Context
The ‘Nationalities and Borders Bill’ , which includes the introduction of an Electronic Travel authorisation (ETA) for non-visa nationals travelling to the UK, has been given royal assent.
On the 21st July 2022, the Home Office published their New Plan for Immigration: Legal Migration and Border Control (publishing.service.gov.uk). Within the document are details of the Permission to Travel policy which includes the introduction of Electronic Travel Authorisations and eVisas. The main part of the document that outlines the ‘Permission to Travel’ process is from page 25.
There are still a lot of question regarding the specificities of the ETA which are to be addressed in the secondary legislation, and as it stands the legislation proposes visa requirements for non-British and Irish nationals to cross the land border in Ireland, something which the Northern Ireland Tourism Alliance (NITA) and other tourism bodies across the island of Ireland believe will be hugely detrimental to tourism on the island.
There is still very little communication on the details, however it is thought that the ETA will be valid for 2 years and will be multiple entry. As per the document released by the Home Office, the plan is to roll out the ETA scheme from January to December 2023, starting with the GCC markets in Q1. This is two years earlier than originally planned. There is no mention of Northern Ireland or crossing the land border within the document. The focus is on people arriving into the UK through authorised ports of entry.
International Visitors to Northern Ireland
Northern Ireland is promoted internationally by Tourism Ireland, as part of the Island of Ireland destination, and most overseas visitors to Northern Ireland arrive via Dublin. It is estimated that over the last twenty years that €1bn has been spent promoting the Island of Ireland overseas.
Typically, non-GB overseas tourists who travel to Northern Ireland (those that spend at least one night in Northern Ireland):
- 60% spend nights in both Northern Ireland and Ireland
- 13% spend nights only in Northern Ireland but access via a port in Ireland
According the information currently available from the Home Office, all non-visa national (NVNs) visitors into the UK, who do not hold British or Irish citizenship, will have to apply for an ETA. There will be a charge attached to this. Further details as to the exact cost and means of application/issuing are, as yet, unclear. How an approved ETA would be validated for entry on the Irish border is also unclear.
This briefing details some of the many ways in which this proposal impacts the tourism industry and the reasons we consider it to be unworkable.
Various industry partners have studied and costed the potential impact of this proposal and their findings are extremely concerning for an industry already on its knees after the pandemic.
Industry concerns
1. No Consultation
The tourism industry in Northern Ireland and across the island have not been consulted at any stage in this process despite being key stakeholders and being promised by the Home Office that their concerns would be heard. Introducing an ETA requirement to cross the border in Ireland is of huge significance to the tourism industry.
2. Difficulty to implement
Northern Ireland is unique in that it is the only part of the UK that shares a land border with another state. There are over 300 crossing points on this border. It seamlessly sits on fields, villages, streets and bridges. It would be impossible (and undesirable) to validate border crossings.
3. Non-Irish/British Citizens Residing in RoI
There are many non-Irish/British EU nationals, residing in RoI, employed in the tourism sector that need to cross the border as part of their job. Examples include coach drivers, taxi drivers, tour guides. They are employed and legally resident in RoI, yet their job requires crossing the border. As it stands, they would currently need an ETA to carry out their job. In addition, there are tour groups which travel to Ireland from mainland Europe, for whom this will be equally unworkable. In an area already experiencing a skills shortage this could prove devastating.
4. Ease of Travel
Tourism Ireland research has continually confirmed that hassle and expense are key deterrents for travellers when choosing their holiday destination, therefore consumer perception on ease of travel is paramount. Over 60% of travellers to NI spend time in both RoI and NI. For a family of 5 to travel from RoI to spend 1 or 2 nights in NI, they would need to complete 5 applications, wait for approval and spend an estimated £50 in order for them to make the trip. This is a significant barrier.
In addition to the bureaucracy and cost we must also consider the threat of prosecution resulting from noncompliance as a significant deterrent. If implemented in its current form this will be expensive and unclear and tourists may likely decide not to bother with the northern part of any itinerary. The experience of differing regulations and requirements under covid was an example of an administrative and psychological border to free travel and saw mass cancellations from tour operators.
5. Travel via EU ID Card
The UK Government have removed the EU ID card as a form of valid identity and require travellers to have a passport. Following lobbying by the Tourism Industry in Northern Ireland, the Home Office confirmed that for those travelling on an EU ID card from RoI to NI, there will be no checks and tourists will be able to cross the border. This means that the legal entry requirements for entry into the UK are different for authorised ports and for the land border with RoI. This is a sensible and enforceable policy which the tourism industry would like to see extended and replicated with regards to the ETA.
Should the ETA be implemented in its current format EU nationals who arrive in the south using an EUID will not be able to enter the north as a passport is a prerequisite to apply for an ETA. This contradicts guarantees previously given by the British government and effectively creates a barrier to free movement on the island, which contradicts the spirit of the Good Friday Agreement. This also means that EU nationals in possession of the EUID wanting to visit the island of Ireland would need a passport, as well as an ETA, creating a significant extra expense.
6. Communication
Another factor to be considered is the communication element. Entry requirements for any country are generally given when travel is booked into the port of entry. Travellers arriving in to the RoI will not be given this information and so many, especially independent travellers, may be unaware of the requirements and find themselves inadvertently having broken the law. This ‘legal jeopardy’ is something we must try and avoid.
7. Financial implications
NITA and industry partners have costed the implication of the ETA some of those findings are outlined below.ese figures are conservative.
- On an industry-wide level we estimate that the introduction and associated costs of the ETA for NVNs could impact over half a million visitors and put £160.6m visitor spend at risk (based on 2019 NISRA figures).
- 9% of residents in the RoI are not Irish citizens but are legally resident due to EU membership. Under this proposal they will require an ETA to go north of the border. Based on 2019 visitor numbers (NISRA) this could impact up to 68,000 visitors from RoI putting around £13M at risk from this alone. This is a conservative estimate as there was a significant (estimated at 50%) increase in these numbers during the pandemic
- Research from one of NI’s key attractions forecasts that an estimated 25% of visitors from outside the Common Travel Area would not travel to Northern Ireland should ETA be a requirement. The combination of the forecasted drop of both Irish-resident and international visitors totals 15%, bringing numbers down from 800,000 to 681,920 visitors per annum.
- Based on the economic impact of this aforementioned key attraction, which contributed £430m in additional spend in its first 10 years, this potential 15% drop in visitors would mean a loss of approx £10million in additional spend to the NI economy in financial year 2024/25
- For the City of Derry, due to its proximity to the border, more than 30% of its visitors are from outside the CTA, well above the national average for NI. Derry/Londonderry, which is a former (and the first ever) UK City of Culture, could see the years of hard work and innovation which went into establishing it as a go-to place in the field of tourism put at risk due to uncertainty and bureaucracy resulting from the ETA and its unworkability.
- Custodians of other key attractions have also put forward their concerns, noting that, in 2019 of the 998,000 visitors to one of their main sites, 78% were out of state, with significant number entering NI from RoI. It has also been noted that attractions close to the border may feel an even greater impact that that foreseen by the industry in general. Another factor giving them cause for concern is the impact this would have on volunteers, on which many attractions depend, and for whom Northern Ireland in general, and especially areas close to the border, may become a less attractive destination.
Proposed action
In line with other exemptions which reflect specific geographic nature of the island of Ireland and the fact that Northern Ireland is promoted internationally as part of the Island of Ireland destination we would like to see an ETA exemption for all those travelling by land to Northern Ireland via the Republic of Ireland for the purposes of tourism/ business/ work/ medical treatment. We would like to see this exemption codified in law as the tourist industry needs certainty and our visitors deserve peace of mind.
