Background

Under the guise of a 'tourist tax' to raise more money, Liverpool BID Company held an alteration ballot in April 2025 to change the way it charges the 83 accommodation providers currently paying the ABID levy.

Of the 83 ballot papers sent (apparently), 44 valid votes were cast, resulting in 26 yes votes and 18 no votes, so a winning margin of 8 votes. But with only 30% of all the accommodation providers casting a vote in support of the scheme, it is clear there is not strong support for the visitors charge alteration.

The alteration increases the combined BID levy liability for the businesses from £784,635 in 2024/25 rising to £4,271,413 in 2025/26, and the accommodation providers are being asked to fund it by raising their prices.

Putting aside the pro’s and con’s of a tourist tax using the BID structure, many accommodation providers are not happy with the lack of consultation and implementation guidance about the new ABID pricing & collection model.

If you are a Liverpool accommodation provider unhappy with the scheme then please contact us in confidence to let us know your views.

Here are some of the many concerns about the Liverpool Visitors Charge scheme.

- Where is the consultation and evidence that imposing a tourist tax via an Accommodation BID is the best option available and will work for Liverpool?

- Many Liverpool accommodation providers will not take part in this tourist tax scheme and not asked to increase their prices. Why aren't all accommodation businesses taking part, surely everyone should pay proportionally into the pot, big and small providers? Wouldn't it make sense to include all hotels, apartments, guest houses and Airbnb’s etc, and then maybe charge less or raise more funds collectively? Instead, only 83 accommodation providers have been asked to carry the weight of a Liverpool vistors charge on their shoulders using the BID model.

- The BID levy structure doesn’t take into consideration actual occupancy, it’s based on a Liverpool average. This means hotels may not recoup enough in visitor charges to cover it, or may make a profit under false pretences which could be seen as fraud.

- The accommodation providers not included will gain an unfair advantage by advertising that they don't charge the tourist tax, this is already happening online. For price sensitive accommodation providers, the visitors charge could actually lead them to losing customer bookings.

- There is no legal basis upon which to charge visitors, it is chargeable on a voluntary basis as a supplementary charge imposed by each accommodation provider. So there's nothing to make every provider charge customers.

- The hotels will be at a financial loss implementing the scheme given staff costs to administrate it, and the card fees for the extra overnight supplements being charged.

- Consumers will be misled that the charge is an official tourist tax, when it's not. It's a scheme whereby hotels are being forced to raise their prices by the Council and Liverpool BID Company in order to recoup their BID tax charges collected by the Council.

- It’s an administrative headache for the accommodation providers to implement, and likely to lead to customer confusion and disatisfaction given it’s not a properly legislated tourist tax.

- Why is the burden for funding Liverpool destination management budgets falling on just 83 accommodation providers? What about others in the hospitality industry that will benefit?

- The charge to consumers is not £2 as is being falsely reported in the press, it’s £2 plus VAT, which makes it £2.40 a night. As a consumer you are not quoted hotel room prices on a net basis are you? The BID Company have failed to properly advise businesses on the matter of VAT which has created confusion about the proposal.

- A BID is not required as a legal mechanism for accommodation providers to group together and charge an overnight supplement as a visitors charge, it can be done without a BID. What a BID does is force those that don't want to be part of the scheme to be in it by creating financial leverage over them.

- The alteration proposal has been rushed without following Government legislation and proper voter due diligence, engagement and consultation.

- The money goes to a private company with no public accountability or transparency.

- Even Liverpool City Council would prefer a proper tourist tax. The Council doesn’t see the ABID work around good enough or a sustainable model, only a precursor to a properly legislated and fair tourist tax. So why on earth are the ABID businesses bothering only for the Council to want to stop them when they can have their own way? Note that a Council scheme would raise a lot more money (nearly x3), because it would be fair as it would include all acccommodation providers.

Appeal - request to the Government to declare the alteration ballot result void

A Council imposing a mandatory business rates levy on businesses is a serious proposition and is not to be taken lightly. Hence it’s important that both a BID Company and its Council conduct themselves strictly in accordance with Government legislation in order to maintain the integrity of a ballot process.

On Friday 23rd May 2025 an appeal was submitted by Liverpool accommodation providers to the Government to declare the Liverpool ABID alteration ballot result void.

The appeal is based on the submission of evidence of alleged alteration ballot material irregularities, which are likely to have affected voting and the ballot result.

The nature of alleged irregularities includes numerous contraventions of Government BID Regulations in relation to the proposal and conduct of the ballot. Further evidence is still coming to light of voters denied a vote, through for example not receiving ballot papers despite being on the voters list, and being liable but not sent a ballot paper, and this can be added to the appeal as further evidence submissions (if you also didn’t receive a ballot paper please do let us know!).

Given the appeal process, the right thing for Liverpool BID company to have done is postpone implementation until the result of the appeal is known, as happened with Bournemouth ABID in 2024. Liverpool BID Company have the power to delay implementation of the visitors charge if they want to.

The moral dilemma and problem for the accommodation providers themselves is that if they start collecting money from visitors on 1st June and the ballot is declared void months later (the BCP ABID appeal last year took 8 months for a decision to be reached), then there is the possibility they will have been collecting the charge from visitors under false pretences. Also, the option of making refunds would be an administrative nightmare, in addition to the scheme collapsing and necessitating another ballot to change the levy rules.

It could be quite a mess and PR disaster for the City if after collecting the visitors charge for several months the appeal is successful. Which is why the sensible thing for Liverpool BID Company to have done to reduce operational and repuational risks for all, would be to postpone implementation pending the appeal decision.

The thing is, ABID have decided not to do this and told the accommodation providers there is no reason for them to not apply the visitors charge. They have unfairly put the weight of the visitors charge decison on their levy payers, and perhaps badly advised them?

ABID have shown their true colours

In response to the appeal publicity Liverpool BID Company released a statement on 30/5/25, a copy is here. It’s agreed that their decision to implement the new BID levy charge calculation arrangements from 1st June, is in accordance with the BID regulations and Government guidance, it’s their legal right.

However, what the statement does help demonstrate is the sneaky ‘get out’ and financial leverage the BID Company has over the accommodation providers. They’ve got what they wanted, a x5.5 increased annual levy pot of cash, and now it seems they are happy to ‘hang their levy payers out to dry’.

This is the ‘killer’ line in their statement that demonstrates just how much the BID Company is now ‘sloping shoulders’:

“if your intention was to make use of the Visitor Charge mechanism, there is no reason why you should not do so simultaneously.”

If? Really? Is any accommodation provider not considering it?

Let’s remember that the whole alteration ballot campaign centred around collection of a £2 visitors charge. Whether the accommodation providers realised it or not, the reality of the situation is that the £2 charge is voluntary, upto the hotels to charge if they want to recoup their new ABID levy costs, it’s not an official tourist tax.

Through a skewed alteration ballot publicity campaign, they have increased the annual collective levy amount the accommodation providers themselves are directly liable for by 550%, and as their statement shows, now they don’t care if their levy payers make the charge or not. Either way, Liverpool BID company intends to collect all the levy money via the Council because the accommodation providers have legally been made liable for the full annual levy of £4.2mn (25/26, up from £0.78mn 24/25), so to them it doesn’t matter if accommodation providers make the charge or not.

If you are a levy payer, how do you feel about this, in some ways do you feel a bit hoodwinked?

P.S. The press release is worded very carefully, and just to be clear, there is no government legislation with regards to the implementation of visitor charges through the BID model. It’s upto each BID company to make it up as they go along.

Liverpool City Council appeal statement released on 3rd June 2025 is here Council and BID company respond to legal challenge to accommodation bid visitor levy. Note there are untrue sentences in the statement, and the Council also makes it clear that it doesn’t see the ABID model as the best way to run a tourist tax scheme. It clarifed for accommodation providers that if the appeal is upheld then the levy collected will be returned to the accommodation providers, but where does this put refunding the visitors charge to their customers? This is a question for the BID Company from the accommodation providers

See the following statement also made on 3rd June 2025 advocating for proper tourist tax legislation, Mayors unite in call for visitor levy powers to drive regional growth.

“The business improvement district model is the only one that allows for an overnight charge to be implemented in England”, is categorically not true.

The verifiable fact is, any group of accommodation providers can voluntarily choose to implement an overnight charge and put all the money raised into a ‘pot’ for their collective benefit. The only thing the BID model does is force businesses to be part of such an initiative and create financial leverage over them in order to encourage them to collect the charge.

BID company leverage

There are many hotels that don't want to be part of the Liverpool ABID visitors charge scheme, but are compelled to be part of it because Liverpool BID Company have created financial leverage over them; "charge it to your visitors or pay it yourselves, either way is fine, because legally you are directly liable to pay it anyway".

A BID doesn't suddenly given hotels the automatic right to implement a visitors charge, any group of accommodation providers can do it themselves anyway. Hotels could have been charging it under the % of RV ABID levy model, there’s no legal difference.

What the ABID has done by aligning the BID levy charge to occupancy rates instead of RV %, is create financial leverage such that hotels feel they have no option but to charge it because the new levy costs would be prohibitive for them not to.

The City Council wants a proper tourist tax. It doesn’t see the ABID workaround good enough or a sustainable model, only a precursor.

Contact us

If you are a Liverpool accommodation provider either unhappy with how the ABID alteration ballot was conducted, or have concerns about the visitors charge scheme, then please do let us know your feedback by email or in the message box below.