Air Departure Tax Administration Regulations: business and regulatory impact assessment
This assessment considers the business and regulatory impacts associated with the introduction of secondary legislation for the administration of Air Departure Tax.
Section 2: Engagement and information gathering
Following the announcement at the 2026-27 Scottish Budget on 13 January 2026 of the implementation of ADT on 1 April 2027, the Scottish Government ran a public consultation ‘Delivering Scotland's Air Departure Tax’ seeking views and evidence on the proposed ADT Highlands and Islands exemption as well as broader ADT policy. The consultation ran for eight weeks, from 29 January to 26 March 2026, closing shortly before the dissolution of the Scottish Parliament ahead of the 2026 Scottish Parliament election.
This formal consultation was supplemented with stakeholder engagement at both official and ministerial level. This included two roundtables for stakeholders from the aviation sector and Highlands and Islands region that were hosted by the then Minister for Public Finance and Cabinet Secretary for Transport respectively.
The ADT Expert Advisory Group (EAG) was set up in March 2026 to support the rollout of ADT and shape future policy and legislation for the tax. The EAG is composed of members from the aviation, tourism and business sectors, as well as environmental non-government organisations and regional bodies. It acts as a sounding board, drawing on a wide range of subject matter expertise and perspectives. Its remit includes providing expert advice and scrutiny of potential ADT policy options, as well as identifying and helping to resolve any unintended consequences or adverse impacts that may arise. Membership may evolve over time to reflect the needs of ongoing discussions and the expertise required at each stage.
2.1 Business / Third Sector engagement
The Scottish Government has engaged with affected businesses since the announcement of ADT’s introduction date at the 2026-27 Scottish Budget. This has provided valuable insights from the aviation sector to enable a full discussion on the technical and financial implications of the implementation of ADT (and the required secondary legislation) on businesses. Other sectors, such as tourism, have also provided insights into the impacts ADT policy can have in benefiting their industry.
2.2 Internal SG engagement
The Tax Directorate within the Scottish Government has a network of stakeholder organisations with an interest in policies relating to tax, transport and rural affairs. Scottish Government stakeholders with a policy interest in proposals are contacted in respect of these proposals and consultation documents are made available to these bodies prior to publication. This includes direct contact and discussion with the following during the development phase of the policy and consultation:
- Revenue Scotland
- Transport Scotland
2.3 UK / Devolved Administrations
Although policy for ADT and APD are the responsibility of the Scottish Government and UK Government, respectively, both Governments are working collaboratively to support the transition from APD to ADT in Scotland.
2.4 Wider Public Sector
The public sector was invited to comment during the 2026 public consultation. The Scottish Government has also engaged with environmental NGOs throughout the development of ADT and its lead-up to implementation.
2.5 Other Key Stakeholders
The ‘Delivering Scotland’s Air Departure Tax’ consultation received responses from travel/tourism organisations, eNGOs, public bodies and individual members of the public with an interest in ADT.
2.6 Public consultation
The ‘Delivering Scotland’s Air Departure Tax’ consultation sought comments on the ADT Highlands and Islands exemption policy to inform the development of the secondary legislation to be subsequently introduced to the Scottish Parliament.
The consultation invited responses to a range of open and closed questions covering the proposed ADT Highlands and Islands exemption and future ADT rates for private jet passengers, as well as operational and future policy considerations and impacts. For all closed questions, respondents had an opportunity to offer comments to support their views.
The consultation received a total of 64 responses, 24 from individuals and 40 from organisations.
Prior to the consultation, the Scottish Government also engaged with Scottish aviation and tourism stakeholders regarding the logistics of devolving the tax.
Notification of the consultation was issued to a list of organisations previously identified as having an interest in ADT broadly.
The consultation ran for an eight-week period between 29 January and 26 March 2026. The responses have been categorised by respondent type as follows:
|
Respondent type |
Number of Responses |
% of total responses |
|---|---|---|
|
Airlines (including trade bodies) |
11 |
18% |
|
Airports (including trade bodies) |
4 |
7% |
|
Travel/Tourism Organisations |
4 |
7% |
|
eNGOs |
6 |
10% |
|
Public Bodies |
5 |
8% |
|
Other organisations |
8 |
13% |
|
Individuals |
23 |
38% |
Contact
Email: airdeparturetax@gov.scot