The deadline to respond to the 182 Consultation is looming, and it is now time to really focus on getting your responses in. PASC UK Cymru provides guidance on how you might answer the 12 questions in the consultation. The most important thing is that you do respond, and use the Consultation to express the impact that the threshold has had on your business, lives and health. Detail on the exemptions is slim, so it’s best to also argue for a substantial reduction in 182 as opposed to a modest reduction as proposed.

PASC UK Cymru data suggests that up to 35% of you reading this might benefit from the exemptions. That leaves 65% that will not. A lower Threshold will mean less discounting, less stress for all, regardless of whether you might directly benefit from an exemption or not. Please, let’s all argue for a Threshold that works for ALL the sector and ALL of Wales.

In Q12 we would also ask you use the Guidance to ask for firm guidance from Welsh Government on Councils having to use their discretion in allowing exemptions to Premiums, especially in the context of issues beyond the control of owners. These could be fire, flood, landslip, wildfires, ill-heath etc and even closing to carry out a major upgrade or heading for net zero. We are getting positive signals back on this, and have been advised by Welsh Government to get as many of you to include as possible.

Below you can find the three papers to help you respond, one is for Owners and Operators, one is for Stakeholder organisations that support our sector and Supply Chains one is for your teams, housekeeping, maintenance, gardening, linen suppliers and others in the wider Supply Chain. Let’s get going on getting as many responses in as possible, we know that numbers count, and personal stories make a real difference.

The Campaign to Date

PASC UK Cymru has been coordinating the Review 182 Campaign since its introduction in 2023. Our objective was simple, bring the letting threshold of 182 down to a level that would work for all the sector, across all of Wales.

Progress was pitifully slow under Welsh Labour, and in three years only one minor Consultation was launched. This was limited in scope, allowing business to count up to 14-day lettings to registered charities towards the 182 threshold, to average 182-days occupancy over three years and an exemption from Council Tax premiums for the year after a business missed the letting threshold. This last useful measure will significantly reduce the cliff edge effect of missing 182 or any other occupancy threshold. However, overall, this hardly constituted a proper review.

Coming into the Senedd Elections in 2026 PASC UK Cymru worked tirelessly with all the political parties to get key tourism measures into their manifestoes. The campaign was then renamed Reduce 182. The Welsh Conservatives came out strongly, pushing for a reduction to 105, Reform for a significant reduction to the threshold, and Plaid Cymru’s policy being a ‘modest’ reduction in the threshold and exemptions for properties that cannot be residential. Post the election result, this meant there was a significant change in the Senedd. By manifesto pledges, the majority of MSs in the Senedd now supported a review of some kind.

Since the election PASC UK Cymru have been pushing all the parties to get on with the much-needed review, renaming the Campaign again, to 182, Bring it Down. We have met with Cabinet Ministers, Officials, Visit Wales, Stakeholders and over half of the Senedd as we pushed towards trying to get the Government to commit in their first 100 days to that all important consultation. On Friday 17 July, the Welsh Government announced a Consultation into the threshold and some exemptions, meeting their Manifesto pledge. It closes on the 23 October 2026. 

YOU CAN FIND THE CONSULTATION DOCUMENT: HERE

What Does the Consultation look like?

PASC UK Cymru has had Several meetings with Cabinet Secretaries, MSs, Officials and Stakeholders as we seek clarity of the detail of the consultation.

Photos above show Nicky Williamson, PASC UK Cymru with First Minister Rhun ap lorwerth, Adam Price, Cabinet Secretary and MS, Elin Jones, Cabinet Secretary and MS and Rowland Rees-Evans, Chair of the Wales Tourism Alliance  

On the headline number, what replaces 182? The Consultation seeks to limit the reduction to 4 weeks, or 154 days and the questions are framed around the words ‘modest reduction’. This simply does not go far enough. Any threshold has to work for all businesses and for all of Wales, we have seen the terrible impact of a one size fits all threshold, and we remain deeply concerned about those that will not benefit from the exemptions being left behind, whilst others are no longer subject to any of the pressures brought about by an artificially high threshold. 

We have concerns about the exemptions too; the intention seems clear, but the devil is always in the detail.

The proposed exemptions are headed:

• Property which is part of a wider business
• Large multi-unit property
• Property subject to a relevant planning restriction
• Property within the curtilage of the owner’s home
• Property on the owner’s farm

No further clarification or detail on Exemptions has emerged, beyond that the detail will be after the Consultation closes, the Response from Government and the Guidance detail is published. All the exemptions may go through, or some may not, or not in the form that we are reading them today. It his therefore essential that all, including those that expect to get exempted argus for a substantially lower threshold, one that works for all of the sector, all of Wales. Those that don’t benefit from exemptions and would still have to hit a high threshold will still have to discount to hit the ’target; bringing pricing pressure across the whole sector.

What are the next steps?

PASC UK Cymru has provided Guidance Notes on how you might respond to the consultation. We are not telling anyone what to say, just providing examples of what might, or might not be included in responses to the 12 Questions, including the free form response areas. The version of the Guidance V3.0 is now available after useful feedback from Members. 

YOU CAN FIND THE GUIDANCE: HERE.

Although we have until the 23 October, it’s now time to start pulling your responses together. We are now unlikely to get more information, particularly about which properties may or may not benefit from exemptions, so it is best to be cautious and ask for the Threshold to be lowered significantly, not modestly. So that it works for ‘All of Wales, All of the Sector’. 

What do we think the Threshold should be?

PASC UK Cymru have always believed that the fairest threshold for all of Wales and for all of the sector should be 105 days.  We will continue to push for this, we have used this number in all the numerous Consultations involving our sector, and there are good reasons for this to be the level. Whilst it is a huge ask, especially when the Welsh Government is being prescriptive about limiting things to a ‘modest reduction’, we will have to push collectively for the lowest possible threshold, otherwise too many, who will not benefit from the exemptions, or who thought they might but could get caught out by the fine detail, will be left behind.

We have prepared a paper that argues for a 105 threshold and that can be found HERE.

How will we keep you informed?

• Guidance Notes: PASC UK Cymru have now made version 2.0 available, please bear in mind that there is no rush to respond, we have until 23 October, and we are trying together as much input as possible from Members and operators in improving this Guidance. We are of course trying to find out more detail about what exactly would be contained in each exemption. Draft version of guidance HERE.

• Weekly Wales Newsletter: PASC UK Cymru will keep everyone up to date throughout the Weekly Wales Newsletter. If you would like to receive the Wales Newsletter (each Thursday), please complete the subscription form at the bottom of this page to be added to the mailing list automatically.

• Online Meetings & Webinars: We will hold regular Online Members Meetings and free Webinars for the Sector to keep everyone abreast of developments and as further information comes available. One we have recently held, and which had a wide range of great questions from the audience, can be found HERE.

• Social channels: We will update regularly through social channels.

• We will run a Countdown as the deadline to respond gets closer.

PASC UK also urges as many of you as possible to try and meet with your MS or MP to make the case for a much reduced threshold for all of Wales and all businesses, and to ensure your voice is heard. We have a toolkit to help you make the best of these meetings and this can be found here: HERE

Please support the work that PASC UK Cymru is doing on your behalf

PASC UK Cymru has been working tirelessly on 182 ever since that awful Consultation was launched by the Welsh Government in 2022. It was not a Consultation in the full meaning of the word; it was a coup de grace on the sector and unfortunately was intended to be so. The previous Welsh Government was deaf to the challenges, issues and mental health problems they caused. Their final last offering, the breadcrumbs of Averaging and Charity Weeks, was not in any way a sufficient response to mitigate very damaging legislation.

Pre-Election and Post Election. the PASC UK Team, led by Nicky Williamson, Policy lead for PASC UK Cymru, have been recognised as the leading force in driving through to a Consultation. It’s not perfect by any means but is an opportunity for significant change.

We need to take it seriously and collectively, and for that we need your help, and your financial support. Please, if you have not joined PASC UK Cymru, please do, it costs from £90 per annum for a single property band and brings a huge range of benefits on top of the lobbying work we do, every day, on all your behalf. You can join HERE

Joining PASC UK is easy, a single property is just £90 (plus VAT from 1 January 2025) per annum. Membership gives a range of benefits including email and phone support and numerous sector specific papers on topics ranging from legal papers providing Terms and Conditions, CCTV etc, plus papers dealing with VOA, Business Rates, EV Charging etc as well as access to discounts via the PASC UK Buying Club.