Below you will find our recommendations on how the government should alter the Bill to help ensure fairness and prevent the damage the Bill promises the local economy as written.
Create scaled requirements based on property size and risk:
Micro-operators (1–5 units, owner-occupied) → simplified application: Proof of insurance, self-certification on safety checklist, fewer certificates.
Small operators (6–20 units) → moderate compliance: Some external inspections, simplified hazard plan templates.
Hotels and complexes (20+ units) → full compliance as drafted.
This tiering recognizes different operating capacities and limits undue burden on homeowners renting a room versus corporate hotels.
Mandate that the Ministries or Licensing Authorities publish service-level agreements (SLAs) for:
Issuing licenses
Scheduling and completing inspections
Processing renewals and exemptions
If government delays/exceeds these SLAs, operators should be automatically granted provisional licenses until inspection is complete.
Report annually (publicly) on SLA metrics for each affected Ministry or Authority.
This avoids the “who-you-know” favouritism risk and ensures equal access to compliance.
Publish free templates for:
Multi-hazard management plans (scaled for small vs. large properties)
Guest record logs (compliant with the 7-year retention rule) OR scrap these requirements entirely for data privacy reasons
Monthly occupancy reporting forms
Offer short training videos or webinars for small and micro-operators on accessibility standards, safe ID storage and emergency protocols.
These tools reduce the compliance learning curve.
The Bill allows 1–5 years for certain requirements (safes, hazard plans, accessibility). Extend these further for ALL operators OR allow compliance in phased steps (e.g., accessible bathrooms by year 3, entrances by year 5). These new timelines should be based on a realistic or even worst-case assessment of availability on the island of both government resources and the supplies necessary for retrofits.
Pair deadlines with financial or technical support (see below).
Duty-free concessions for safety, accessibility, and compliance equipment:
Safes
Fire extinguishers
Ramps
Rails
Generators
Water tanks
Tax credits or rebates for documented accessibility upgrades and insurance premiums.
Low-interest micro-loans via government or credit unions for compliance investments.
Grants or subsidies for multi-hazard planning and training, comparable to the subsidies hotels receive for capital works.
Publish a comparative concessions schedule: Show what hotels receive (duty-free, tax breaks) and match proportionally scaled incentives for short-term rental operators.
Allow small and micro-operators to access a 'Tourism Compliance Concession Program' for partial relief of compliance costs.
This directly addresses fairness: If large hotels get duty waivers on imported furniture, smaller operators should get duty waivers on installing accessibility ramps or buying a safe.
Instead of heavy, up-front inspections, use a “trust, but verify” model:
Operators file a sworn self-declaration
Random audits catch bad actors
Purpose-based audits - if a complaint is received, it may trigger an audit or review
Appropriately safeguard the audit process to ensure it isn't abused
This reduces bottlenecks (30,000 certificates otherwise) and shifts enforcement focus to risk-based inspection.
Ideally, government should scrap the requirement for operators to store sensitive personal data at all. At a minimum, they should consult with representatives of the European Union as to how their law interacts with the GDPR requirements for their citizens (as well as other jurisdictions that offer similar protections, including but not limited to: Quebec, Ontario, California, New York). Additionally, this would force operators under the Data Protection Act - 2019, a likely unintended consequence of the Bill, that would be virtually unnavigable for small and micro-operators.
OR
Government should issue minimum data security standards for storing photo IDs and 7-year guest logs.
Provide approved low-cost software or cloud templates, so small and micro-operators don’t risk non-compliance or breaches.
Without adjustment, the Bill risks:
Pushing small operators out of the market (reduced diversity of offerings)
Direct economic harm to the island (from reduced accommodations and economic participation)
Shifting demand toward large hotels, enabling them to raise prices without proportionate benefit to the local economy (which will reduce tourism demand)
Undermining fairness by treating homeowners and major international chains as if they had equal resources
With tiered requirements, clear service standards and financial support, the Bill could still achieve its aims (safety, quality, accessibility), while retaining small operators, sustaining local jobs and preserving authentic Barbadian tourism experiences.