Status on Proposed Greenland Tourism Law

Following the latest consultation in July, the proposal for the Greenland Tourism Law has now been submitted to the Parliament for debate and decision for the autumn parliamentary session.

The proposal submitted to the Parliament is identical to the draft that was sent in consultation in July with no changes or further clartifications.

The intent behind the proposal is:

1. To implement a requirement for providers of tourism activities in Greenland to hold a Government license and that such a license can only be acquired by Greenland residents or companies controlled by Greenland residents.
2. To empower the Greenland Government to implement zones with requirements for access, traffic and economic activities.

Main issues:

• Authorization is changed to License. The initial proposal was to require an authorization and that this would be granted for a limited period and for specific locations. The license is not time or geographically limited.
• §2, item 1: Definition of tourism activity requiring license. Clarification that the requirements for license applies to providers of a) daytrips without overnight stay, and b) trips of several days duration
• §3, items 6-8: Exemptions from requirement for license. A clarification on which operators are exempt from the license requirement – an issue raised by AECO in the response to the initial consultation as it was not clear to which extent cruise operations and activities would be exempt.
  • The revised proposal is that requirement for license does not apply for “physical or legal entities providing passenger transport to/from and in Greenland without engaging in tourism activity in connection with this”. This is interpreted in the comments as:
    • (the exemption) .. concerns all transport of tourists, where the primary purpose is not to offer touristactivities. This applies to cruise vessels and other vessels sailing with tourists to or from Greenland.
    • … (the requirement for licens) applies if the physical or legal entity offers other activities covered by this law, where the means of transportation is used for such activity not as part of the transportation.
• §9Requirements for companies eligible to apply for license:
  • Company must be home in Greenland
  • More than 50% of the company must be owned by persons registered with residence in Greenland
  • The (Greenlandic) company must have full control of its equity
  • Owners, with direct or indirect ownership of more than half of the voting rights in the company must be registered as residents of Greenland and be liable for full taxation by Greenland
• §15, item 2 regarding zoning. includes now a clarification that zoning regulations must align with other existing municipal planning regulations or other regulations – an issue raised by AECO in our response to the initial proposal.
  • In the comments international agreements are also mentioned to be considered.

AECO’s main concerns

• If the requirement for licenses will apply on activities undertaken by the cruise operators as part of the cruise, such as nature landings, Zodiac cruising, kayaking, etc. AECO has highlighted this issue in both responses to the various consultations, and in several meetings with the Ministry. There is still no clarification.
• How extensively municipalities will use the opportunity to apply red zones (no go) and yellow zones (conditions apply)

Proposed implementation

The Tourism law is proposed to come into force by January 1, 2025, but with a clause allowing for all companies engaged in present tourism activities to continue their activities until January 1, 2027.

Parliamentary process and timeline

The first debate on the proposal is planned for October 3, the second on November 15 and the final decision is on February 6, 2025. Between the Parliamant debates, the proposal will be sent in Committee for further discussion and potential amendments.