City tourism: Operators Update

June 2018

We are looking forward to seeing many of you at City Fair in London on 11th June. A wide range of destination marketing and management organisations, and suppliers, will be there to meet senior product managers from operators who are looking at 2019/20 and onwards, so they can provide information about developments in destination and improve their understanding of origin market needs. Buyers may still register for the workshop at The programme also includes a range of content on 12th June about the ‘Digital City Visitor’.

Policy Updates


Croatia – guiding
Croatia has introduced a list of sites at which only those with local licenses may provide guiding services. This has already caused operational problems and threatens to be both inflationary and disruptive of continuity of client service. We have questioned the proportionality of this list and related regulation with both the Ministry in Zagreb and the European Commission. While a member state’s right to ‘reserve’ individual sites has been accepted in principle by the EU Court of Justice, the volume of sites and the justification for ‘reserving’ them are both relevant factors in order to determine whether such a move is abusive thus illegitimate. Tour guides from other EU countries who have completed the appropriate prior declaration should be permitted to provide services unhindered. We will provide any further news when we have it.

For further information, the first link below is to the schedule of protected sites; the second to the relevant national law:

Iceland – driver and vehicle regulation
We have received reports of imminent regulation in Iceland that will affect operators using non-Icelandic vehicles and drivers to provide services in destination; as we understand it, the vehicles that would be affected are only those for 9 passengers or fewer. Providing relevant rules for vehicles, driving hours etc. are observed, in principle there are no grounds for an EU/EEA country to prevent providers from another EU/EEA country from offering services on a temporary basis. We are in touch with the Ministry in Reykjavik and the DMO and will follow the situation closely.

Switzerland – VAT registration
We have no further news since the last interim update. Our understanding is that the Federal authorities do not expect to require VAT registration for non-Swiss tour operators, despite recent regulatory change which appeared to require any company with a global turnover of at least 100,000CHF to register if it wishes to provide services (i.e. buy services which its clients enjoy) in Switzerland. We await more formal confirmation, but the strong signal from the national tourism  organisation is that, unsurprisingly, there is no intention to deter direct spend by foreign companies. We will communicate any more news when we have it.

City Updates



Thanks to the kind sponsorship of Blue Boat Company, we hosted an evening reception in Amsterdam on 24th May. This was an opportunity to understand in more detail from both members and new colleagues the effect of restrictions on group walking tours and coach access, and gather more perceptions as to the political context in which new regulation has arisen. We are seeking further dialogue with the city.


Reservation and ticket availability continue to be highly problematic. Some operators are resolving the problem by buying tickets through the hotels at which groups are staying. While overnight visitors are, in principle, of greater economic benefit to a destination than day visitors, this practice raises questions of market control. As for other attractions subject to very high demand at peak times, the question arises whether dynamic pricing, or variations by time of day or season, may be part of the answer in order to spread volume and influence buyer behaviour, trade and retail. There is the related question of the inherent risk in allowing one attraction to become so dominant in a destination’s market presentation that its lack of availability may be seen as sufficient to deter visitors altogether.


Eiffel Tower
The Eiffel Tower (SETE) announced that the group desk will close on 31st May 2018. Therefore, no last minute group reservations will be available to purchase on the day. With the increase in security measures and the renovations works taking place around the Eiffel Tower, queuing times have increased to up to 2 hours. As part of the new online booking process operators are now required to register with the French tax authorities; we are questioning the necessity of this. For recent coverage, please see the following link.

Château de Versailles
As per previous update, to obtain the reduced price for groups for Versailles gardens operators will now need, as was the case in the past, to show group reservation for Palace visit. Accompanying tour guides are not allowed to buy the tickets while the group is inside with the local licensed guide. Only local guides may obtain the discounted tickets on presentation of both group reservation and their guide card. The next Paris working group will meet on 26th June. Please send any current operational insights or questions related to Paris to Aliya Jivraj.


The new requirements for pre-booking and pre-payment have brought some certainty, but at the cost of unused tickets (precisely what the Ministry, MIBACT, wanted to avoid) and unnecessary complication should additional tickets be needed. We are in touch with Coop Culture, an ETOA member, to explore whether there may be any scope for adaptation that would serve the interests of both operators and the attraction. It seems clear that, if operators were to release unwanted tickets by a given deadline, opportunities for resale through alternative channels are plentiful, especially at peak times.

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