Package Travel and Linked Travel Arrangements Regulations have now been published
Here is a summary of the key changes in the draft legislation, which is due to come into force on 6 April 2027.
LTAs to become packages
This is potentially the most significant consequence of the updated PTRs. What are currently classified as Type A LTAs will become packages and will therefore require organiser liability as well as financial protection.
By way of reminder, a Type A LTA is where a customer books one travel service (such as a flight) and then another (such as a hotel) in separate transactions during a single visit to a trader’s point of sale (e.g. a website).
From April 2027, this type of sale will be classified as a package. It will be interesting to see how this impacts online booking platforms and airline websites where more than one type of product is offered, as these arrangements would now fall within the definition of a package. This means they would require financial protection and would carry organiser liability.
It is also notable that there is currently no proposal to update the definition of a package in the ATOL Regulations. Whether this is deliberate or an oversight remains to be seen. If deliberate, it may (and I stress may) indicate that ATOL reform could follow relatively soon after the PTR updates. Only time will tell.
LTA Type B arrangements
Type B LTAs will cease to exist. Traders will still be able to refer consumers to relevant businesses (for example, a B&B referring customers to a local activity provider) without the need to provide financial protection.
Mandated refunds
This change addresses issues highlighted during the COVID-19 crisis. Suppliers will now be required to issue refunds to organisers within 14 days of a cancellation.
Previously, operators were often left exposed: although they were required to refund consumers within 14 days, suppliers were under no equivalent obligation to refund operators within that timeframe. This frequently left operators significantly out of pocket.
While this is good news for organisers—particularly those who experienced delays from certain airlines during COVID—it remains to be seen how enforceable these requirements will be where suppliers are based overseas.
What do I need to do?
The new PTRs will come into force in April 2027, so there is no immediate urgency. However, if you currently facilitate LTAs, you should consider whether these arrangements will be classified as packages going forward.
This is also a good opportunity to review your terms and conditions and payment terms with suppliers. Under the new rules, suppliers will have 14 days to refund you, but you will still be required to refund consumers within the same timeframe. While this is a step in the right direction, it does not completely eliminate cash flow risk.
ATOL update
The March 2026 renewal was my first at ATC “on the other side of the desk” since leaving the CAA—and, by my calculations, my 54th ATOL renewal overall. From last March’s process, it became clear just how important it is for the ATOL Reporting Accountant to understand the relevant deadlines to avoid unnecessary delays.
ATOL renewals opened on the CAA portal earlier this week, with the introduction of reduced renewal fees for ATOL holders who renew earlier.
Franchise ATOL holders (up to 1,000 passengers)
- If you submit a Small Franchise ATOL renewal application on or before 1 August 2026, the fee is £630.
- If submitted after 1 August but by 31 August 2026, the fee is £750.
- If submitted on or after 1 September 2026, the fee is £869.
Franchise ATOL holders (over 1,000 passengers)
- If you submit a complete Large Franchise application on or before 1 August 2026, the fee is £1,373.
- If submitted after 1 August but by 31 August 2026, the fee is £1,931.
- If submitted on or after 1 September 2026, the fee is £2,240.
Small Business ATOL – potential reductions
| Completed application received | Direct Debit maintained (CAA & APC) | Direct Debit NOT maintained |
| On or before 1 August 2026 | £798 | £962 |
| After 1 August but before 1 September 2026 | £1,255 | £1,329 |
| From 1 September 2026 | £1,421 | £1,542 |
Standard ATOL
| Completed application received | Direct Debit maintained (CAA & APC) | Direct Debit NOT maintained |
| On or before 1 August 2026 | £1,211 | £1,373 |
| After 1 August but before 1 September 2026 | £1,690 | £1,931 |
| From 1 September 2026 | £1,960 | £2,240 |
The CAA has also confirmed that it intends to take a firmer approach with licence holders who do not renew in September, including ensuring that non-compliant websites are taken down.
If you are renewing this September and are concerned about the process, please contact us. The earlier we are involved, the sooner we can provide support and advice.
We have extensive experience in dealing with the CAA and understand their expectations. We can also discuss scenarios with the CAA on a no-names basis to obtain informal views. If you think you may need assistance, please get in touch.
Ben White Director
email Ben.White@thetc.co.uk