City tourism: Operators Update

May 2018

This month, prior to the city updates, we have four policy notices related to tours operations. One reports potentially very disruptive VAT changes in respect of Swiss inbound business, another concerns market access for tour guiding in Croatia. Tax law and guiding regulation were of great concern to ETOA’s founding operators in 1989; their continued significance mean they remain priorities now.

To this list we can add ‘capacity management.’ At an operators working group on 25th April, it was clear that attractions with problematic reservation, ticketing and capacity management, especially the Alhambra and the Eiffel Tower, are progressively being dropped from group programmes. Demand for Paris is not contingent on one attraction. Granada is another matter, and we will focus on southern Iberia product in a seminar planned for Seville, provisional date 27.9.18. More details to follow in due course.

ETOA is in close dialogue with destinations as their strategies develop, ensuring that industry’s voice is heard and that authorities are aware of the impact of proposals. We also welcome first-hand information from operators to ensure that these updates can be as useful as possible. CityFair is a great opportunity to talk to destinations about their plans to work with the travel trade. If you or colleagues are not yet registered, there is still time to do so. You can follow this link to register, it is free of charge to operators.

Policy updates

Chinese market – group visa application
For operators working with the Chinese market we have prepared a briefing note regarding group visa applications within the ADS scheme.

Croatia – guiding regulation
Members have reported hostility to their tour guides accompanying groups in various sites in Croatia. These tour guides have made a ‘prior declaration’ in order to provide services on a temporary and occasional basis and, as such, should be free to do so. The apparent justification for this is a very long list of ‘protected sites’ at which guides must have a local licence. More detail here.

ETOA believes the extensive nature of the list is contrary to EU law and is seeking urgent clarification of the position from the Ministry of Tourism in Croatia. We are in touch with the European Commission’s unit that monitors the operation of the professional qualifications directive. Cultural tourism is a valuable balance to Croatia’s beach tourism. It is counter-productive to erect regulatory barriers to its delivery.

GDPR – supply chain compliance
The enforcement date for GDPR is 25th May. Persistent concerns expressed by members relate to their ability to require suppliers to comply and the dispersed nature of the supply chain. A tour guide may be looking at protected data on a personal smart phone in the course of their duties; a museum may require a rooming list for group ticketing. It is increasingly clear that some more practical guidance would be valuable; we are seeking to develop that. Meanwhile, we remind members that if they have a ‘legitimate interest’ in holding data – e.g. about a supplier they have not worked with for some time but might book in future – there is probably no need for an ‘opt in’ campaign by which they seek explicit permission to retain the data.

Switzerland – VAT registration

There are very worrying reports that a consequence of a recent change to Swiss VAT law designed to protect Swiss businesses from EU service providers offering services in Switzerland at lower cost (e.g. cleaning and construction services) may affect incoming tourism. The changes would affect business with over 100,000CHF annual global turnover who must (if the interpretation is correct) either register for VAT in Switzerland or use a Swiss-based intermediary in order to book services there. We have brought this to the attention of senior figures in Swiss tourism, whose purpose is to keep Switzerland attractive to inbound business. They have promised urgent action in order to clarify the actual position, and to explore options for mitigation if the law’s consequences are as feared. We will provide updates as soon as we have them. If members have received any related advice they can share, or if they have encountered the problem directly, please contact

City updates

Updated information about rules and permits for group tours in the red light district are available here. It is not clear how the suggested fine on operators would be enforceable if tour guides were informally escorting groups through the designated area, and group size of behaviour infringed guidelines, but there is clearly a risk of disruption at least.

As previously reported, live information about coach access is available in various languages at

We are in dialogue with the city and expect to have meetings in late May. There are strong concerns expressed by local business and operators, especially those whose river cruise programmes begin or end in Amsterdam, and those who include walking tours that include Dam Square (part of the restricted area). While there is an apparent political mandate and intention to control tourism it is vital the response is rational and proportionate in order not to deter operators whose product is consistent with the city’s long-term plans for tourism’s place in the local economy.

Conwy Town – Coach Drop-off for tourists

The historic walled market town is popular with overseas visitors but, if they arrive in a left-hand drive coach (a continental coach) at the traditional drop-off point, passengers have to step out into moving traffic. Local authorities wish to discourage coaches using the Castle Sq. area, which is the street in front of Conwy Castle, to setdown and pick-up passengers. Aside from obstruction and consequent congestion, there are obvious safety concerns.

There is a new coach bay for set-down and pick-up that should be used, which is located slightly further into the town on Rose Hill Street. This is immediately adjacent to tourist information and toilets. For further information, please refer to this link.


Some group operators running scheduled tours including the Alhambra are experiencing perhaps a 60% success rate in securing reservations, leaving 40% of
production subject to alternative attempts to secure space, service recovery etc, and the possibility that, once on tour, clients may obtain tickets via online channels or in person. As reported above, it is clear some operators have dropped or will consider dropping the Alhambra as an inclusion. This may have an impact on overnights in the city. Bespoke operators also encounter difficulty: bookings made months in advance have been cancelled at relatively short notice. This brings serious reputational risk whose cause is primarily related to process rather than capacity. Some operators report improvements in online booking platform.

Paris and Versailles

River Cruise operators please note: The call for bids for the dock of Grenelle (in Paris) is now released here (in French).

Coach operation – updated information

We have confirmation that if a coach is circulating around Paris without stopping then there is no pass required. Hotel pick-ups and drops in Zone 1 do require a pass unless they have a private carpark. There is a new stop at Tour St Jacques, (near Chatelet) for groups to be dropped off and picked up if they want to go to Notre Dame. This is a pick up and drop off point only; coaches cannot park and wait without passengers getting on or off.

Eiffel Tower
The access to the Tower is closed from the main road (Quai Branly). While traffic and coaches can still circulate on the main road, pedestrian access is closed. To access the Eiffel Tower visitors can take the avenue de Suffren and then a small side alley which comes out between the west and south pillars. See map below. Visitors can still access the Eiffel Tower by walking from Bir Hakeim metro station. Coaches with a permit can still drop off at Avenue Joseph Bouvard located on the Champ de Mars. Paris City Council states the aim is to improve the surroundings of the Eiffel Tower and its amenities before the Olympic Games in 2024. Major works will eventually stretch from Trocadero to Ecole Militaire taking in the areas around the Champ de Mars and the Quai Branly Museum. A wider range of services will be available such as public toilets, benches, food outlets and left luggage facilities with improved signage enabling visitors to have a more enjoyable experience.
The Groups desk at the Eiffel Tower still exists for now, opening at 9am, but in order to purchase tickets for groups on the day one must have an account registered with the Eiffel Tower. There are reported difficulties adding to pre-booked groups, especially for ‘grands comptes’ buyers wishing to add additional pax on the day and consequent risk to original reservation. Others have reported that, subject to availability, tickets are available as normal for standard price of €16. It is unclear whether the ‘grands comptes’ system is one the Eiffel Tower is keen to maintain given general levels of demand.

Musée du Louvre
The museum reports that the new group entrance is expected to open on 17th May. Regarding group reservations these may be bought and modified online ( and henceforth there will be one reservation and one ticket per group (as opposed to one reservation and individual tickets).

Château de Versailles
We have been informed that, to obtain the reduced price for groups for Versailles gardens, operators will now need to show reservation for Palace visit (this was previously the case). Accompanying tour guides are not allowed to buy the discounted tickets while the group is inside with the local licensed guide. Only licensed local guides may obtain the tickets on presentation of both group reservation and their guide card.

Windsor Castle – Royal Wedding 19th May

Castle closure and coach parking

Please note there will be a full closure of Windsor Castle on 18th and 19th May. Local authorities have provided the following information about parking arrangements for the 19th.

“On 19th May, the Alma Road coach park will be open as usual; however, the booking process is different for this specific event. Spaces must be pre-booked and paid for via our online box office here. There will be 80 spaces available and the cost per space is £100 incl. VAT plus £1.50 admin/postage fee for the day. The coach park will open on Saturday 19th May at 4am and close at 10pm. Pre-booked coaches must be parked by 9am at the latest. Any operators who have not pre-booked will not be permitted to park. Permits and further instructions will be sent at least five working days before the event.

Due to the nature of this event and the very high number of spectators expected in Windsor on the day there will be no provision for drop off anywhere in the town nor any provision for coach parking outside of the coach park itself. There will be extensive road closures from as early as 6am on Saturday 19th May and coaches without the approved parking permit for the coach park will not be allowed past these road closures.

We would very much appreciate your help in keeping traffic moving around Windsor and the town safe and secure by not attempting to access the area without prebooking for the designated coach parking spaces at Alma Road. As more details about the event become available, we are adding them to our website here.”

Destination and Policy update

 Receive the latest news on operational developments in destinations across Europe



This content is exclusive to ETOA members

Login here to access it now

Not a member yet?

The ETOA membership opens invaluable networking opportunities to your business, allows you to gain access to critical insights and information and contributes to the campaign for a better regulatory environment in Europe.

  • Connect with the global travel trade
  • Stay informed of insights, regulations and changes
  • Be supported in shaping the tourism landscape

Enquiry now

Our latest members