Package Travel - Updating the Framework

ABTA is keen to understand how potential reforms to the Package Travel Regulations, including exemptions for domestic packages, insolvency protection, and redress mechanisms, may impact our members. Your insights will help shape our advocacy efforts with the UK Government in the coming weeks and months.
We would appreciate your views on key areas under review, including the scope of regulation for domestic packages, flexibility in insolvency protection, and changes to redress requirements. Your feedback will be crucial in ensuring that any regulatory changes strike the right balance between consumer protection and business sustainability.
Please take a few moments to share your perspectives on the following questions.


All responses are anonymous and will be aggregated for analysis.

Please complete the survey by Close of Play, 13 June 2025.
UK-Only Package Holidays

The government is considering exempting domestic packages without travel from the 2018 Package Travel Regulations (PTRs). Industry representatives argue this would lower costs and increase choice, especially for smaller businesses.

PTR protections, like repatriation and travel assistance, may be less relevant for UK-only trips.

Options:
  1. Exempt domestic packages without transport – Covered by general consumer law, reducing regulatory costs.
  2. Keep all domestic packages in scope – Ensures consumer protections and consistency.
The government seeks views on these proposals.
1.Do you think that domestic-only arrangements that do not include travel should be exempt from the regulations?
2.If you offer or have considered offering domestic packages, what impact does the current regulatory regime have on your decision to put together domestic packages?
3.Would removing domestic packages that do not include a travel element from the scope of the regulations support businesses to offer more choice?
4.Would removing domestic packages that do not include a travel element from the scope of the regulations support businesses to offer lower cost options?
5.Please explain your answers to the two questions above, setting out how and to what extent this reform could lead to benefits or detriment to business.
Linked Travel Arrangements (LTAs)

LTAs offer some protection for travellers booking multiple travel services separately but do not meet the definition of a package. They are created when:

  • Type A: Multiple services are booked in a single transaction under separate contracts.
  • Type B: Services are booked separately within 24 hours via linked processes.
LTAs were introduced to ensure fairness between travel providers and package organisers, but few businesses use them. The government is reviewing their effectiveness and considering:

  1. Keeping LTAs as they are.
  2. Retaining LTAs but simplifying how they are created.
Feedback suggests LTAs are confusing, rarely used, and difficult to enforce. The government seeks views on possible reforms.
6.What do you think the regulatory position on linked travel arrangements should be?
Flexibility in Insolvency Protection

Package organisers must secure insolvency protection through:

  • A bond
  • Insurance
  • A trust account
Currently, non-flight packages can use any method, while packages with transport must have insurance for repatriation and accommodation. Organisers using a trust can combine it with insurance but not bonding.

The government is considering allowing trust accounts to be combined with either insurance or bonding, giving businesses more flexibility while maintaining consumer protection.

Options:

  1. Allow trust accounts to be combined with either insurance or bonding.
  2. Keep the current system.
Views are sought on the best approach.
7.Would increasing flexibility in how businesses can obtain insolvency protection benefit businesses to meet their obligations under the regulations?
8.Would there be any risk associated with increased flexibility in insolvency protection, particularly for compliance and enforcement?
9.In what other ways could the cost to package travel businesses of securing insolvency protection be reduced without compromising consumer protections?
10.What are the risks and or benefits of keeping the regulations as they are?
Territorial restrictions on insurance cover

Currently, the organiser can take out one or more insurance policies which recognise the travellers as the insured persons and therefore pay direct to the travellers in the event of insolvency. Policies must be held with an insurer who is authorised in the UK, Channel Islands, or the Isle of Man.

Relaxing the territorial restriction on where the insurer is authorised could widen the choice available to organisers, which in turn could lower costs and make more packages available to travellers.

Proposal

The government is interested in views on widening the territorial restrictions on insurance cover.

Option under consideration

Option 1: Widen territorial restrictions to allow for insurers to be based outside of the UK, Channel Islands, or the Isle of Man.

Option 2: Keep as it is.
11.What should we do concerning insurance cover for insolvency protection providers?
12.How do we ensure non-UK based providers still provide good quality reliable services?
13.What impact would doing so have on the cost and quality of cover?
How other tourist services form part of the rules

‘Other tourist services’ are one of the four types of travel services that can create a package or linked travel arrangement. These include:
  • Concert or sports event admission
  • Excursions and guided tours
  • Theme park entry
  • Ski passes and sports equipment rental
  • Spa treatments
Currently, these services form part of a package if they are combined with transport, accommodation, or vehicle hire and either make up a ‘significant proportion’ or are an ‘essential feature.’ This allows minor services to be included without creating a package.

Proposal
The government is reviewing these definitions and considering whether to clarify the construction of ‘other tourist services.’

Stakeholders have raised concerns about ambiguity, particularly regarding the ‘significant proportion’ criterion, which the EU defines as 25% of the package value. Price fluctuations can unexpectedly turn a minor service into a package.


For example, a hotel stay with dinner might form a package if the dinner becomes a ‘significant proportion’ due to price changes. Removing this criterion would mean it only qualifies as a package if the dinner is an ‘essential feature,’ such as when the package is marketed around a Michelin-star experience.


Options Under Consideration

Option 1: Remove the ‘significant proportion’ criterion and rely solely on the ‘essential feature’ test. The government is also considering clarifying what qualifies as an ‘essential feature.’


Option 2: Keep the current definitions unchanged.


The government is seeking feedback on these options.
14.What should be done to the ‘significant proportion’ criterion included in the current definition of other tourist services?
15.Is it clear what forms an ‘essential feature’ of the package, so consumers and businesses understand when a package has been created?
16.What are the consequences and benefits of options 1 and 2 relating to the ‘significant proportion’ criterion?
Redress from Third Parties

Organisers are responsible for delivering package travel services, even when provided by third parties. Regulation 29 allows them to seek redress from suppliers when compensation is paid to consumers due to a supplier’s failure. However, many organisers struggle to recover costs, as suppliers often refuse refunds or delay payments.

The government is considering whether to introduce a 14-day deadline for suppliers to reimburse organisers and whether time limits should apply only in specific cases, such as cancellations or non-performance. Views are also sought on other ways to improve redress, as well as the risks and benefits of keeping the current system.
17.Should the regulations be changed to require suppliers to provide redress to organisers within 14-days?
18.Should any time limit for payment of redress apply only in narrower circumstances than Regulation 29 (for example, only where the third party has cancelled or wholly failed to provide the relevant service)?
19.What else could improve package travel organisers’ ability to obtain timely and effective redress from suppliers?
20.What are the difficulties of leaving legislation as it currently is?
21.What are the benefits of leaving legislation as it currently is?