Advocacy

 

Accommodation Australia works extensively in policy and advocacy across a broad spectrum of issues to ensure travel and tourism remains at the forefront of the minds of policy-makers. Accommodation Australia holds a high level of engagement with a range of government and shadow ministers at both a state and federal level. This includes the senior advisors, departmental personnel and other key political staffers. As well as working to ensure that governments are sensitive to the needs of our members and the broader tourism industry. We alsowork with other leading industry organisations and maintain strong links with representatives of the main travel destinations and with travel principals and suppliers.

On behalf of members, we lobby government both at the national and state level, on a range of issues to help our members do business more easily:

  • Supporting Tourism Investment
  • Addressing Online Travel Agencies (OTAs) and anti-competitive behaviours
  • Strengthening the regulatory environment for non-compliant short-term rental accommodation
  • Supporting tourism demand growth
  • Encouraging and supporting accommodation investment
  • Addressing Labour and Skills shortages
  • Driving visa reform

 The below details our submissions on the key issues affecting our sector. 

2024

December 2024
Unfair Trading Practices Submission
(December 2024)
This submission makes it clear that the commercial acconnodation sector that AA represents does not in any way condone unfair practices such as drip pricing and dynamic pricing (as defined as not being surge pricing).  It responds to the Treasury Consultation paper that specifically referred to accommodation bookings as where drop pricing can occur.

September 2024
Commercial Building Disclosure Program Submission (September 2024)
There is a proposal to extend the NABER's commercial building rating system, which relates to building environmental efficiency, to hotels.  In the same way as the NABERs rating can impact government decisions to rent space, the concern in this extention is that it could impact government procurements decisions for accommodation.  As part of the consultation process, AHA and AA have made a joint submission to follow up recent meetings on the issue.

July 2024
Response to discussion paper on Regional Migration Settings (July 2024)
This joint submission from the AHA/AA makes recommendations to government about how "regional" should be defined, as well as seeking improvement to regional migraton settings so that members can accwss the skills and labour they need.  The submission covers temporary and permanent skilled migration as well as ensuring that working holiday makers continue to be required to work in the regions if they want their second and third visa extensions.

June 2024
Short Term Rental Accommodation Policy Statement (June 2024)
After the April 2024 Board Meeting, Accommodation Australia's policy on Short Term Rental Accommodation has been updatedwi the new policy as well as extra evidence and international examples.  The action on STRA has significantly increased globally in the last 12 months, driven by a universal concern about housing shortages.

May 2024
Submission to Jobs & Skills Australia on the Draft Core Skills Occupations List (CSOL) (May 2024)
This joint AHA/AA submission makes a number of reccommendations to facillitate important access by members to migrant sponsorship.  It strongly advocates for the inclusion on the proposed Core Skills Occupation List of Chefs. Cooks, Hotel Managers, Pastry Cooks, Restaurant Managers, Finance Managers and Hotel Security Managers.  It also recommends an orderly transitional period from the old system to the proposed one to ensure occupations in shortage remain accessible for sponsorship.

May 2024
Submission to the Strategic Review of the Australian Apprenticeship Incentive System (May 2024)
Accommodation Australia's represents more than 1,400 members across Australia and this submission highlights the importance of apprenticeships and traineeships to our industry and the vital role incentices play in the total business case for employers to take on an apprentice or trainee.

January 2024
Accommodation Sector Pre-Budget Submission 2024-25 to Treasury (January 2024)
Accommodation Australia's recognises the importance of working with Government departments and stakeholders and we have a demonstrated history of achievement in working with Federal, State and Local Government, law enforcement agencies, and other organisations.

 

2023


COVID Submission (December 2023)
Accommodation Australia's response to COVID-19 Pandemic to identify lessons learned to improve Australia's preparedness for future pandemics.

Submission to the ABS on ANZSCO (December 2023)
ANZSCO is the classification of occupations that the Australian Bureau of Statistics and other important bodies use for labour market analysis.  It underpins decisions on migration and training funding, and this joint submission with the AHA seeks to update the jobs that are relevant to the hotel industry today.

Permanent Migration Planning 2024/25 (December 2023)
The Department of Home Affairs has sought stakeholder views on the zise of permanent migration for 2024/25.  This joint submission with the AHA on behalf of the hotel industry recommends an increase in permanent employer sponsored migration places.

Payday Super (November 2023)
In the 2023/24 budget, the Government announced it will legislate for employers to pay their employee Superannuation Guarantee (SG) contributions at the same time that they pay salary and wages and amend SG compliance framework, including amending the calculation of the SG charge and adding new penalties.

Comments on the Principles and Standards of Assessing Authorities of Skilled Migrants (October 2023)
The migration program is critically important to the accommodation sector, and the hotels industry more broadly.  Skills assessment is a compulsory requirement for employers in sponsoring many of the occupations important to our industry.  Over the years, members have reported their frustration with the lengthy delays in finalising assessments, particularly those arranged overseas, as well as the cost.

Closing Loopholes Bill (September 2023)
The new meaning of casual employment within proposed Section 15A is a fundamental shift away from the valid and legitimate participation of casual works in our workforce.  As drafted, Section 15A unfortunately ignores the fact many casual employees prefer a regular pattern of work, want to retain flexibility to reject shifts, and want to be paid casual wage loadings.

Submission to Senate Select Committee Inquiry Into Bilateral Air Service Agreements (September 2023)
The accommodation sector is at the core of the visitor economy, employing over 110,000 Australians.  Like other sectors connected with tourism, accommodation businesses have suffered through a difficult three years and have not yet fully recovered the ground lost during the pandemic.   In particular, the sector is still being negatively impacted by the fact that international tourism has not yet fully returned to pre-pandemic levels.  As this submission makes clear, improved aviation access from international visitor source countries to Australia is of critical importance to the accommodation sector.  Decisions taken through the Bilateral Agreement process need to balance the needs of aviation as well as the tourism industry and travellers in order to achieve a sustainable competitive market.

AA Inquiry Into Australia's Tourism & International Education Sectors (September 2023)
The accommodation sector is at the core of the visitor economy, employing over 110,000 Australians, down from pre-COVID level of around 127,000. Economic value-add to tourism of the accommodation sector at $4.5 billion in 2021-22 is also showing some recovery but still considerably short of the $6.2 billion in 2018-19.


There should be NO Bed Tax in Victoria (August 2023)
Under a banner of addressing the supply of long-term rental accommodation, a bed tax is being considered by the Victorian Government.  A ‘bed tax,’ or ‘tourism tax,’ is a government-imposed levy, added to the cost of short-term stays in both traditional regulated commercial and unregulated accommodation.   There are important reasons why this proposed tax should not be implemented.


Jobs & Skills Workplan Development (August 2023)
Thank you for the opportunity for Accommodation Australia (AA) to comment on the proposed annual work plan process for Jobs & Skills Australia (JSA).  Overall, the proposed process looks comprehensive and appropriate to the important task given to JSA.  Our reflections on what is proposed are outlined below for your consideration.


Online Bookings Restrictions on Tourism & Accommodation Providers Setting Prices (January 2023)
The Accommodation Association (AAoA) and Tourism Accommodation Australia (TAA) are pleased to provide the following submission to The Treasury and Australian Trade and Investment Commission’s consultation process into Online bookings – restrictions on tourism and accommodation providers setting prices.  This submission reflects the views of our smaller and independent accommodation providers and has been created by the Associations to provide our views on the specific issues around ensuring smaller and independent accommodation providers can set their own prices.

2023-24 Pre-Budget Submission (January 2023)
Tourism Accommodation Australia (TAA) and the Accommodation Association of Australia (AAoA) welcomes the opportunity to make a pre-budget submission for 2023 - 2024. 

2022

2022 - 23 Pre-Budget Submission
Tourism Accommodation Australia (TAA) and the Accommodation Association welcomes the opportunity to make a pre-budget submission for 2022 - 2023.

TAA and the Accommodation Association recognises the importance of working with Government departments and stakeholders and we have a demonstrated history of achievement in working with Federal, State and Local Government, law enforcement agencies, educators, universities, and other organisations, never more so than over the last 24 months.

Prior to COVID-19, tourism had been identified as the super-growth sector of Australia’s transitioning economy, with a total tourist consumption of $143 billion, which saw $57.3 billion in GDP contributed to the economy (comprising 3.1% of the national total), and employment of 646,000 persons (5.2% of the Australian workforce).1 Confidence and investment had supported the recent strong performance of the sector which has outpaced national growth rate for the last three years.

Joint Submission into Regulated Sewerage
On behalf of the Australian Hotels Association (ACT Branch) and the Accommodation Association, and representing the interests of over 70 accommodation providers in the ACT, we make this joint submission to the Independent Competition and Regulatory Commission’s price investigation into prices of the fixed sewerage charges price from 2023-2028.


QLD Visitor Levy Opposition Letter
The Australian accommodation industry is facing its greatest ever challenge as our members slowly recover from the pandemic. This is especially the case with Queensland’s accommodation businesses who have been heavily impacted by the lack of available workforce which contains to drastically curtail operations. This is not a situation which is going to improve any time soon unfortunately.

2021

Reimagining the Visitor Economy - June 2021

In the 2019 year, the visitor economy was one of the largest and fastest growing sectors in the world, contributing over ten per cent to the global economy and accounting for one in ten jobs. In Australia, the visitor economy was a $152 billion sector ($126 billion in overnight visitor expenditure in 2019), provided direct and indirect jobs to one in thirteen Australians, involved one-in-eight Australian businesses and is Australia’s number one services export. It plays an important role in the economic development of regional Australia, with 44 cents in every visitor dollar spent in regions

This submission will explore the policy settings and investment that the Association and its members believe will be vital to ensure the resilience of the visitor economy post COVID, facilitating adaptation, innovation and transformation

ACCI and the Accommodation Association 4 stage plan for Domestic Travel - May 2021

The objective for managing COVID-19 in 2021 is to achieve a balance of positive health and economic outcomes. Governments have a duty to minimise both the direct virus health impacts, as well as the economic and social impacts of response measures

This document is part one of a two-part series on ‘Reopening Australia’. Part 1 focuses on domestic reopening and living with COVID-19

ACCI and the Accommodation Association 4 stage plan for International Travel - April 2021

The Accommodation Association supports the ACCI four stage plan for International Travel Reopening following table summarises the proposed plan to restart international travel in four stages. The plan overlays the three dimensions of risk: vaccinated or not, the country that the traveller is coming from or going to, and where Australia’s vaccination program is up to. All travel would include a suitable testing regime appropriate to the risk.

Addressing critical labour & skills shortages in the Accommodation sector - April 2021

This submission outlines the critical skills shortages currently being faced by the tourism accommodation sector. The sector has been significantly impacted by the pandemic, losing 50% of its workforce at the commencement, with further reductions due to the prolonged nature of the pandemic. As we emerge from the pandemic with international borders closed, the industry is seeking to meet the fluctuations in demand, with employment a direct function of rooms sold. Housekeeping and chefs have been identified as two areas of critical shortage.  

Submission and Letter to: Inquiry into the impact of the COVID-19 pandemic on the tourism and events sector (VIC) - April 2021

The Accommodation Association makes this submission to the Standing Committee on Economy and Infrastructure’ Inquiry into the impact of the COVID-19 pandemic on the tourism and events. The impact of COVID-19 on the Victorian Tourism Accommodation Sector saw losses in room revenue alone, top $1.7 billion as of year ending February 2021 according to modelling conducted by AHS Advisory. COVID-19 is now the single largest peacetime economic contraction for our Sector which has resulted in significant job losses across the accommodation sector. While many other sectors have rebounded quickly, the modelling undertaken by AHS Advisory demonstrates that the path to recovery for the tourism accommodation sector will take at least four years. 

2020

Members of the Accommodation Association wrote an open letter the Prime Minister, Premiers and Chief Ministers - July 2020

We write as the leaders of Australia’s tourism accommodation sector which has been devastated by COVID-19. As an industry prior to COVID-19 we directly contributed more than half of $47.5 billion tourism GDP and directly employed more than 113,000 Australians. While we have done everything, we can to limit the impact on our teams, our overall workforce has been reduced by close to half to 56,000 and further reduction may need to occur if JobKeeper and the Rental Mandatory Code of Conduct is not extended until March 2021

Submission to the Federal Government to extended JobKeeper for Australia’s accommodation sector - June 2020

JobKeeper must be extended to at least March 2021 in order to keep jobs and businesses alive in Australia’s accommodation sector, a critical part of the Australian tourism industry

Tourism Industry Joint Correspondence to Treasury's Coronavirus Business Liaison Unit - March 2020

A joint submission from the CEOs of the Accommodation Association, the Australian Federation of Travel Agents, Cruise Lines International Association Australasia, the Restaurant and Catering Association, the Business Events Council of Australia and the Tourism & Transport Forum. 

Our industries have collectively experienced the economic double impact of bushfires and now the far greater impact of Covid19. Our sectors are beyond pain, we are facing extinction. Current economic modelling shows that over the course of 2020 we will likely see over 300,000 job losses in tourism, or almost half the sector. 

For example, within the accommodation sector, hotels are facing occupancies of 10% or less across the country and will have no other recourse but to close their doors. And in the business events sector, every event from February 2020 through to November 2020 has been cancelled and revenues are already at zero. The harsh reality is that there is no longer any demand and therefore no work for most of our industry

Submission to Federal Government COVID19 support packages - March 2020

The devastated Australian tourism industry is now facing massive job losses and a very bleak future without significant government support to retain as many workers as possible. The sector's peak bodies have today called on the Federal Government to urgently introduce a raft of measures to urgently assist the failing visitor economy industries which are reeling from the combined impacts of the bushfires and the Covid19 pandemic

Submission to the NSW Pre-Budget Submission 2020/21 - March 2020

With the tourism industry going through a period of unprecedented crisis, the tourism accommodation sector is currently preparing short and long-term contingency measures and undertaking scenario planning in an effort to sustain business operations. During this period the government has a role to play, both in reducing immediate regulatory burdens to support growth and working with industry to both sustain growth and ensure resilience post the crisis

Submission to the Queensland Government on Short Term Letting - January 2020

The Accommodation Association is pleased to provide the following submission to the Queensland Government’s Short-Term Resident Accommodation Industry Reference Group.

Submission to the Federal Government Pre Budget 2020/21- January 2020

The Accommodation Association is pleased to provide the following submission to the Federal Government on the need to increase investment into the tourism industry in the next budget.

2019

Submission to the Australian Government Franchising Taskforce Franchising sector reforms Regulation Impact Statement 

The Accommodation Association of Australia is pleased to provide the following submission to the Franchising Taskforce in response to the call for submissions on the Franchising Regulation Impact Statement

Submission to NSW Government  Short-Term Rental Accommodation A NEW REGULATORY FRAMEWORK DISCUSSION PAPER 

The Accommodation Association of Australia (AAoA) is pleased to provide the following submission to the NSW Department of Planning, Industry and Environment responding to the New South Wales Government’s Short-Term Rental Accommodation, A new regulatory framework Discussion paper

Submission to Department of Environment and Energy - Independent review of the Commercial Building Disclosure Program

The Accommodation Association of Australia (AAoA) is pleased to provide the following submission to the Federal Department of Environment and Energy responding to the request for further input into the DRAFT REPORT of the Independent review of the Commercial Building Disclosure Program

Economics and Industry Standing Committee Inquiry into Short-Stay Accommodation in Western Australia - Submission of Accommodation Association of Australia (March 2019) 

The Accommodation Association of Australia submission Inquiry into Short-Stay Accommodation in Western Australia.

2018

Treasury Laws Amendment (Make Sure Multinationals Pay Their Fair Share of Tax in Australia and Other Measures) Bill 2018 (November 2018)

The Accommodation Association of Australia does not support the bill passing Parliament in its current form. This is because the additional tax GST on accommodation bookings the legislation seeks to impose will fall on operators of accommodation businesses – not online travel agencies – making it a virtual bed tax. Effectively, this legislation will impose a new bed tax on Australia’s accommodation businesses of 3.75 per cent.

GST on offshore hotel bookings legislation (August 2018)
The Accommodation Association strongly supports the Australian Government making it unlawful for online travel agencies to impose price-parity clauses on tourism accommodation businesses in Australia, and the introduction of measures which ensure that large, offshore-based online travel agencies pay their fair share of taxation in Australia. The Accommodation Association of Australia opposes any legislative change whereby the burden of additional tax is passed back to bricks-and-mortar accommodation businesses which are located in Australia.

Next Generation of Employment Services - Submission of the Accommodation Association of Australia (August 2018)
Future growth of the accommodation industry is in doubt if labour shortages in the industry cannot be addressed. Wage subsidies remain an attractive method of encouraging employers in the accommodation industry to hire people who are unemployed. 

Legislative Council Select Committee inquiry into short-stay accommodation in Tasmania – Submission of Accommodation Association of Australia (August 2018)
The number one priority when considering the regulation of tourism accommodation/short-term letting in Tasmania must be the safety and security of guests (consumers). Any building in which short-term letting is conducted must meet requirements under Class 3 of the Building Code of Australia.

Development of a new national long-term tourism strategy (April 2018)
To assist with improving aviation access, the accommodation industry supports Australia’s new national long-term tourism strategy containing targets to grow the number of flights and the number of seats on flights.

2017

2018/2019 Pre Budget Submission (December 2017)
The Accommodation Association's submission relating to the 2018/2019 Federal Budget.

Inquiry into impacts on local businesses in Australia from global internet-based competition (December 2017)
Australia’s accommodation industry is the subject of significant disruption from online businesses, the majority of which have their headquarters overseas. • Operators of accommodation businesses are being forced to swallow constant increases in commissions imposed on them by Expedia and Priceline.

Short-term holiday letting in NSW - Submission of Accommodation Association of Australia (October 2017)
The Accommodation Association noted the recommendations in the final report of the NSW Parliament Legislative Assembly Committee on Environment and Planning inquiry into the adequacy of the regulation of short-term holiday letting in NSW, and has provided its views.
 

Inquiry into opportunities and methods for stimulating the tourism industry in northern Australia - Submission of Accommodation Association of Australia (October 2017)
The Accommodation Association of Australia is pleased to provide the following submission to be considered as part of the inquiry into opportunities and methods for stimulating the tourism industry in northern Australia, which is being conducted by Parliament's Joint Standing Committee on Northern Australia. 

Working Holiday Maker Visa Review - Submission of Accommodation Association of Australia (September 2017)
The Association is pleased to provide the following submission to be considered as part of the fresh review of issues affecting the supply and remuneration conditions of labour performed by visa holders in the working holiday maker category. The focus of the Association's submission is the so called "backpacker tax".

2016

 

Draft State Planning Provisions (Tasmania) - Submission of Accommodation Association of Australia (May 2016)
The Association is pleased to provide the following submission to be considered as part of the consultation process on Tasmania's Draft State Planning Provisions. 

2015

 

Inquiry into the adequacy of the regulation of short-term letting in New South Wales - November 2015
The Accommodation Association of Australia is pleased to provide the following submission to be considered as part of the NSW Legislative Assembly Committee on Environment and Planning inquiry into the adequacy of the regulation of short-term holiday letting in NSW. 

The feasibility of, and options for, creating a national long service standard, and the portability of long service and other entitlements - December 2015
The introduction of any portability scheme for employee benefit entitlements is, effectively, another payroll tax on employers, which have a negative cash flow effect on businesses. 

ACCC Consultation: Online Accommodation Booking Sector - September 2015
The Accommodation Association of Australia makes this submission on behalf of its members, in response to the ACCC's request for information about the online accommodation booking sector in Australia. 

"Sharing the Future" Federal Opposition Discussion Paper - June 2015
Accommodation Association of Australia Submission in response to the release by the Federal Opposition of a discussion paper, "Sharing the Future". The Association has lodged this submission on the basis that the Opposition should take into account policy positions that the submission outlines when developing policies for the next Federal Election.  

Review of the Disability (Access to Premises – Buildings) Standards 2010
Accommodation Association of Australia submission on behalf of the Australian Building Code Working Group.

Future Directions for Australia’s Tax System - June 2015
Accommodation Association of Australia submission as part of the development of a new Tax White Paper by The Treasury on behalf of the Australian Government.

Inquiry Into Corporate Tax Avoidance - May 2015
Senate Economics References Committee Inquiry into Corporate Tax Avoidance – Submission of Accommodation Association of Australia.

Annual Wage Review 2015
After taking into account that the national wage has exceeded CPI by 1.2% over the last three years,the Panel should give special consideration to there being no increase to the national minimum wage awarded this year.

Workplace Relations Inquiry Productivity Commission (March 2015)
The economic data indicates that Australia’s labour productivity requires improvement. While a range of factors can influence labour productivity, the degree of workplace relations regulation can be influential at the workplace level.

Productivity Commission Inquiry into Business Set-up, Transfer and Closure (February 2015)
The level of regulation in Australia’s accommodation industry must strike a balance between the safety of guests and the cost of administration and compliance.

Objection to Floating Hotel - NT - February 2015 
The proposal to locate an accommodation barge described as being built to “Australian hotel standards” by the applicant is of concern to our members who operate compliant accommodation properties in Darwin.

Simplification of the skilled migration and temporary activity visa programmes – January, 2015
The tourism and hospitality sector welcomed the Review of the Skilled Migration and 400 Series visa programmes back in September 2014, presenting a joint submission on behalf of Restaurant & Catering Australia (R&CA), the Accommodation Association of Australia (AAoA), the Australian Tourism Export Council (ATEC), and the National Tourism Alliance (NTA).