Advocacy

Advocacy

 

The Accommodation Association unites Australia's expanding accommodation sector with a single vision and a single voice. Our proactive approach to industry advocacy includes:

  • Representation on tourism boards & industry committees
  • Legislation updates
  • Government lobbying
  • Fair Work Australia submissions
     

Submissions to Government

Short-term holiday letting in NSW - Submission of Accommodation Association of Australia
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 methords for stimulating the tourism industry in northern Australia - Submission of Accommodation Association of Australia
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
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",

Draft State Planning Provisions (Tasmania) - Submission of Accommodation Association of Australia
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. 


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).

Skilled Migration Review - September 2014
The availability of skilled labour through Australia’s temporary migration system is of critical importance to the productivity of Australia’s largest export services sector, and meeting projected growth targets. A one-size-fits-all migration system is not working, particularly for many low-skilled positions required by the tourism and hospitality sector.

Modern Award Review Submission - Annual Leave Commons Issue - March 2014
The Association agrees that annual leave is a necessary entitlement, and encourages employees to use annual leave from a life-style perspective. However, it has been the experiences of Association members that employees’ request the option to cash out their annual leave to assist manage their financial and personal affairs.

Reply Submission for Annual Wage Review 2014 - April 2014
The Accommodation Association believes there are sufficient grounds to grant a wage freeze in the Hospitality Industry (General) Award for the 2013/14 annual wage review.

Annual Wage Review Submission - March 2014
The Accommodation Association of Australia recommends to the Fair Work Commission that there be no increase to minimum wages in the Hospitality Industry (General) Award.

2014-15 Pre-Budget Submission - January 2014
If an online travel agency generates business from within Australia, then it should pay a levy
or tax which could be used to bolster funding for tourism marketing, through Tourism Australia. Sufficient funding should be made available to the Australian Bureau of Statistics to enable it to revert to providing quarterly tourism accommodation statistics. Given the importance of international tourism marketing, funding for Tourism Australia should be preserved at its current level.

Submission to the NSW Liquor Review - August 2013
The accommodation industry supports complete separation of the NSW liquor licensing regime into two distinct segments: Businesses where the principal source of revenue is the sale of alcoholic (and other) beverages on-premise; and Businesses where the principal source of revenue is the sale of tourism accommodation rooms.

Inquiry into Tourism in Local Communities – NSW Legislative Council - July 2013
Local government has a track record of creating more “red tape” than less for businesses in the accommodation industry in NSW. The Accommodation Association is opposed to special variations to council rates to support local tourism initiatives because such variations are a virtual tax on tourism.

Commonwealth Consumer Affairs Advisory Council – Credit Card Surcharges Study - July 2013
Australia’s tourism accommodation businesses do not impose excessive surcharges on customers who pay by credit card for goods and services provided by these businesses.

Annual Wage Review Submission 2013 - April 2013

“Should Queensland maintain or terminate the referral of industrial relations jurisdiction for the unincorporated private sector to the Commonwealth?” - March 2013

2013/14 Pre-Budget Submission - January 2013

Senate Legal and Constitutional Affairs Legislation Committee Inquiry into Exposure Draft of Human Rights and Anti-Discrimination Bill 2012 - January 2013

Business Tax Working Group Consultation - September 2012
The industry opposes any change which would result in operators paying more taxation and the Accommodation Association calls on the Business Tax Working Group to ensure that this does not eventuate.

Building Code of Australia Review - September 2012
The Association’s position is that the definitions of Class 2 and Class 3 buildings should be clarified to ensure that buildings used for short-term tourism accommodation are Class 3, subject to the certain conditions.

Passenger Movement Charge Amendment Bill 2012 - June 2012
There should be a broader debate about the merits or otherwise of recalibrating the Passenger Movement Charge so that it benefits domestic tourism.

Annual Wage Review Reply Submission - April 2012
The Association has considered the written submissions of the ACTU and other trade unions and wishes to comment on a number of submissions presented by the ACTU.

Productivity Commission Enquiry into Default Superannuation - April 2012
We support a process for the selection of default funds within awards that both ensures those funds that are considered for inclusion in awards as default funds have an adequate performance history.

Annual Wage Review - April 2012
The Association submits that FWA should not award an increase in excess of 2.25 per cent on minimum wages in modern awards, as well as 2.25 per cent to the national minimum wage. Such a scenario would preclude many businesses from consolidating on 2011, where our industry is still in recovery mode from the global financial crisis.

Foxtel Proposed Undertaking - March 2012
The proposed acquisition of Austar by Foxtel would create a highly uncompetitive environment. This combined with the negotiating power brought by FOXTEL’s Ultimate Shareholders has the potential to create a virtual monopoly which would discourage new entrants into the market.

New Template Labour Agreement - March 2012
It is the Association’s view that the Agreement be available for tourism and hospitality employers in both regional and metropolitan areas. According to the Australian Tourism Labour Force Report, 53% of forecast accumulated labour demand by 2015 will be in Sydney or Melbourne.

New NT Tourism Strategic Plan - March 2012
Without it being overly detrimental to existing tourism businesses, the Association is supportive of the NT’s new tourism strategic plan containing measures to assist with stimulating the development of new premium accommodation businesses which target high-end leisure visitors through incentives including payroll tax relief and land tax relief.

Application to Vary Modern Award - March 2012 
The Accommodation Association makes this application to vary a number of the Award’s provisions on its own behalf, and having obtained feedback from its members

ACT Budget Submission - March 2012
The ACT Government – through the 2012-13 Budget and other policy settings – must create a regulatory and investment environment that does not result in a glut of tourism accommodation rooms in Canberra.The minimum investment in tourism by the ACT Government should be 1.0 per cent of the Budget.

Fair Work Act Review Submission - February 2012
There are areas of concern, notably a lack of protection from unfair dismissal provisions and a lack of flexibility, which imposes costly restrictions on small businesses which operate in a 24/7 environment, as the overwhelming majority of members of our Association.

Pre-Budget Submission - January 2012

There should be a broader debate about the merits or otherwise of recalibrating the Passenger Movement Charge so that it benefits domestic tourism.Taxation incentives should be considered to promote refurbishment and development of tourism accommodation businesses.

Future of Financial Advice Legislation - December 2011
Timeshare is an integral part of Australia’s accommodation and tourism industries.If both the Future of Financial Advice (FOFA) bills pass Parliament in their current form, the impact on timeshare in Australia will be immediate and devastating.

Energy Efficiency Information Grants Program - December 2011
Accommodation businesses across Australia are at varying stages of preparedness for the introduction of a price on carbon from 1 July 2012 and the transition to an emissions trading scheme from 2015.

Coalition Industries for Australia's Future Review - November 2011
There should be harmonisation of payroll tax rates and thresholds across Australia. To assist with stimulating new tourism infrastructure, land sites – particularly in major Australian capital cities – should be specifically designated for development of tourism accommodation businesses.

Cruse Ship Garden Island Access - November 2011
Accommodation businesses are one of a number of businesses that derive significant economic benefits from the cruising industry. When large cruise ships berth at Australian ports, it often results in more than a thousand visitors coming onshore.

Productivity Commission Study: Role of Local Government - October 2011
The Accommodation Association welcomes the opportunity to put forward the following submission to be considered as part of the Productivity Commission’s study to benchmark the extent to which particular approaches to the exercise of regulatory responsibilities by local governments affect costs incurred by business.

Future COAG Regulatory Reform Agenda - October 2011
There should be harmonisation of payroll tax rates and thresholds across Australia.To assist with stimulating new tourism infrastructure, land sites – particularly in major Australian capital cities – should be specifically designated for development of tourism accommodation businesses.

Tax Forum Submission  - October 2011
The Association acknowledges that the Federal Government wishes to bring the Budget back into surplus by 2012-13. Consistent with this, the Association’s submission contains taxation policy proposals that would result in less government revenue, as well as proposals that may generate additional government revenue.

NSW Enquiry into International Student Accommodation - October 2011
The international education sector is one of the fastest growing in Australia and this has corresponded with the entry into the market of commercial businesses in the sector, alongside universities who continue to control and manage the majority of student housing in Australia.

QLD Bunk Bed Safety in Accommodation Premises - October 2011

Tourism accommodation businesses across Australia invest significant capital in conforming with mandated safety requirements including the Building Code of Australia, building fire safety requirements and various other local government regulations.

Building Code of Australia Review - August 2011
The Accommodation Association – through this submission – will address issues raised in the ABCB Discussion Paper dated 11 July 2011 about the impact of different classifications within the BCA on tourism accommodation within Australia.

 

 

Other Submissions

 

Submission to RBA - Credit Card Surcharging - July 2011
The Association welcomes the opportunity to provide input into the Payments System Board’s public consultation on potential modifications to the “no-surcharge” Standards that apply to credit card and debit card systems in Australia.

 

 

The Accommodation Association unites Australia's expanding accommodation sector with a single vision and a single voice. Our proactive approach to industry advocacy includes:

  • Representation on tourism boards & industry committees
  • Legislation updates
  • Government lobbying
  • Fair Work Australia submissions
     

Submissions to Government

Short-term holiday letting in NSW - Submission of Accommodation Association of Australia
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 methords for stimulating the tourism industry in northern Australia - Submission of Accommodation Association of Australia
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
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",

Draft State Planning Provisions (Tasmania) - Submission of Accommodation Association of Australia
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. 


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).

Skilled Migration Review - September 2014
The availability of skilled labour through Australia’s temporary migration system is of critical importance to the productivity of Australia’s largest export services sector, and meeting projected growth targets. A one-size-fits-all migration system is not working, particularly for many low-skilled positions required by the tourism and hospitality sector.

Modern Award Review Submission - Annual Leave Commons Issue - March 2014
The Association agrees that annual leave is a necessary entitlement, and encourages employees to use annual leave from a life-style perspective. However, it has been the experiences of Association members that employees’ request the option to cash out their annual leave to assist manage their financial and personal affairs.

Reply Submission for Annual Wage Review 2014 - April 2014
The Accommodation Association believes there are sufficient grounds to grant a wage freeze in the Hospitality Industry (General) Award for the 2013/14 annual wage review.

Annual Wage Review Submission - March 2014
The Accommodation Association of Australia recommends to the Fair Work Commission that there be no increase to minimum wages in the Hospitality Industry (General) Award.

2014-15 Pre-Budget Submission - January 2014
If an online travel agency generates business from within Australia, then it should pay a levy
or tax which could be used to bolster funding for tourism marketing, through Tourism Australia. Sufficient funding should be made available to the Australian Bureau of Statistics to enable it to revert to providing quarterly tourism accommodation statistics. Given the importance of international tourism marketing, funding for Tourism Australia should be preserved at its current level.

Submission to the NSW Liquor Review - August 2013
The accommodation industry supports complete separation of the NSW liquor licensing regime into two distinct segments: Businesses where the principal source of revenue is the sale of alcoholic (and other) beverages on-premise; and Businesses where the principal source of revenue is the sale of tourism accommodation rooms.

Inquiry into Tourism in Local Communities – NSW Legislative Council - July 2013
Local government has a track record of creating more “red tape” than less for businesses in the accommodation industry in NSW. The Accommodation Association is opposed to special variations to council rates to support local tourism initiatives because such variations are a virtual tax on tourism.

Commonwealth Consumer Affairs Advisory Council – Credit Card Surcharges Study - July 2013
Australia’s tourism accommodation businesses do not impose excessive surcharges on customers who pay by credit card for goods and services provided by these businesses.

Annual Wage Review Submission 2013 - April 2013

“Should Queensland maintain or terminate the referral of industrial relations jurisdiction for the unincorporated private sector to the Commonwealth?” - March 2013

2013/14 Pre-Budget Submission - January 2013

Senate Legal and Constitutional Affairs Legislation Committee Inquiry into Exposure Draft of Human Rights and Anti-Discrimination Bill 2012 - January 2013

Business Tax Working Group Consultation - September 2012
The industry opposes any change which would result in operators paying more taxation and the Accommodation Association calls on the Business Tax Working Group to ensure that this does not eventuate.

Building Code of Australia Review - September 2012
The Association’s position is that the definitions of Class 2 and Class 3 buildings should be clarified to ensure that buildings used for short-term tourism accommodation are Class 3, subject to the certain conditions.

Passenger Movement Charge Amendment Bill 2012 - June 2012
There should be a broader debate about the merits or otherwise of recalibrating the Passenger Movement Charge so that it benefits domestic tourism.

Annual Wage Review Reply Submission - April 2012
The Association has considered the written submissions of the ACTU and other trade unions and wishes to comment on a number of submissions presented by the ACTU.

Productivity Commission Enquiry into Default Superannuation - April 2012
We support a process for the selection of default funds within awards that both ensures those funds that are considered for inclusion in awards as default funds have an adequate performance history.

Annual Wage Review - April 2012
The Association submits that FWA should not award an increase in excess of 2.25 per cent on minimum wages in modern awards, as well as 2.25 per cent to the national minimum wage. Such a scenario would preclude many businesses from consolidating on 2011, where our industry is still in recovery mode from the global financial crisis.

Foxtel Proposed Undertaking - March 2012
The proposed acquisition of Austar by Foxtel would create a highly uncompetitive environment. This combined with the negotiating power brought by FOXTEL’s Ultimate Shareholders has the potential to create a virtual monopoly which would discourage new entrants into the market.

New Template Labour Agreement - March 2012
It is the Association’s view that the Agreement be available for tourism and hospitality employers in both regional and metropolitan areas. According to the Australian Tourism Labour Force Report, 53% of forecast accumulated labour demand by 2015 will be in Sydney or Melbourne.

New NT Tourism Strategic Plan - March 2012
Without it being overly detrimental to existing tourism businesses, the Association is supportive of the NT’s new tourism strategic plan containing measures to assist with stimulating the development of new premium accommodation businesses which target high-end leisure visitors through incentives including payroll tax relief and land tax relief.

Application to Vary Modern Award - March 2012 
The Accommodation Association makes this application to vary a number of the Award’s provisions on its own behalf, and having obtained feedback from its members

ACT Budget Submission - March 2012
The ACT Government – through the 2012-13 Budget and other policy settings – must create a regulatory and investment environment that does not result in a glut of tourism accommodation rooms in Canberra.The minimum investment in tourism by the ACT Government should be 1.0 per cent of the Budget.

Fair Work Act Review Submission - February 2012
There are areas of concern, notably a lack of protection from unfair dismissal provisions and a lack of flexibility, which imposes costly restrictions on small businesses which operate in a 24/7 environment, as the overwhelming majority of members of our Association.

Pre-Budget Submission - January 2012

There should be a broader debate about the merits or otherwise of recalibrating the Passenger Movement Charge so that it benefits domestic tourism.Taxation incentives should be considered to promote refurbishment and development of tourism accommodation businesses.

Future of Financial Advice Legislation - December 2011
Timeshare is an integral part of Australia’s accommodation and tourism industries.If both the Future of Financial Advice (FOFA) bills pass Parliament in their current form, the impact on timeshare in Australia will be immediate and devastating.

Energy Efficiency Information Grants Program - December 2011
Accommodation businesses across Australia are at varying stages of preparedness for the introduction of a price on carbon from 1 July 2012 and the transition to an emissions trading scheme from 2015.

Coalition Industries for Australia's Future Review - November 2011
There should be harmonisation of payroll tax rates and thresholds across Australia. To assist with stimulating new tourism infrastructure, land sites – particularly in major Australian capital cities – should be specifically designated for development of tourism accommodation businesses.

Cruse Ship Garden Island Access - November 2011
Accommodation businesses are one of a number of businesses that derive significant economic benefits from the cruising industry. When large cruise ships berth at Australian ports, it often results in more than a thousand visitors coming onshore.

Productivity Commission Study: Role of Local Government - October 2011
The Accommodation Association welcomes the opportunity to put forward the following submission to be considered as part of the Productivity Commission’s study to benchmark the extent to which particular approaches to the exercise of regulatory responsibilities by local governments affect costs incurred by business.

Future COAG Regulatory Reform Agenda - October 2011
There should be harmonisation of payroll tax rates and thresholds across Australia.To assist with stimulating new tourism infrastructure, land sites – particularly in major Australian capital cities – should be specifically designated for development of tourism accommodation businesses.

Tax Forum Submission  - October 2011
The Association acknowledges that the Federal Government wishes to bring the Budget back into surplus by 2012-13. Consistent with this, the Association’s submission contains taxation policy proposals that would result in less government revenue, as well as proposals that may generate additional government revenue.

NSW Enquiry into International Student Accommodation - October 2011
The international education sector is one of the fastest growing in Australia and this has corresponded with the entry into the market of commercial businesses in the sector, alongside universities who continue to control and manage the majority of student housing in Australia.

QLD Bunk Bed Safety in Accommodation Premises - October 2011

Tourism accommodation businesses across Australia invest significant capital in conforming with mandated safety requirements including the Building Code of Australia, building fire safety requirements and various other local government regulations.

Building Code of Australia Review - August 2011
The Accommodation Association – through this submission – will address issues raised in the ABCB Discussion Paper dated 11 July 2011 about the impact of different classifications within the BCA on tourism accommodation within Australia.

 

 

Other Submissions

 

Submission to RBA - Credit Card Surcharging - July 2011
The Association welcomes the opportunity to provide input into the Payments System Board’s public consultation on potential modifications to the “no-surcharge” Standards that apply to credit card and debit card systems in Australia.