UEFA European Championship (Scotland) Bill: final business and regulatory impact assessment (BRIA)
Final Business and Regulatory Impact Assessment (BRIA) for UEFA European Championship (Scotland) Bill.
Section 3: Costs, impacts and benefits
Quantified costs to businesses
Option 1: Do nothing
Scottish Government would not propose legislation for parliamentary consideration. UEFA's requirements would likely not be met.
If UEFA did not permit Scotland to host, Glasgow and Scotland may still see some economic and social benefit from the UK and Ireland hosting EURO 2028, for example, through visitor tourism. But it is likely that this would be much more limited than if Scotland were a co-host.
There may be a longer-term reputational cost to Scottish Government, Glasgow and Scotland as an event host if EURO 2028 does not take place at Hampden Park as a result of not having commercial rights protection measures in place. This could limit Scotland’s ability to secure future event opportunities, and the economic and social benefits attached to them.
Current provision on ticketing could result in members of the public buying tickets at inflated prices and still being unable to attend the matches due to the ticket terms and conditions. Not prohibiting unauthorised resale could add risks to the safety and security of the event.
If UEFA did permit Scotland to host, the lack of more detailed legislative provision to prevent unauthorised advertising or street trading activity may make it more difficult for UEFA to secure investment commitment from sponsors, for example to purchase advertising space.
Option 2: Framework legislation
There would be costs to Scottish Government, Local Authorities and Police Scotland in scoping and developing proposals, as well as to businesses to engage with and contribute to proposals. This would be more extensive than for Option 3 because framework legislation would affect people, organisations and businesses across Scotland on an ongoing basis.
It is uncertain how many rights holders would seek protections through framework legislation for mega events or how frequently. This means a more uncertain impact on local businesses from advertising and street trading restrictions compared to option 3. Due to infrastructure requirements for mega events, impacts would most likely affect businesses in Glasgow and Edinburgh. However, the 2025 Tall Ships Races in Aberdeen and the 2025 International Island Games in Orkney are examples of large scale events hosted in other parts of Scotland. The recent UCI Cycling World Championships also spread events around Scotland, including to Fort William, the Scottish Borders, and Dumfries and Galloway.
There would likely be ongoing costs for Police Scotland, Glasgow City Council and other local authorities to ensure sufficient capacity to enforce legislative measures for events. Again, it is relatively uncertain how many future mega events in Scotland might seek this provision and therefore what these costs would be. However, we could expect these costs to have longer term impacts than the specific and short-term provision for EURO 2028 only.
Framework legislation would likely require some kind of assessment process for eligible events, which has already been undertaken for EURO 2028. There would be costs to assessing a specific mega event. This would likely include rights holders, event organisers, local authorities, VisitScotland, Police Scotland and Scottish Government.
Given the more complex and wider scope of framework legislation, there is a risk that impacts could not be sufficiently scoped and understood with key stakeholders within the time available to put the measures in place for EURO 2028 specifically. This risks longer term unintended costs from framework provisions. There would also be a risk that legislative provision was not put in place within the timescales required for EURO 2028. This could risk a more rushed bespoke provision to meet UEFA’s requirements for hosting EURO 2028 with less time for scrutiny or even failure to meet the requirements altogether. If UEFA’s requirements were not met, this would incur similar costs to Option 1.
Option 3: Bespoke EURO 2028 legislation – Proportionate and limited restrictions (preferred option)
There would be costs to Scottish Government, Local Authorities (mainly Glasgow City Council) and Police Scotland in scoping and developing proposals, as well as to businesses to engage with and contribute to proposals. This may cost less than for Option 2 because the effect of the advertising and street trading proposals is limited to EURO 2028 in Glasgow, and the ticket touting provisions to EURO 2028.
Costs as a result of the Bill include for Glasgow City Council in relation to enforcement and communication activity that is required to ensure compliance. These are estimated to be around £65,000-£125,000 in 2028/29 prices, although some of this could be covered by the redeployment of existing resources. Glasgow City Council would be expected to incur these costs from early 2028 until the event ends (and a short period following), with the bulk of costs arising during the tournament in Summer 2028.
The Scottish Government estimate approximately £195,000 of staff costs will be required from April 2026 to September 2027 to support development of regulations, including event zone locations and times of operation. This would be met from the existing Scottish Government staff budget. Police Scotland also estimate costs of around £45,000. Police Scotland expect to be able to meet costs from within existing EURO 2028 and business as usual budgets.
There would also likely be some small costs to other organisations including, SLAB, SCTS and COPFS. The overall cost to these three public sector organisations was estimated at £0-50,000 in 2028/29 prices.
There would be costs to businesses in Glasgow affected by restrictions on advertising and street trading in event zones. Provision would include a duty for Glasgow City Council to offer affected traders alternative trading arrangements to mitigate the impact of the restrictions and allow them to still benefit from the opportunity the Championship represents.
One of the event zones will be around Hampden Park. The other(s) are expected to be around official fan zone(s) in a Glasgow city centre location. Businesses in the Retail Trade, Accommodation or Food and Beverage industries in these areas are most likely to be affected by the restrictions. Latest data from the 2024 Annual Survey of Hours and Earnings estimates that the median hourly wage in Scotland in these industries is £12.15, £12.28 and £11.80 respectively. These businesses will need to read and, where relevant, apply guidance that will be provided by Glasgow City Council.
Provisions propose that certain advertising that is in place in the event zones to remain such as fixed/permanent branding of businesses, to help to minimise the impact of the advertising restrictions on businesses. This would not permit any advertising installed specially for EURO 2028, in addition to usual branding. If so, there would be a cost to Glasgow City Council in carrying out an audit of existing branding before the event.
Other impacts
The Bill would have an impact on a relatively small number of street traders and other businesses in comparison to those operating in Glasgow as a whole. Only external advertising and trading is captured by suggested restrictions. Many existing businesses in these zones could therefore continue to trade unaffected, though outdoor areas would be affected. Certain advertising in place in the event zones could be allowed to remain if the Bill were to come into force, reducing the impact on business. The duty on Glasgow City Council to offer affected street traders alternative trading arrangements would help mitigate the impact on this group.
Scottish firms’ international competitiveness
The Bill is not expected to affect Scottish businesses’ ability to compete internationally.
Events make a significant contribution to Scotland’s economy, driving tourism and hospitality, providing a platform from which to showcase Scotland and its international trading strengths. They provide exposure for Scotland’s nation brand and can generate profile for a city or region. This international profile can enhance Scotland’s reputation, bring people together to make and maintain international relationships, and support global recognition of our cultural assets, including our landscapes, festivals, artists and historic landmarks. EURO 2028 will enhance Scotland’s reputation as the perfect stage for events. It will continue the strong pipeline of events. This included the World Athletics Indoor Championships in 2024 and the first ever UCI Cycling World Championships in 2023.
The UCI Cycling World Championships had broadcast coverage in 130 countries, reaching a cumulative audience of over 537 million. There were 1,000 items of global press coverage reaching over 1.5 billion, with an 81% positive sentiment in media coverage. 93% of spectators felt proud of Scotland hosting the championships.
The reported worldwide television audience for EURO 2024 in Germany was 5.4 billion. Around 2.6 million spectators attended the 51 matches played during EURO 2024, with fans present from more than 190 countries. The official UEFA EURO 2024 channels on TikTok, Instagram, Facebook, X and WhatsApp have added more than 14 million new followers since the start of the championship. The channels accumulated 335 million engagements and 2.8 billion video views during the event.
Benefits to business
Option 1: Do nothing
It is expected that EURO 2028 would still go ahead under this option, but Scotland would not meet UEFA’s requirements to host. There is a risk that UEFA would not permit Scotland to host matches.
The Scottish Government would save resource from not progressing legislation any further. This resource could be diverted to other Scottish Government work.
Without any enhanced legislative provisions to enforce, there would less need for increased resource from Glasgow City Council and Police Scotland. Costs for the EURO 2028 legislation are estimated to be around £65,000-£125,000 for Glasgow City Council and £45,000 for Police Scotland in 2028/29 prices. This would be a saving of resource compared to the other options.
Option 2: Framework legislation
General provision for mega events could meet UEFA’s likely requirements for hosting EURO 2028.
In addition to the benefits outlined for the Bill for EURO 2028 only (Option 3), this option could help Scotland “future proof” itself for other mega events in future years that may require rights protections. This could increase the range of hosting opportunities Scotland could consider and derive benefit from. In so doing, it could more strongly fulfil the 2023/24 Programme for Government commitment to support a pipeline of strong hosting opportunities.
Framework legislation might create an opportunity for rights holders of other large-scale events in Scotland to seek similar protections to those proposed for EURO 2028. It could also seek to address a wider range of points identified by the events sector. This could benefit a larger number of event organisers in Scotland.
A consistent approach to measures for mega events and associated enforcement could make it easier for Scottish Government, Local Authorities and Police Scotland to plan and budget for such events.
Option 3: Bespoke EURO 2028 legislation – Proportionate and limited restrictions (preferred option)
The Bill would meet commitments that have been made to UEFA on protection of commercial interests. It will help to ensure successful delivery of the event, which will bring broader economic benefits to Glasgow and Scotland. This may help Scotland's chances in securing any future mega events.
Glasgow residents and visitors would benefit from a celebratory look and feel where there is EURO 2028 related activity.
By ensuring that sponsors’ and licensees’ exclusive rights to associate their brands with the EURO 2028 is safeguarded, the proposed legislation will maximise potential sponsorship funding for the event.
Provisions on ticket touting would reduce the likelihood of this being attempted. This protects UEFA’s commercial interests and would also benefit members of the public, who might otherwise buy tickets at inflated prices and still be unable to attend the matches due to the ticket terms and conditions. UEFA’s current terms and conditions prohibit resale and transfer save in the explicit circumstances permitted by those terms and conditions. For example, tickets purchased from a secondary ticket platform or social media are invalid under UEFA’s current terms and conditions. Prohibiting unauthorised resale could also contribute to the safety and security of the event.
By directing measures to cover only EURO 2028, any negative impacts are clearly limited to a particular place and time, and can be consulted on, providing those affected to provide a view on impacts. This includes the costs of measures to Police Scotland and Glasgow City Council, and any adverse impacts to local businesses from restrictions to advertising and street trading.
There is no uncertainty of the Bill applying to other events, places or times.
Small business impacts
The main costs identified for small businesses are the time required to understand and comply with restrictions. Feedback from the Federation of Small Businesses has highlighted that small businesses are often time-poor and can be unaware of new restrictions for large events. Proactive engagement and communication with small businesses about restrictions, giving them plenty of time and information to be prepared, is therefore important.
Option 1 would mean no new restrictions for small businesses to comply with but may also see no or less increase in revenue if no EURO 2028 matches were hosted in Glasgow. For EURO 2028 specifically, the effects of Options 2 and 3 on small business would be the same. However, Option 2 could mean similar restrictions being put in place for other events, whether in Glasgow or elsewhere. Restrictions put in place might vary from event. This increases the potential scale of impact on small businesses.
Option 3 does not rule out similar restrictions being put in place for other events. However, because no new primary legislation would be required, Option 2 might mean less advance notice for businesses of restrictions applying for future large events.
Impacts could be mitigated by setting and communicating restrictions well in advance of EURO 2028, giving small businesses more time to plan in preparations. Issuing guidance on the restrictions could also help small businesses to understand what is required more quickly.
Investment
While EURO 2028 is expected to raise Scotland’s international profile, the Bill itself is not expected to make Scotland a more, or less attractive place for global investment. It is not expected to impact on investors or investment sentiment.
Workforce and Fair Work
Policy options are not expected to affect the workforce, beyond time taken to understand and comply with the restrictions in the Bill. They are not expected to affect business ability to meet the Fair Work First principles.
Climate change/ Circular Economy
Policy options are not expected to impact on business ability to contribute to climate and circular economy targets. They are not expected to contribute to the reduction, reuse or recycling of resources by businesses. Although hosting EURO 2028 is expected to increase the goods or services consumed in Scotland (through the visitor economy), the Bill itself is not.
Competition Assessment
Will the measure directly or indirectly limit the number or range of suppliers?
The Bill would limit the number of street traders operating in the event zone(s) while they were in operation. The Scottish Government anticipates that the impact on street traders could be mitigated by a duty on Glasgow City Council to offer them alternative trading arrangements.
Will the measure limit the ability of suppliers to compete?
Restrictions on trading and advertising in the event zones for specified event periods could have some impact on competition. This could likely benefit EURO 2028 sponsors and authorised traders, who would be able to operate in event zones with reduced competition. We think that this impact on competition is proportionate given the overall size and economic benefit of the event to Glasgow (and Scotland) as a whole. Where the restrictions in the Bill apply, it would be for a short time and within a limited geographical area. This would not make a permanent change to business.
There are some exemptions to the advertising offence in the Bill. These include certain advertising to which the Town and Country Planning Regulations 1984 do not apply (because, for instance, it forms part of the fabric of a building), and advertising to commemorate events. This would help to minimise the impact on businesses and their ability to compete.
Will the measure limit suppliers' incentives to compete?
The Bill is not expected to limit suppliers’ incentives to compete.
Will the measure affect consumers’ ability to engage with the market and make choices that align with their preferences?
The Bill may limit the choices of consumers within the designated event zone(s) specifically for the time that they are in operation. However, it is not expected to affect their ability to engage with the market and make choices that align with their preferences overall or in the long term.
Will the measure affect suppliers’ ability and/or incentive to introduce new technologies, products or business models?
The Bill is not expected to affect suppliers’ ability and/or incentive to introduce new technologies, products or business models.
Consumer Duty
The Bill aims to protect the commercial rights of UEFA and its partners for EURO 2028. It does so by restricting street trading and advertising within designated event zones at specific times, and by restricting the resale of EURO 2028 tickets.
The street trading and advertising restrictions may limit the choices of consumers within the designated event zone(s) specifically for the time that they are in operation. The Bill would limit the number and range of suppliers in the event zones when these are in operation (providers of food, beverages and Championship memorabilia, in the main). However, other businesses in the zones such as those based inside buildings (such as bars, shops and restaurants) should be able to operate largely as normal. These provisions are considered to be proportionate as they would only apply to the relatively small geographical area covered by the event zones and would only be in effect for a short period of time around the time of the event.
The Bill may also have a positive impact on consumers as a result of people being assured that they are buying official merchandise.
While the primary driver of the EURO 2028 legislation is commercial rights protection, in its response to the public consultation Advice Direct Scotland found that similar street trading for EURO 2020 had a positive effect on consumer rights and confidence. Limiting the number of traders in prescribed zones and ensuring that the ones that were allowed were regulated increased accountability and minimised bad actors. An event such as EURO 2028 is an opportunity to strengthen trust in Scotland’s consumer landscape to residents and abroad. Advice Direct Scotland noted the adverse impact that poor quality goods and services have on consumer experiences and the damage it can do to consumer trust. This is compounded by rampant and ever evolving scam tactics that seek to deprive consumers of money and personal information. Street Trading, to any extent that it occurs, must provide goods that are in good condition, as described and of suitable quality. Any deviation from this lowers trust and causes consumer detriment. They encouraged raising awareness among consumers of both street trading restrictions in event zones, and potential scams and poor-quality goods outwith event zones. In addition, there should be counter-scam initiatives and investigations into repeat offenders.
Advice Direct Scotland believed that advertising was key in reducing the risk of scam advertising and ambush marketing for EURO 2020. Both of these use the popularity of events to take advantage of consumers, using urgency and lack of information to pressure consumers into regrettable decision making. Restrictions reduced the opportunities to take advantage of consumers. They therefore anticipated a significant positive effect on consumer experiences from similar restrictions for EURO 2028. The removal of advertisements that lead to consumer issues would boost consumer confidence and minimise detriment. The targeting of ambush advertising would also reduce the risk of scams and poor goods and services. The regulation of advertising would ensure that whatever organisations can advertise are accountable to consumers. However, Advice Direct Scotland considered that exemptions for charitable purposes would be appropriate. This would allow charitable acts to be performed without compromising the curtailment of scams and ambush advertising. Charitable acts should also be authenticated in order to protect consumers and promote accountability.
Tickets are often sold on the secondary market significantly above face value; for example, research by the Competition and Markets Authority found that most tickets sold through Viagogo and StubHub in 2019 had a mark-up over their face value of more than 50%. Demand for EURO 2028 tickets is expected to be high. There were over 50 million ticket requests for EURO 2024 and only 2.7 million tickets available. Evidence of EURO 2024 ticket resale prices suggests much higher mark-ups than 50% in some cases. Creating a criminal offence of ticket touting is expected to discourage this practice and allows for action to be taken to punish ticket touting both in person and by electronic methods. For these reasons, the Bill should reduce opportunities for unscrupulous suppliers to target consumers.
In its response to the public consultation, Advice Direct Scotland reflected on contacts through its consumer.advice.scot service regarding the touting of tickets during EURO 2020. The demand for tickets, coupled with the urgency placed on getting them created fertile ground for fake tickets. These caused consumer detriment and significant difficulty in getting any kind of redress. The market for touted tickets remains prevalent to this day and it is important that efforts to raise consumer awareness and prevent tactics from being used. Nevertheless, it considered that ticket touting restrictions for EURO 2028 would reduce the effect of touting tickets and increase in ticket scams in the runup to the events. This highly publicised event will have a large demand on the tickets and the incentive for resale will be very high. Pointing to UEFA EURO 2024 championships, where ticket resale prices rose to over £10,000 in some cases, Advice Direct Scotland stated that this kind of demand increases the detriment faced by consumers and gives scammers additional resources to conduct the same scams repeatedly. Strict measures should be used to prevent these kinds of tactics. In addition, reducing the resell practicality of the tickets with exclusive codes and non-transferable methods would also reduce the practicality of selling the tickets (e.g. with paper tickets).
Advice Direct Scotland considered the exemption of selling tickets by auction for charitable purposes to be reasonable and ethical. This is a purpose that is aimed to perform a good deed, without a view of illicitly profiting from the resale of tickets. The removal of a profit motive would curtail the common incentive for ticket resale. The regulation of charity work would mitigate the risks of this exemption and would not mislead the public about resales.
It also highlighted that ticketing restrictions should be paired with clear public information and additional preventative tactics. Proper channels for the sale of tickets should be clearly indicated and secure against reselling. The use of electronic and non-resalable tickets for EURO 2024 minimised the ability to tout and made scam tickets much easier to identify. It is far better for a consumer to avoid detriment.
Some respondents to the public consultation supported a ban on ticket resales more generally, which could benefit consumers. The UK Government launched a consultation on the resale of live events tickets and a call for evidence on pricing practices (dynamic pricing) in the live events sector on 10 January 2025.
The Equality Impact Assessment and Fairer Scotland Duty Assessment for the Bill have considered impacts on consumers who may be living in vulnerable circumstances. Advice Direct Scotland has found that certain groups, including older people, isolated people and those with disabilities, are frequently targeted by scams and illicit practise that takes advantage of their situations. It had seen scammers use tent-pole events to market scam products and services, using popularity as a sales pressure and false sense of security. It thought the measures proposed had the potential to provide additional protection and safeguards to vulnerable and marginalised people. They would otherwise be vulnerable to poor goods and services from traders that were not sufficiently regulated.
It is unlikely that harm will be experienced by consumers as a result of the Bill. It should not affect the essential services market. It should not have an impact on consumers' ability to seek advice. It will be possible for consumers to inform enforcement officers of breaches of the restrictions so that these can be addressed, as appropriate. The Bill will not affect the information available to consumers on either goods or services, or their rights in relation to these. The Bill does not involve storage or increased use of consumer data.
Contact
Email: majorevents@gov.scot
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