City tourism: Operators Update

February 2019




Last week we hosted a second Brexit briefing for UK members in London to update on the latest guidance issued by the European Commission and UK Government. External speakers included K&L Gates and Elman Wall Bennett covering topics such as travel in the event of a ‘no deal’, VAT post Brexit and the UK Government’s proposed long term immigration strategy. Please find here the presentations from the briefing, ETOA and K&L Gates (there is no presentation from Elman Wall Bennett as there was no update since our first briefing in October).

However, since the briefing, HM Revenue and Customs have confirmed that in an event of a ‘no deal’, a UK version of TOMS is proposed. As a result UK businesses will only pay VAT on UK travel but the door is open for EU member states to charge VAT on the price paid by the consumer. Further information from Elman Wall Bennett can be found here.

EU citizens visiting or working in the UK arriving after 29 March 2019: On 28January, the UK Government announced arrangements for EU citizens visiting or working in the UK who arrive after 29 March 2019, in the event of ‘no deal’.

For up to 3 months, EU, EEA and Swiss citizens would be allowed to visit and work on the same basis as today (Irish citizens’ rights of residence in the UK are unaffected).
For longer than 3 months, permission is required to receive a European Temporary Leave to remain, which would be valid for 3 years and a fee would be chargeable (to be announced). EU citizens wishing to stay for longer than 3 years would then need to make a further application under the new skills based future immigration system, set to begin from 2021. Further information is available here.

These procedures do not apply to EU citizens resident in the UK before 29 March 2019 as the EU Settlement Scheme applies.

Below are links to the guidance issued by the EU Commission and UK Government.

EU Guidance
Travel in the event of ‘no deal’
Travel between EU and UK – 13 November 2018
Contingency Action Plan – 13 November 2018
Implementation of Contingency Action Plan – 19 December 2018

UK Guidance
Explainer for Withdrawal Agreement – 14 November 2018 (agreement awaiting ratification by UK parliament)
No Deal Guidance – 23 August 2018 updated 21 December 2018

Travel in the event of ‘no deal’
Travel to EU – 19 December 2018
Travel to Ireland – 19 December 2018

UK Employment policy from 2021
Immigration White paper – 19 December 2018

Visas and borders

ETOA submitted its report to the European institutions to support its arguments for improvements to Schengen Visa Code. The report assessed impact of current arrangements on China and India outbound. We are preparing a report on the potential benefits of further collaboration between Schengen and UK/Ireland on visa application processes. The UK government has announced consultation on a new instrument, which would require the citizen of any country other than Ireland to have an ‘Electronic Travel Authorisation’ (ETA). As for the Schengen area’s ‘European Travel Information and Authorization System’ ETIAS, the probable year of introduction is 2021.

Correction to January update: we incorrectly stated that, even if the UK stayed in the EU, UK citizens would nevertheless still need to apply for an ETIAS in order to visit EU countries. While ETIAS was designed to strengthen Schengen’s external border in part to promote confidence in freedom of movement within Schengen, and thus has no effect on external border security of non-Schengen EU members (at present, Bulgaria, Croatia, Cyprus, Ireland, Romania and UK) the requirement for an ETIAS will only apply to citizens of non-EU states. We apologise for any confusion caused.

Coach operations

European Parliament’s Committee on Transport and Tourism (TRAN) voted on Mobility Package proposals this month concerning changes to Driver’s Hours and Posting of Workers regulations. Some of the proposals were extending the international 12 day rule to apply to national operations, increasing the authorised daily driving time to up to one hour twice a week and exclude coach drivers from posting of workers regulations on a closed door tour. However, TRAN voted against these proposals. Therefore, driving rules will remain the same.

Furthermore, the European Commission proposed that local day excursions within an international closed-door tour are to be within the scope of cabotage. Consequently, this could increase the cost of administrating tours to comply with posting of workers regulations, result in loss of value-adding to a tour and is anti-competitive. With assistance from colleagues in IRU and EACT, ETOA successfully lobbied TRAN in voting against the European Commission’s proposals. As a result, local excursions will continue to be classed within the framework of an international occasional tour.

Tour Guide ID cards 2019

We will soon be launching a new application form for 2019 tour guide ID cards. Due to technical issues, we have experienced a slight delay. The system is expected to be up and running within a few weeks in conjunction with the launch of our new website. We accept bulk applications now – please email with the details of your order or if you have any questions regarding the process.
We have been providing the tour guide ID cards since 2010 and are now issuing more than 2000 cards on a yearly basis. While the ID card is not a proof of qualification or a licence, the card is evidence of status. It has proved to be a convenient form of photo-ID that shows the holder is a professional tour guide contracted by an operator to lead tours. As such, it can provide reassurance to officials tasked with controlling commercial activity. For example, it helps distinguish the holder from an individual offering guiding services directly to visitors without appropriate authorisation, as distinct from providing services under a contract already made between visitor and operator. It has proven to be useful where museums and other attractions choose to recognise it.

If you haven’t heard about the ID cards before, but are interested, please email or Sofie Jensen.




Amsterdam – guiding regulations: As mentioned in the Interim Update on 18 January, Amsterdam Gemeente (city hall) is proposing stricter guiding regulations in the Red Light District and Dam Square. We encourage anyone affected to respond to the consultation on the proposals (open until 31st January 2019). Link here or email It is important “Algemene Plaatselijke Verordening (APV) – wijziging verbodsbevoegdheid groepsrondleidingen” is used as the subject header.

Amsterdam – Anne Frank House: We have recently become aware of a visitor condition (2.5) for the Anne Frank House, which has been in place since June 2018: “The Anne Frank House wants to give as many individuals and (school) groups as possible the opportunity to visit the Anne Frank House, at an entry price determined by us. Travel organisations / tour operators may not make bookings for third parties.”

According to their Visitor Service department, the change was intended to control the re-selling of tickets. Furthermore, it appears school groups often booked their educational programme without knowing about the language requirements.

Clearly the new condition affects operators selling packages including the Anne Frank House. Despite the change, however, the actual booking procedure seems to remain the same: non-educational groups of up to 14 pax allowed; school groups of up to 35  students allowed (one group per 15 minutes). Bookings open two months in advance. If you have had experiences or challenges with this new condition, please contact Sofie Jensen.


Florence – Uffizi Gallery: In November 2018 we were made aware of the new €70 group fee at the Uffizi Gallery from 01 March 2019 for all groups from 15-25 pax (groups over 25 pax are not permitted). After being in contact with the Gallery, it has become apparent that the main reason for the new regulation is to avoid congestion. For groups with self-guided visits it is possible to split up the group to smaller entities of max. 14 pax to avoid the fee. Uffizi recommend that the fee is only paid on arrival and not online in case the group has reduced in size.

Rome – coach plan: The new coach plan in Rome came into effect on 01 January. Immediately issues regarding booking procedures, contradicting information online and lack of response from Roma Mobilità. The contradicting information resulted in coaches with valid permits being held back and questioned. Furthermore there are serious worries how the new system will be able to cope with the pressure in high season.

According to our understanding, one of the initial main issue has been whether a B5 permit would give access to drop-off at Gianicolo parking by the Vatican. To avoid any doubt, it has been confirmed by Roma Mobilità that all permits, except A permits, will give access to this drop-off point. There are still information online with contradicting information.

Despite our efforts, we still do not have been able to get an answer to a list of questions sent to Roma Mobilità, with exception of Q2 regarding B5 permit. Our current understanding is that despite various contradicting information on their website, the FAQ section is updated fairly frequently with some the most pressing issues.

Our focus is to help our members understand the plan operationally. If you have any unanswered questions regarding the plan, or if you have any information that may help other members, please contact Sofie Jensen. We would like to thank all operators we have been in contact regarding the plan.

Venice – landing contribution: We are still awaiting more information regarding the proposed changes, such as rates and collection process. If you missed our interim update on 18 January, please click here for more information regarding this subject.


FITUR: The ETOA team attended FITUR last week meeting several members and nonmembers. Thank you to everyone who came by.

Alhambra and Sagrada Familia: In February, we will hold meetings with both attractions. While we have had a close relationship with Alhambra for a few years, it is positive news that Sagrada Familia has confirmed a meeting with us. Our aim is to understand their business model better and to get a better relationship to be able to support our members’ different businesses in the best way possible.

Madrid – coach plan: As reported in the December update, on 30 November 2018 the four access restriction zones in the city centre (Areas de Prioridad Residencial) were extended to create 1 large zone, covering the entire downtown area in Central Madrid. The new zone becomes fully effective from 1 February 2019. However, all tour coaches will still be allowed to enter the zone until 2023 (for minibuses there are some restrictions from 2020). We understand that authorisation from Madrid City Council is not required for tour coaches to enter the zone. Further information on the scheme can be found here.


If you are based in or around Paris (or if you are in Paris on the day), ETOA will be celebrating their 30th anniversary on 27 March. Please keep this evening free and bring your non-member colleagues from the industry to an evening of networking, celebrations and socialising. Invitations to follow. If you are interested in the event, please click here.




• 30 January, Brussels: ETOA attended ‘Forum for Mobility & Society’ at European Parliament. Topics included urban access policy, including possibility of further restrictions on diesel vehicles.
• 15 January: The first meeting in 2019 of the ‘Welcome to Britain’ working group with Visit Britain was held earlier this month. Industry stakeholders and UK Government departments discussed operational issues affecting the UK inbound and outbound sectors. Particular focus was the potential impact at theborder from Brexit, especially in the event of a ‘no deal’.
• 11 January, Aberdeen: The Scottish Government has concluded a national consultation about a tourism tax (‘transient visitor levy’). ETOA participated in one of the round table meetings chaired by the Minister for Public Finance and Digital Economy. A range of views were expressed by representatives from public and private sectors. Issues explored included purpose of such a tax; notice period; the overall tax burden (the UK does not currently discount accommodation services for VAT); overall tax exposure for the distribution chain; merits of mandatory tax versus local discretion; use of revenue; visitor perceptions. Of note, ETOA’s work on tourism tax was cited in the discussion document circulated by the government. We will follow developments closely.
• 23 January, Brussels. ETOA is part of the steering group of the Tourism Manifesto, which includes over 40 signatory organisations involved in the travel industry. The focus of this workshop was the scope for EU funding for the sector, especially sustainable tourism. The purpose was to develop  possible joint actions in the context of the Commission’s budget preparation for the next Multiannual Financial Framework (MFF) which will be in effect from 2020.


• 06-08 February: ETOA will be attending the Conference on Managing Sustainable Tourism Growth in Europe taking place in Krakow hosted by ETC. This is followed by ETCs general meeting where ETOAs will be speaking.
• 11 February: ETOAs event Hoteliers European Marketplace (HEM) will take place in Seville. If you would like to discuss any operational challenges, our Spanish Country Representative Jorge Traver will attend.
• 13-15 February: ETOA will attend ECM’s Spring meeting in Edinburgh.
• 15 February: ETOA will attend the Agri Travel & Slow Travel Expo in Bergamo. If you are attending, please contact Tinì Gattazzo to set up a meeting. Simultaneously, ETOA will be participating in a panel discussion on sustainable tourism at the Bergamo Conference and Marketplace of Ideas “Sustainable Tourism for Rural Development“, also representing NET.

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