish Tourism Alliance.

With Hosts, guests, and communities feeling the economic strain of limited travel, we welcome the increased funding for destination marketing. However, a particular area of concern is urban markets, which are largely dependent on overseas visitors and have not all felt the same level of benefit of the return of domestic travel. As such, it is essential to support urban recovery as a priority. Whilst the additional funding is welcome, we need joined up and consistent action to promote urban destinations, particularly London, as it is both an important market in its own right and a gateway to the rest of Britain.

This collaboration is vital to support the growth of the inbound tourism industry as we recover from COVID-19. The continued engagement between platforms such as Airbnb, tourism boards and the Government will drive this recovery forward. Partnerships are at the heart of this strategy and Airbnb will continue to work closely wherever possible to promote tourism and local communities across the whole of the UK.

The Tourism Recovery Plan

We welcome the Tourism Recovery Plan as a comprehensive response to the challenges posed by the pandemic that require a cross-government, cross-sector response. We support the Plan’s objectives to build resilience in domestic and inbound tourism, as well as ensuring the benefits of the recovery are shared across the nations and regions of the UK.

Airbnb is determined to play a key role in ensuring the sector builds back in a resilient and innovative way, using our technology and data to enhance the visitor experience. For example, we offer local governments, politicians and tourism organisations access to our City Portal tool - allowing them to use Airbnb data to help deal with any potential issues in the community and make data driven decisions locally.

The way in which Airbnb facilitates easy access to affordable, diverse, and inclusive accommodation options across the UK is directly linked to the objectives of the Tourism Recovery Plan. This year we have seen millions of Brits choose to enjoy a Great British Summer at seaside towns like Sandgate in Kent, which became the top trending coastal destination in the UK on Airbnb. Overall, we have seen a shift in travel preferences in 2021, supporting local economies. This represents a vital lifeline to local businesses and hospitality across the UK and is a key objective of the Tourism Recovery Plan.

We are supportive of the Government coordinating a national response to the challenges facing the sector due to the impacts of COVID-19 - captured in the Tourism Recovery Plan.

Key to delivering on the plan’s objectives will be to ensure that the Government and tourism organisations understand and contextualise the consequences of the rise in short-term lettings on local communities. As such, we need to build a firm, clear evidence base showing the impact of short-term lets on our communities, to enable the Government and communities to design interventions that effectively address any issues whilst maximising the economic benefit delivered by visitors to local businesses.

Within the Tourism Recovery Plan, we were particularly happy to see the government announce plans to consult on establishing a Tourism Accommodation Registration System (TARS) and we look forward to continuing to work with the department on this important piece of work.

Airbnb Short-Term Lets Registration Proposal

In June 2021, we proactively set out our own proposals for a simple, national registration system for short-term let operators in the UK in a UK Registration Whitepaper.

A registration system would give greater transparency over short-term letting activity across the country, giving local authorities greater visibility on short-term lets, including those who are breaking the rules.

The registration system would be industry-wide, and we believe that its introduction would demonstrate the value that short-term lets offer - not just to established tourist destinations, but to the places across the country which are less visited and less well known. Such a system would allow local authorities and central government to better understand the impact that short-term lets may have on local housing markets and make better informed decisions about local issues.

In addition, it would bring much needed clarity to current arrangements (with different rules applying in London, Northern Ireland and Scotland), and would be simple for the Government to establish and empower - via the Legislative and Regulatory Reform Act 2006.

Airbnb has proposed that a registration system should be targeted, proportionate, transparent, accountable and consistent.

The key principles for the registration system to operate effectively and provide maximum benefit to local authorities, Government, Hosts, and guests would include:

●        Online one-stop-shop: Hosts should be able to complete their notification in a single visit to the GOV.UK website, leveraging existing identity validation infrastructures in order to approve entries in real time and allowing Hosts to receive their registration number automatically after completing the registration process.

●        Instantaneous and one-time-only: There should be no delay in issuing a registration number. If further validation is required, a Host should be able to welcome their first guests without waiting for follow-up. Hosts should not need to repeat or renew their notification, except in the case of material changes of circumstance. There should be a mechanism in place that removes registrants from the register if they have not been active for an extended period of time, to avoid artificial inflation of the number of short-term let properties over time.

●        Affordable for Hosts: Non-commercial Hosts should be able to register cost-free. A nominal fee for commercial Hosts will cover the actual administration costs of the regime. A definition of “commercial Hosts”[14] would need to be established - something the authors of this paper would be happy to discuss further with the Government and other interested parties. We are also open to discussing whether the registration system could also apply to other types of short-term accommodation. Structures should be proportionate, taking into account the Host’s level of activity. Sliding scales of fees for the maintenance of a register are common in the UK. Due to the diverse range of relevant actors in the short-term let industry, we believe these sliding fee scales would be an appropriate benchmark for the registration system being proposed in this paper:

○     In Northern Ireland, £20 is payable for every room you intend to let, subject to a minimum fee of £80 and maximum of £200.[15]

○     The Information Commissioner’s Office (ICO) charges small businesses £40 per year to maintain their data protection registration, while charging higher fees to larger organisations.

●        Accessible for local authorities and emergency services: A nationally run scheme should be able to be accessed by local authorities and local services. Since a Host’s registration information is collected for the purposes of enforcement, there is no justification from a privacy perspective for publishing a public database of registered Hosts or listings. Data protection laws, in particular those governing limitations on the purposes of processing, must be strictly complied with.
 

●        Data minimisation: Consistent with data protection best practices, Hosts should only be required to provide the minimum data necessary to process their registration. There should be no requirement to upload supporting documents, but Hosts should be required to attest to understanding applicable health and safety regulations.
 

●        Consistent application and level playing field: Registration and enforcement obligations should apply to Hosts whether they are offering their property for short-term let through online or offline means and across all types of online distribution channels (including platforms).
 

●        Effectively enforced: Transparency introduced by registration will enable more effective enforcement of individual breaches. Further, it would make it possible to track repeat breaches for which stricter penalties - such as being suspended or struck from the register - may be appropriate. In addition, this should be enforced by platforms and other types of operators through established effective notice and action protocols.

●        In partnership with platforms: To this end, the Government should work with platforms to formulate detailed and consistent processes, whereby listings of concern can be flagged to platforms for appropriate action. For listings being operated illegally, the process should be consistent with existing processes for other kinds of illegal online content and should be established in accordance with the planned legislation set out in the Online Safety Bill. This process would introduce much-needed structure into current notice and action systems. It would also highlight the benefits of using standard language in such communications and the importance of providing the right level of information to enable platforms to take action.
 

●        Reasonable implementation period: In introducing a new system, Hosts should be given a reasonable period to register before enforcement against unregistered listings commences. To encourage the highest levels of adoption the Government should partner with industry to communicate jointly about the new process.

Conclusion

The UK is a world-leading tourism destination and a sustainable recovery across the sector is a clear priority for the Government and the tourism industry more widely. We believe the Tourism Recovery Plan is the right first step towards driving the recovery in tourism that is required across the country and we are supportive of the Government coordinating a national, cross-sector response.

We urge the Government to continue to prioritise and facilitate collaboration between businesses such as ours, tourism and trade organisations as well as local politicians, business groups and wider communities in order to build a sustainable and resilient recovery that utilises data, innovation and technology to drive growth.

As part of this collaboration, the Government and tourism organisations must be able to understand and contextualise the consequences of the rise in short-term letting on local communities. We were pleased to see the Government announce plans to consult on a National Registration System in the Tourism Recovery Plan, and Airbnb would urge all interested parties to continue to work with the department on this important piece of work, which will build a clear evidence base on the impact of short-term lets and allow local authorities to design appropriate policy interventions for their communities.