Every year, Washington cities and counties report to the state how they spent lodging tax money, and the numbers in those reports come from the festivals, marketing groups and facilities that received it. If you are one of those recipients, someone is going to ask you how many visitors came, how many traveled more than 50 miles, and how many paid for a hotel room. This guide explains what the law requires, what the Joint Legislative Audit and Review Committee (JLARC) actually accepts as an answer, and how to collect numbers you can stand behind.
The requirement lives in RCW 67.28.1816(2). We are describing it in plain language here. It is not legal advice, and your city or county sets its own deadlines and forms, so confirm local details with your municipality. Reporting follows the spending, so see our guide to lodging tax eligible expenses as well.
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Who reports, and what the statute asks for
The legal duty has two layers. Under RCW 67.28.1816(2)(c), all recipients must submit a report to the municipality describing the actual number of people traveling for business or pleasure on a trip in three categories: staying overnight in paid accommodations, traveling fifty miles or more one way, and traveling from another state or country. The municipality makes that report available to its legislative body and the public, and furnishes copies to JLARC and to the members of its lodging tax advisory committee. One exception: the section does not apply to lodging tax imposed by a county of 1.5 million or more people, which is why JLARC lists King County as exempt from reporting.
JLARC’s reporting instructions put the duty on municipalities (cities, towns and counties that levy the tax), who enter the data through JLARC’s online Lodging Tax Expenditure Reporting System. JLARC’s 2025 lodging tax report adds that municipalities are responsible for the accuracy of their data and that JLARC does not independently verify it. In practice, your city or county needs your numbers, and the accuracy of what it passes on depends on you.
The same report says 194 of the 213 municipalities that received a lodging tax distribution (91 percent) reported for 2024. The statute does not spell out a penalty for recipients. The practical risk is credibility: the next application goes in front of a committee that remembers last year’s numbers.
What JLARC’s forms actually collect
JLARC publishes data field definitions. For each funded activity, the fields include the activity type (event or festival, marketing, or facility), funds requested and awarded, total activity cost including other funding, and attendance in several buckets:
- Overall attendance.
- Attendees who traveled more than 50 miles (JLARC’s wording; the statute says fifty miles or more).
- Attendees from out of state or out of country.
- Attendees who paid for overnight lodging, and those who did not.
- Paid lodging nights, where one lodging night is one or more people occupying a room for one night.
Each bucket has a predicted figure (given when you ask for funds), an actual figure, and a method field naming how you counted. That last field is the part that most recipients underestimate. JLARC wants to know how you got the number, not only the number.
If the activity is not expected to generate measurable attendance, such as a general marketing campaign, the definitions say to leave the attendance fields blank and explain in the notes. Where data for a field cannot be obtained, JLARC’s FAQ asks you to explain the missing or blank field in the Notes.
Estimates are acceptable, if you show your method
The statute says “actual,” and that scares people. JLARC’s reporting FAQ addresses it directly: where an actual count by attendee category is impractical, a good faith best estimate will suffice. JLARC expects municipalities and their advisory committees to ask applicants how they will determine actual or estimated attendance, and to report the method alongside the figure.
The same FAQ says JLARC staff do not have the expertise to provide technical help on estimation methods, and suggests municipalities work with the Association of Washington Cities and the Washington State Association of Counties to find it. So the burden of making your numbers credible falls on you.
The five estimation methods JLARC lists
The FAQ and data definitions name five methods, which are also the choices in the “method” dropdown:
- Direct count. Actual counts such as paid admissions or registrations, entry clicker counts, vehicle counts or chairs filled. It can include information from businesses like hotels, restaurants or tour guides affected by an event.
- Indirect count. An estimate from related information, such as raffle tickets sold, redeemed discount certificates, brochures handed out, or visual estimates.
- Representative survey. A highly structured survey of a defined random sample, with margin of error and confidence level, whose results can be projected to everyone who attended.
- Informal survey. Responses collected in a nonrandom way. JLARC says these cannot be projected to the whole visitor population and are a limited indicator.
- Structured estimate. A computed estimate from known facts. JLARC’s example is a jurisdiction that divided the square footage of an event area by the building code allowance for persons (3 square feet).
Notice the hierarchy implied there. A direct count of tickets or registrations is stronger than a raffle-ticket guess, and a random-sample survey is stronger than a pile of friendly comments. If you can use direct counts, use them.
How a website and registration data produce defensible numbers
This is where your online systems earn their keep. These are our suggestions, built on JLARC’s own method definitions:
- Ask for a home ZIP code at registration or checkout. It gives you a direct record of where registrants live, which supports the 50-mile and out-of-state figures. Decide up front how you will calculate distance, and ask your municipality whether it prefers a specific approach.
- Ask one lodging question. “Will you stay overnight in paid lodging, and for how many nights?” creates a direct record for the overnight bucket. Ask hotels and lodging partners to confirm event-related reservations too, since JLARC’s definition of a direct count includes information collected directly from businesses such as hotels.
- Separate registrants from attendees. A registration is a count of people who signed up, not necessarily people who showed up. Use check-in scans or gate counts to confirm, and note the difference in the “please explain” field.
- Label what you did. If you ran a post-event survey, call it an informal survey unless it was a true random sample. Honest labeling is what makes the rest of your numbers believable.
- Keep the raw records. If a committee member asks how you got 1,240 out-of-area visitors, you want an export you can show, not a number in an old email.
Common mistakes to avoid
- Reporting one blended number. The buckets overlap (a traveler can be both from out of state and in paid lodging). Count each category on its own terms.
- Misclassifying the activity. JLARC’s FAQ says lodging tax used to advertise a specific event is reported as event or festival, not general marketing.
- Forgetting the calendar year. JLARC notes that all reporting is for a calendar year, so a multi-month or ongoing activity is limited to January 1 through December 31.
- Waiting until the deadline. JLARC lists the reporting deadline on its reporting system home page, and your municipality will likely ask you for data well before it. Collect from day one, not after the event.
The honest verdict
You probably do not need custom software to report lodging tax results. A small event with one ticketing service that exports ZIP codes, a spreadsheet and a short lodging question can produce a clean direct count. Buy the off-the-shelf tool first, and keep your records tidy.
Custom work makes sense when you run several events or channels, when partners and lodging properties need to feed data into one system, or when you are tired of rebuilding the same report by hand every year. Then it pays to have registration, referral and lodging data in one place you own. Our tourism website design guide covers that architecture, and the Mercy House Ministry case study shows how we approach verified reporting. If you want to talk scope, request an estimate or run the free audit first. Again, this is general information, not legal advice. Your city or county has the last word on its reporting forms.
Frequently Asked Questions
Who has to report lodging tax results in Washington?
Under RCW 67.28.1816, every recipient of lodging tax funds must report to the city or county that gave them the money. The municipality then makes the report public, gives it to its legislative body, and sends copies to JLARC through the state’s online reporting system. JLARC does not independently verify the data, so accuracy rests with the municipality and, in practice, with you. Your city or county sets its own deadlines and forms, so ask for them early.
Do I need exact visitor counts, or are estimates acceptable?
The statute uses the word actual, but JLARC’s reporting FAQ says that where an exact count by attendee category is impractical, a good faith best estimate will suffice. You do need to state the method you used, such as a direct count, indirect count, representative survey, informal survey or structured estimate. Choose the strongest method you can support, and explain gaps in the notes field instead of guessing.
What does JLARC want me to count?
JLARC collects overall attendance; the number of attendees who traveled more than 50 miles, who came from out of state or country, and who paid for overnight lodging; and paid lodging nights, each as a predicted and actual figure with a method. It also collects funds requested and awarded and total activity cost. If an activity, like a general marketing campaign, cannot produce measurable attendance, you leave the attendance fields blank and explain in the notes.
How can my website help me report lodging tax numbers?
A registration or ticketing form can capture home ZIP code and a short lodging question, which produces direct records for the 50-mile, out-of-state and overnight categories. Pair it with check-in counts so you can separate sign-ups from actual attendance, and keep an export of the raw data. Label any survey honestly as informal unless it was a random sample, because a clear method is what makes your numbers defensible.