Call for evidence outcome

Package travel legislation: updating the framework – call for evidence response

Updated 7 April 2025

Introduction

The 2018 Package Travel and Linked Travel Arrangements Regulations (PTRs) set a series of requirements for organisers of package holidays and Linked Travel Arrangements, which provide bespoke protections for travellers.

The government wishes to consider interactions with general consumer rights law and any opportunities to make the PTRs better suited to the needs of UK travellers and organisers, including those holidaying within the UK. 

The purpose of the call for evidence (CfE) was to:

• gain insights into how the PTRs are working
• seek views on options to improve, simplify, and rationalise some aspects

We have considered all CfE responses carefully.

The purpose of this document is to provide an overview of the main themes which arose in those responses. It aims to reflect the views offered by a diverse range of stakeholders, but it does not describe all responses in detail.

On the open questions, we have undertaken a thematic analysis to identify the key issues raised.

Some of the responses included issues which were not within the scope of the CfE. We have not, therefore, addressed these directly in this response – although we have analysed them and some may be considered in the future.

We have also considered the views expressed during the stakeholder engagement sessions, which naturally allowed deeper discussion.

Executive summary

The CfE was launched on 12 September 2023 and ended on 12 December 2023. It was conducted alongside a series of workshops and roundtables with diverse stakeholders to produce a comprehensive review of package travel legislation.

This process has not only shaped our policy direction but also identified the need for additional research to assess the understanding of current regulations and the impact of any changes for British businesses and consumers.

To this end, we commissioned an external consumer research project. The results of this are published alongside this response.

An overall theme of the responses throughout all areas of the CfE was that the PTRs need to be simpler and that, in all the areas we sought views on, there is an appetite for reforms that support industry but still provide appropriate protections for consumers.

The sector recognises the value of consumer confidence for bookings but believes that more clarity is possible in many areas.

The PTRs need to work for businesses and consumers, and be supported by clear, concise guidance and enforcement, enhancing understanding for all.

The outcome of this CfE has informed the follow-up Package travel legislation: consultation on proposed amendments.

Domestic packages

A significant proportion of industry representatives have suggested that clarifying the type of holiday trips that fall under the PTRs would support businesses as they seek to provide more cost-effective domestic offerings and packages. This could lower business risk, and could lead firms to offer new, more competitive domestic services to travellers. 

We received several strong arguments to look at this in more detail. In particular from the perspective of reducing burdens to allow small and medium-sized enterprises (SMEs) greater ability for collaboration and, consequently, to be able to offer a more tailored and value for money service to customers. Where this was seen as reducing the overall protection for consumers, it was met with opposition from consumer groups and enforcers.

The preferred option on the proposals from stakeholders on this issue was mixed. There were low levels of online support for removing all domestic packages, with strong support for reform which exempts domestic packages that do not include travel.

Responses suggested the need for greater clarity and that it may be an option for reform. Future consultation will look to understand this issue further.

Minimum cost threshold

Currently, the PTRs apply to all packages that meet the prescribed criteria, regardless of the cost of the package.

The government sought views on the benefits of an alternative approach where non-flight packages would be exempt from the PTRs if priced below a minimum threshold. This was based on there being other areas of consumer protection that rest on a minimum spend level – such as credit card payments.

The feedback received was largely against this proposal and respondents identified a number of issues this would cause, leaving the regulations more complicated for business and consumers alike. Therefore, the government does not expect to take this forward as an option for reform.

Linked travel arrangements (LTAs)

The government sought views on whether to review the current regulations related to linked travel arrangements (LTAs). Currently, there are 2 types of LTA with differing rules applied.

Examples of LTAs and further information on how they are defined can be found in Package holidays: complying with regulations - guidance for businesses.  

We wanted to understand:

• what benefits there are in the current system
• whether greater benefits could be secured by a reformed LTA model

Respondents showed a clear desire to reform LTAs to ensure simplification, but with mixed feedback on how to do so.

There were strong suggestions that the LTA type B category is seldom used by the sector, but mixed opinions on whether to remove LTAs from regulations completely, or to incorporate them within the package aspect of the regulations.

There was wide agreement that LTA type Bs are not understood or fit for purpose, and that there needs to be significant simplification of LTA type As.

We intend to consult further on both types of LTA to work out the best options to simplify the PTRs and aid compliance whilst ensuring consumers are protected.

Insolvency cover

Under the regulations there are 3 insolvency protection options which organisers can use for non-flight packages:

• bonding
• insurance
• trust accounts

We were interested in views as to how these insolvency obligations interact with other card related consumer protection provisions, such as section 75 of the Consumer Credit Act 1974 and debit card chargeback measures.  

The responses to the call for evidence show a clear desire from the industry to simplify this area and to make the provision of insolvency protection more flexible for traders to ensure some level of choice is built into how businesses choose to provide insolvency protection.

Stakeholders have indicated differing views on which methods of insolvency protection work best. Most businesses agree that having multiple routes to comply with the PTRs is preferable. 

We had extensive feedback in the CfE on this subject and held roundtables and workshops to investigate it further. There are many factors at play, including those beyond the direct coverage of the PTRs.

We are consulting on a proposal that seeks to allow more options of insolvency protection. We are mindful also that the rules on ATOL that apply to flight-based travel offered by package organisers are also under review by the Civil Aviation Authority (CAA).

Other tourist services

‘Other tourist services’ are one of the 4 types of travel service that can be combined to form a package or linked travel arrangement. These are services that are not intrinsically part of the transport of passengers, accommodation or motor vehicle hire. Examples include:

• admission to concerts
• admission to sports events
• excursions
• admission to event parks
• guided tours
• ski passes
• rental of sports equipment such as riding equipment
• spa treatments

Here, there was a majority feeling that simplification and clarity is needed.

The government is bringing forward 2 options for simplifying these provisions.

Definition of a traveller

In the current regulations, the definition of a traveller includes a traveller booking for business purposes unless a general agreement is in place. General agreements are defined in regulation 3(3) as:

an agreement which is concluded between a trader and another person acting for a trade, business, craft or profession, for the purpose of booking travel arrangements in connection with that trade, business, craft or profession.

Such agreements are common for larger business and those for whom travel is a key part of their working practices and use booking agents to provide for that. Most consumer legislation applies to transactions between business and consumers, so the PTRs are unusual in that their protections could also apply to business bookings.

Much of the feedback we received indicates that this additional protection is not an area of concern in the industry. There was a view that any change would be costly to implement as most organisers do not separately identify business and consumer travellers. This would also be hard to enforce in relation to current widely used system.

We do not expect to take this forward, as responses to the call for evidence show that most of the industry does not see this as a pressing issue.

Redress from third parties (regulation 29)

The PTRs place liability for the performance of the travel services included in the package on the organiser, irrespective of whether the travel services are performed by third parties. 

Organisers have indicated that having fulfilled their own obligations to a traveller, they can find it difficult to get redress from third parties if they have failed to fulfil elements of the package. Some third parties will refuse to refund the organiser, often claiming that they are not required to.

The requirement for organisers to provide refunds within 14 days may also not align with the time it takes to receive recompense from suppliers. 

There is a strong feeling in the sector that this is not working in its current format, not least on the back of the issues experienced during the pandemic. Many respondents would like to see stronger wording to make recouping funds from suppliers easier and support retaining or strengthening regulation 29.

This is something we will work with the sector to develop for any future consultation.

Extenuating circumstances

COVID-19 brought significant disruption to the travel sector, which affected both businesses and consumers in ways that could not be foreseen when the PTRs were introduced in 2018.

We were interested in:

• reflections on the operation of the PTRs during this time
• feedback about whether changes should be made to the regime, so that it better caters for any similarly extreme extenuating circumstances in the future

During the pandemic the industry responded by underwriting refund credit notes for an extended period until travellers could book again but there is doubt as to whether the industry would be able to offer something similar in a future scenario.

There was feedback from package organisers that leant toward allowing more flexibility in terms of refund rules and timescales in extreme extenuating circumstances. This was also met with some scepticism from consumer groups.

The current rules are consistent with other consumer legislation – such as Consumer Contract (Information, Cancellation and Additional Charges) Regulations 2013 (CCRs) where refunds are required to be processed in 14 days.

Organiser liability

While we did not specifically ask for feedback on this area in the CfE, we received some feedback that this was an area of concern for the sector.

For example, in instances where consumers receive poor service or detriment at the fault of a provider of a particular service as part of the package, should the organiser be held liable and accountable over and above the obligation on the service provider? This a topic the subject of recent court cases, and the government does not propose to intervene further at this stage.

Analysis of responses

In total there were 151 responses to the CfE, including:

• 80 responses received through the online survey
• 71 responses received by email

List of organisations that responded

Respondees that did not give permission to publish their names are not included.

• ABTA
• ABTOT
• ADVANTAGE TRAVEL CENTRES LIMITED
• ADVANTAGE TRAVEL PARTNERSHIP
• Adventure Lifesigns Limited
• Air Travel Insolvency Protection Advisory Committee
• AirBnB
• AITO
• Angela Holidays Ltd
• Association of ATOL Companies
• Association of Personal Injury Lawyers
• Audley Travel
• BA Holidays
• BBPA
• Bed & Breakfast Association (UK)
• British Holiday & Home Parks Association (BH&HPA)
• British Tourist Authority
• Broadgate Farm Cottages
• Carnival UK
• Chartered Trading Standards Institute
• Chilisauce LTD
• Citizens Advice
• Competition Markets Authority
• Confederation of Passenger Transport
• Cresta World Travel Limited
• DNATA Travel
• Easyjet Group
• Eaton Manor
• Eclipse Breaks Limited
• Expedia Group
• Gwendon Holiday Home Anglesey
• Hall Farm Cottages
• Hedgehog Corner Holiday Accommodation
• Hextalls Law
• Higher Menadew Farm Cottages
• Holiday Heat LTD
• Hotel Plan UK
• International Air Transport Association
• Jet 2 Holidays
• Lake District Estates
• Love Holidays
• Merlin Entertainments Ltd
• MSC Cruises UK
• National Trust
• NST Travel Groups & European Study Tours
• On the Beach Group plc
• Parkdean Resorts
• Protected Trust Services Ltd
• PT Trustees Limited
• RCL Cruises Ltd
• Riviera Travel
• Road Haulage Association
• Rocksdrift & Seaview Apartment
• Royal Caribbean Group
• Sanderson Phillips
• Skills MTB Coaching and Guiding
• Skyscanner
• South of Scotland Destination Alliance
• South West Tourism Alliance
• Stewarts
• Surrey County Council, Trading Standards South East
• The Different Travel Company
• The Forum of Complex Injury Solicitors
• The Professional Association of Self-Caterers UK
• Thomas Cook
• Tour easy
• Tourism Alliance
• Tourism Alliance
• Tourism Management Institute
• Towergate Travel
• Trail UK Coach Operators Association
• Trailfinders
• Travel Nation Ltd
• Travel Trade Consultancy
• Travel Trust Services Ltd
• Travelopia Group of Companies
• TUI
• UK Chamber of Shipping
• UK Finance
• UK Hospitality
• Viewfinder Tours
• Virgin Atlantic
• Visit Worcestershire
• Wales Tourism Alliance
• Welly Boot Cottages
• Which?
• Windermere Lake Cruises
• Woodcombe Lodges
• Yarn Market Hotel