Sections of article:

• The Package Travel Directive and Linked Travel Arrangements: A 2025-26 Guide for European Travel Businesses

• The Package Travel Directive and Linked Travel Arrangements: A 2025-26 Guide for UK Travel Businesses

• EU vs UK Package Travel Regulations: Key Differences in 2025-26

• EU Package Travel Directive (PTD) Reforms: Status and Expected Changes as of November 23, 2025

• Impact of Abolishing Linked Travel Arrangements in the EU Package Travel Directive Reforms

• Applicability to Businesses Outside the EU and UK

• EU and UK Package Travel Regulations Compared with US Consumer Protections in 2025–26

The Package Travel Directive and Linked Travel Arrangements: A 2025-26 Guide for European Travel Businesses

The EU Package Travel Directive (PTD) 2015/2302 and its provisions on linked travel arrangements (LTAs) form the backbone of consumer protection in the European travel industry. As we finish 2025, and enter 2026, with ongoing revisions to the directive following a 2023 proposal and European Parliament adoption in September 2025, travel agents, tour operators, and online platforms must adapt to enhanced rules for better traveler safeguards and operational clarity. Antravia explains the key elements, obligations, and strategies to ensure compliance across the EU, while addressing implications for businesses outside the region.

Introduction

Since its full application on 1 July 2018, the PTD has modernized protections for travelers booking combined services, responding to the rise of online and dynamic packaging. Transposed into national laws across EU member states, it ensures uniform standards while allowing some flexibility in implementation. The directive covers "packages" and "linked travel arrangements," emphasizing information transparency, performance guarantees, and insolvency protection.

In 2025, global travel is projected to surpass pre-pandemic levels (UNWTO estimates over 1.5 billion international arrivals), amplifying compliance risks. Non-compliance can result in fines up to 4% of annual turnover under national enforcement, plus civil liabilities. Recent developments include a Commission proposal from November 2023 to revise the PTD, with the European Parliament adopting its position on 11 September 2025, focusing on stronger insolvency measures, prepayment limits, and potential elimination of the LTA concept. Interinstitutional negotiations began on 24 September 2025, with final adoption expected in 2026. This guide outlines current rules, anticipated changes, and practical steps for EU businesses, including financial ties and audit readiness.

The Package Travel Directive: Core Principles and EU Implementation

The PTD aims to protect travelers by harmonizing rules on combined travel services, replacing the 1990 directive to address digital sales. Key principles include:

• Traveler-Centric Protections: Rights to clear information, remedies for non-conformity, and assistance during trips.

• Scope: Applies to EU-established businesses selling packages or LTAs to EU residents, or targeting the EU market.

• Enforcement: Handled by national authorities (e.g., consumer protection agencies), with the European Commission overseeing consistency. The European Consumer Centres Network (ECC-Net) aids cross-border disputes.

Post-COVID evaluations, including a 2021 application report and 2020 guidance on vouchers, highlighted needs for reform. The 2023 proposal simplifies aspects like vouchers (making them optional and protected) and strengthens refunds (within 14 days). As of November 2025, revisions are progressing, potentially capping prepayments at 25% (unless justified, e.g., for flights) and refining package definitions for better clarity in online bookings.

Defining Packages and Linked Travel Arrangements

Accurate classification determines the level of protection and obligations.

Packages

A package combines at least two different travel services (e.g., transport, accommodation, car rental, or significant tourist services like excursions) for the same trip, sold under a single contract, at an inclusive price, or advertised as such. Examples:

• A pre-arranged flight + hotel holiday.

• Customer-selected components via an online platform, paid together.

Key criteria:

• Combined by one trader or at their request.

• Purchased from separate traders but through processes linked within 24 hours.

• Includes services accounting for at least 25% of the total value or essential to the trip.

Full PTD protections apply, including joint liability and insolvency cover.

Linked Travel Arrangements (LTAs)

LTAs involve looser links: A traveler books one service, then is facilitated to book another from a different trader within 24 hours, often via data sharing or targeted links, without forming a single contract. Examples:

• Booking a flight, then linking to a hotel via the airline's site with details transferred.

• OTAs enabling separate bookings without full integration.

LTAs offer limited protections: Only insolvency cover for the facilitator's fees, plus disclosure requirements. Note: Proposed reforms may remove or redefine LTAs to reduce complexity, merging them into package rules for stronger safeguards.

Distinction Tip: Use national guidance or the Commission's decision tools; misclassification can lead to enforcement actions.

Key Obligations for European Travel Businesses

The PTD imposes duties across the sales and delivery cycle, enforced nationally.

Pre-Contract and Information Duties

• Provide standardized information forms (Annexes to the directive) detailing if it's a package or LTA, key features, price (including taxes), and rights.

• Disclose potential changes, additional costs, and limited LTA protections to prevent misleading claims.

Performance and Changes

• Organizers liable for the entire package, even if suppliers fail.

• Price increases limited to specific costs (e.g., fuel), max 8%; travelers can cancel free if exceeded or for unavoidable circumstances (e.g., unrest).

• Offer alternatives, price reductions, or compensation for issues; provide assistance (e.g., medical help) if travelers face difficulties.

Insolvency Protection

• Mandatory for packages: Secure refunds and repatriation via insurance, bonding, or trust-like mechanisms, varying by member state (e.g., guarantee funds in Germany, insurance in France).

• For LTAs: Limited to payments received by the facilitator.

• Reforms propose enhanced protection, like mandatory voucher coverage and clearer cross-border mechanisms.

Liability and Remedies

• Travelers entitled to remedies for non-conformity (e.g., hotel mismatches), including compensation.

• Up to three nights' accommodation if stranded, extendable under passenger rights regulations (e.g., EU 261/2004 for flights).

Financial and Audit Implications

PTD compliance intersects with business finances:

• Insolvency Mechanisms: Require financial guarantees, impacting cash flow. National schemes may involve funds like the Dutch SGR or Italian FOG, with contributions based on turnover.

• Prepayments and Refunds: Proposed 25% cap limits upfront collections, aiding liquidity but requiring robust forecasting.

• VAT and Accounting: Interact with national VAT rules (e.g., margin schemes); accurate classification avoids tax disputes.

• Audit Requirements: Vary by country—e.g., annual certifications for insolvency schemes. EU-wide, businesses must maintain records for inspections; larger operators face enhanced scrutiny.

• Liquidity Focus: Reforms emphasize rapid refunds (7 days for downpayments in proposals), necessitating strong reserves.

In 2025-26, with EU inflation at ~2% (ECB projections), monitor national implementations of reforms for cost impacts.

Staying Compliant: Practical Tips for European Businesses

• Classify and Document: Annually audit sales processes; use EU templates for disclosures.

• Enhance Systems: Integrate software for automated info provision, fund segregation, and refund tracking.

• Monitor Reforms: Follow European Parliament, Council, and Commission updates; join associations like ECTAA for guidance.

• Risk Assessments: Simulate scenarios (e.g., cancellations) and ensure insolvency cover meets national minima.

• Cross-Border Prep: For multi-country ops, align with strictest rules; leverage ECC-Net for disputes.

• Seek Advice: Engage auditors or consultants for financial modeling and compliance checks.

Embedding these practices turns the PTD into a competitive strength, fostering trust and resilience.

Conclusion for EU

As 2025-26 unfolds with PTD revisions enhancing protections amid booming travel, EU businesses must prioritize adaptability. The directive safeguards consumers while promoting fair markets, as compliance is key to avoiding pitfalls. Antravia specializes in travel finance across Europe, offering support on insolvency setups, audits, and cross-border strategies. Contact us for tailored advice, and visit the European Commission's site or national authorities for resources. Stay proactive as reforms finalize to keep your operations seamless.

The Package Travel Directive and Linked Travel Arrangements: A 2025-26 Guide for UK Travel Businesses

The Package Travel Directive (PTD) and its UK implementation through the Package Travel and Linked Travel Arrangements Regulations 2018 (PTRs) remain cornerstone regulations for protecting consumers in the travel sector. With ongoing post-Brexit adjustments and potential reforms, understanding packages and linked travel arrangements (LTAs) is essential for compliance, risk management, and financial stability. Antravia breaks down the key elements, obligations, and practical strategies to help travel agents, tour operators, and online platforms stay compliant while optimizing operations.

Introduction

The original EU Package Travel Directive (2015/2302) aimed to modernize consumer protections for combined travel services, replacing the 1990 version to account for online bookings and dynamic packaging. Post-Brexit, the UK retained and adapted these rules via the PTRs, enforced by Trading Standards and the Civil Aviation Authority (CAA) for flight-inclusive elements. These regulations cover "packages" (pre-arranged combinations of travel services) and "linked travel arrangements" (LTAs, where services are facilitated but not fully combined).

In 2025, with travel volumes rebounding to pre-pandemic levels (projected to be higher than 1.3 billion international arrivals globally per UNWTO), UK businesses face heightened scrutiny. Non-compliance can lead to fines up to 4% of global turnover, civil claims, or licence revocations. This guide explores definitions, obligations, financial implications, including ties to ATOL and trust accounts, and tips for audit-readiness, tailored for UK travel entities.

The Package Travel Directive: Core Principles and UK Adaptation

The PTD establishes harmonized rules across Europe for traveler rights, including pre-contract information, performance standards, and insolvency protection. In the UK, the PTRs mirror this but operate independently post-Brexit, with no automatic alignment to future EU changes. Key principles include:

• Consumer Protection Focus: Travelers get rights to refunds, repatriation, and compensation if services fail, shifting liability to organizers.

• Scope: Applies to businesses selling to UK consumers, regardless of where the travel occurs.

• Enforcement: Local authorities like the Competition and Markets Authority (CMA) oversee, with CAA handling ATOL-linked aspects.

Recent developments: In 2024, the EU proposed PTD revisions for better voucher handling and faster refunds, but the UK has not adopted these yet. Instead, the Department for Business and Trade (DBT) is consulting on PTR enhancements, potentially introducing stricter LTA rules by late 2025. UK businesses should monitor DBT and CAA updates to anticipate changes.

Defining Packages and Linked Travel Arrangements in UK

Understanding what constitutes a package versus an LTA is crucial for determining obligations.

Packages

A package exists when at least two different travel services (e.g., transport, accommodation, car rental, or tourist services like excursions) are combined for the same trip and sold under a single contract or at an inclusive price. Examples:

• A flight + hotel bundle sold by a tour operator.

• Dynamic packages where customers select components but pay a total price.

Key tests under PTRs:

• Combined by one trader (or on their behalf).

• Sold at an inclusive/total price or advertised as a package.

• Services purchased from separate traders but through linked processes (e.g., within 24 hours via the same website).

If it's a package, full protections apply, including insolvency cover (often via ATOL for flights).

Linked Travel Arrangements (LTAs)

LTAs are a lighter-touch category for looser combinations, where:

• A traveler buys one service (e.g., a flight), then is directed to buy another (e.g., hotel) from a different trader via targeted links or data sharing.

• The second purchase occurs within 24 hours, but without a single contract or inclusive price.

Examples:

• Booking a flight on an airline site, then clicking a partner link for car hire, with booking details transferred.

• Online travel agents (OTAs) facilitating separate bookings without bundling.

LTAs trigger limited protections: Insolvency cover only for the facilitator's service (not the whole trip), plus information duties. Unlike packages, there's no joint liability for performance issues.

Distinction Tip: If your platform uses cookies or data transfer to link bookings, it might tip into LTA territory. Use CAA's decision tree tool to classify offerings accurately.

Key Obligations for UK Travel Businesses

Compliance involves information provision, contract terms, performance, and protection mechanisms.

Pre-Contract and Information Duties

• Provide standard information forms (Schedules 1-5 of PTRs) explaining rights, using CAA templates.

• Disclose if it's a package or LTA, total price (including taxes), and any changes.

• For LTAs, clearly state limited protections to avoid mis-selling claims.

Performance and Changes

• Ensure services match the contract; liable for supplier failures.

• Allow price increases only for specific reasons (e.g., fuel costs), capped at 8%.

• Offer alternatives or refunds for significant changes; travelers can cancel without fees if unavoidable circumstances arise (e.g., natural disasters).

Insolvency Protection

• For Packages: Mandatory cover for refunds and repatriation. Options include bonding, insurance, or trust accounts. Flight-inclusive packages require ATOL, linking to CAA financial tests.

• For LTAs: Protection only for payments to the facilitator, often via insurance. No ATOL needed unless flights are involved.

Financial Impact: Trust accounts (as per PTR Reg 19) segregate client funds, requiring independent trustees and daily reconciliations. This ties into broader finance ops, affecting cash flow and audits.

Liability and Remedies

• Organizers are liable for the entire package, even for supplier errors.

• Travelers can claim compensation for non-conformity (e.g., downgraded hotel), with remedies like price reductions.

Financial and Audit Implications

PTR compliance has direct finance ties:

• Trust Accounts and Funds Segregation: Client monies for packages/LTAs must be held in trust until fulfillment, preventing commingling. Use CAA-approved setups for traceability.

• ATOL Integration: For flight packages, align with ATOL reporting (e.g., APCs based on passenger numbers).

• Liquidity and Ratios: Insolvency protection influences CAA financial tests, like current ratios. Poor setup can trigger higher bonds or monitoring.

• Audit Requirements: Annual audits verify compliance, including AAR for ATOL holders. ARAs check trust account integrity and PTR adherence.

• Tax Considerations: VAT on packages under Tour Operators Margin Scheme (TOMS) interacts with PTRs, requiring accurate classification to avoid HMRC penalties.

In 2025-26, with inflation at ~2.5% (Bank of England projections), expect scrutiny on price adjustments and voucher issuance from pandemic backlogs.

Staying Compliant: Practical Tips for UK Businesses

• Classify Offerings: Review sales processes annually; train staff on package/LTA distinctions to avoid accidental non-compliance.

• Update Contracts and Systems: Integrate PTR forms into booking platforms; use software for automated disclosures and fund segregation.

• Monitor Reforms: Join ABTA or check DBT consultations for PTD-inspired changes, like enhanced LTA protections.

• Risk Management: Conduct internal audits quarterly; simulate insolvency scenarios to test protections.

• Leverage Expertise: Partner with specialists for trust setup and financial modeling to minimize costs while maximizing compliance.

By embedding these practices, businesses can turn regulations into a trust-building advantage, reducing disputes and enhancing customer loyalty.

Conclusion for UK

The Package Travel Directive and LTAs, via the UK's PTRs, provide a robust framework for consumer protection amid evolving travel dynamics. As 2025-26 brings potential tweaks, proactive compliance safeguards your operations and finances. Antravia UK specializes in travel finance, offering tailored advice on trust accounts, ATOL integration, and audit preparation. Contact us for a consultation to ensure your business thrives compliantly. Visit the CAA or DBT sites for official resources, and stay ahead in this regulated landscape.

EU vs UK Package Travel Regulations: Key Differences in 2025-26

As of November 2025, the EU operates under the Package Travel Directive (PTD) 2015/2302, with an amendment proposal from 2023 in trilogue negotiations (European Parliament adopted its position in September 2025; final adoption expected late 2025/early 2026). The UK continues with the Package Travel and Linked Travel Arrangements Regulations 2018 (PTRs), a retained version of the 2015 PTD, but is actively consulting on reforms following a 2025 consultation (April-June 2025). This creates a diverging path, with the UK potentially simplifying rules for growth while the EU focuses on stronger protections post-COVID and Thomas Cook lessons.

EU (PTD 2015/2302 – current, pre-amendment)

As discussed above, the current EU Package Travel Directive is a mandatory harmonization measure applying across all 27 Member States. Linked Travel Arrangements exist as a separate, lighter category with limited insolvency protection and information requirements. There is no EU-wide cap on prepayments or deposits, although national rules differ. Vouchers issued during crises are voluntary but must be financially protected if used. Refunds must be issued within 14 days when the organiser cancels. Insolvency protection is mandatory for package organisers but the form of protection varies between Member States. The Directive applies fully to domestic holidays, even when all travel occurs within one country. Insolvency protection approved in one Member State is recognised across the EU. Enforcement is carried out by national authorities with oversight at EU level. Business travel is excluded when sold under a “general agreement.”

EU (Proposed Amendment – expected 2026+)

The amended Directive will strengthen crisis-related rules, introduce clearer refund obligations, and is expected to include limits on prepayments, such as a proposed 25 percent cap unless justified (although it appears this may be scrapped). The European Parliament and Council both favour abolishing or merging Linked Travel Arrangements into the main package category to simplify the rules and improve consumer protection. Vouchers will become more regulated, with clearer requirements on protection and acceptance. In some scenarios, refunds may need to be processed in as little as seven days. Cross-border insolvency mechanisms will be strengthened, and relationships with service providers will be more tightly regulated. No change is proposed to the full application of the rules to domestic holidays. Mutual recognition of insolvency protection is expected to continue, and enforcement powers for national authorities will be strengthened. Business travel exclusions will remain largely unchanged.

UK (PTRs 2018 – current as of November 2025)

The UK’s Package Travel and Linked Travel Arrangements Regulations 2018 remain effectively identical to the 2015 EU Directive, as they were retained EU law at the point of Brexit. Linked Travel Arrangements continue to exist in the UK in the same form as before. There is no cap on prepayments or deposits. Vouchers remain voluntary under the same framework as the old EU rules. Refunds must be paid within 14 days when the organiser cancels. Insolvency protection remains mandatory, with ATOL applying to flight-inclusive packages and a mixture of trust accounts, bonds, or insurance applying to non-flight packages. The rules also continue to apply fully to domestic UK holidays. UK insolvency protection schemes are no longer recognised in the EU, meaning UK organisers selling to EU consumers must obtain EU-compliant protection. Enforcement is carried out by Trading Standards, with the CAA responsible for ATOL matters. Business travel remains excluded when sold under a general agreement.

UK (Potential Reforms post-2025 consultation)

The UK Government is considering reforms that would reduce regulatory burdens for domestic tourism and simplify insolvency protection. One proposal is to abolish or significantly simplify Linked Travel Arrangements, which are viewed as confusing and rarely used. No cap on prepayments is proposed, meaning this would remain flexible for UK organisers. Vouchers in crises are expected to remain voluntary, and the 14-day refund period is likely to stay unchanged. The consultation also explores more flexible insolvency protection mechanisms, including clearer guidance on trust accounts and bonding. A major proposed change is the possible exemption of purely UK-only packages without booked transport, so such as hotel plus attraction tickets, to support the domestic tourism sector. Enforcement is expected to remain with Trading Standards and the CAA, but domestic packages may face a lighter-touch regulatory regime. Business travel rules may receive minor clarification but are unlikely to change significantly.

Practical Implications for Travel Businesses (November 2025)

• Selling to EU residents (from UK or elsewhere): You must comply with the current PTD (and soon the amended version) if “targeting” the EU market (e.g., EU languages, .eu domains, marketing in EU). UK ATOL/trust accounts alone are not sufficient → you need EU-recognised insolvency protection in at least one Member State.

• Selling to UK residents (from EU): UK PTRs apply; EU insolvency schemes are not automatically recognised in the UK.

• Purely domestic UK domestic packages (no flight): Currently fully regulated; reforms may exempt many (e.g., coach tour + hotel in Scotland) to encourage UK staycations.

• Online & dynamic packaging: Both regimes struggle with click-through/LTA distinctions, but UK may simplify faster by removing LTAs entirely.

• Future divergence risk: EU heading toward tighter consumer rights (crisis refunds, prepayment caps); UK toward lighter regulation for domestic/inbound growth.

Outlook for 2026+

• EU: New directive likely applies from late 2026/2027 → higher compliance costs but clearer rules.

• UK: Government expected to legislate reforms in 2026 → potentially more business-friendly, especially for UK-only operators.

Dual-market operators should plan for continued divergence and consider separate compliance streams or limiting sales to one market.

EU Package Travel Directive (PTD) Reforms: Status and Expected changes as of November 23, 2025

The amendment to Directive (EU) 2015/2302 (the Package Travel Directive) is currently in trilogue negotiations between the European Parliament, the Council of the EU, and the European Commission. These informal talks began in late September 2025 after the Parliament adopted its negotiating mandate on 11 September 2025 (535 votes in favour, 36 against, 47 abstentions). The Council had already adopted its mandate in December 2024.

The process is advancing quickly under the new Presidency (second half of 2025), with industry sources indicating trilogue discussions are ongoing and a provisional agreement could be reached by the end of 2025 or early 2026. Final adoption is most likely in Q1–Q2 2026, followed by transposition into national law (typically 12–24 months, so full application across the EU expected in 2027–2028).

Original Commission Proposal (29 November 2023)

The Commission aimed to address gaps revealed by the COVID-19 pandemic and the 2019 Thomas Cook bankruptcy:

• Limit prepayments to 25% of the package price (balance no earlier than 28 days before departure), with exceptions possible.

• Introduce clearer rules on vouchers (voluntary, protected against insolvency, maximum 12-month validity + optional extension).

• Faster refunds in crises (7 or 14 days for down-payments).

• Business-to-business (B2B) refund right: Service providers must refund organisers within 7 days if a service is cancelled.

• Strengthen insolvency protection, especially for prepayments and in crises.

• Clarify definitions and reduce the regulatory burden of Linked Travel Arrangements (LTAs).

Key Outcomes after Parliament and Council Positions

Both the European Parliament and the Council have substantially softened or rejected several of the European Commission’s most controversial 2023 proposals following intense industry lobbying. Below is what each institution proposed and what the final compromise is likely to look like.

1. Prepayment / Down-payment Limits
The Commission originally proposed a strict EU-wide 25 percent cap on prepayments, with only limited exceptions where higher amounts could be justified. The Council removed this cap entirely and left the decision to Member States if they wish to impose national limits. The Parliament also rejected the rigid cap and supported giving Member States the flexibility to decide whether limits are needed. The most likely final outcome is that there will be no EU-wide prepayment cap, which is viewed as a major win for industry liquidity.

2. Linked Travel Arrangements (LTAs)
The Commission supported keeping LTAs but clarifying their scope. The Council went further and proposed abolishing the LTA concept entirely. The Parliament also favoured abolishing or merging LTAs into the main package category to provide stronger and more consistent consumer protection. The likely final outcome is that LTAs will be abolished, removing a category that has long been criticised as confusing and rarely used in practice.

3. Vouchers
The Commission proposed voluntary vouchers that must be insolvency-protected and valid for a maximum of 12 months, with possible extensions in crises. Both the Council and the Parliament supported the voluntary nature of vouchers and the need for protection. The final compromise will likely keep vouchers voluntary but introduce clearer, more harmonised rules and ensure they remain fully protected.

4. Refund Timelines
The Commission proposed reducing organiser refund deadlines to seven days in certain circumstances. The Council preferred to keep the existing 14-day timeline. The Parliament showed some interest in faster refunds during crises but did not support universal acceleration. The most likely outcome is 14 days as the standard rule, with the possibility of 7-day refunds in limited B2B scenarios.

5. B2B Refund Rights
The Commission proposed giving organisers a right to obtain refunds from service providers, such as airlines and hotels, within seven days. Both the Council and the Parliament supported this measure. The likely result is that a formal B2B refund right will be introduced, helping organisers recover funds more quickly during cancellations and reducing liquidity strain.

6. Package Definition and Click-Throughs
The Commission suggested minor clarifications. The Council proposed practical adjustments to the 24-hour rule, while the Parliament supported tighter definitions and clearer timing rules to avoid unintentional package creation. The likely outcome is clearer and more consistent definitions, which should reduce accidental packages and improve compliance certainty.

7. Insolvency Protection in Crises
The Commission proposed stronger mechanisms to deal with large-scale disruptions. The Council supported enhanced cross-border protections, and the Parliament also backed improved mechanisms. The final rules are expected to deliver stronger protection for prepayments and better coordination across Member States during crises.

8. Official Travel Warnings and Extraordinary Circumstances
The Commission sought clearer rules on when travellers can cancel free of charge. Both the Council and the Parliament supported better clarity and improved definitions. The most likely result is clearer, more predictable rules governing cancellations and refunds in extraordinary circumstances, especially when official travel warnings are issued.

Practical Implications for European Travel Businesses

• No mandatory prepayment restriction at EU level → Operators can continue flexible payment plans (e.g., low deposits), improving cash flow.

• End of LTAs → Many “click-through” or facilitated bookings will become full packages, triggering full insolvency protection and organiser liability. This increases compliance costs but removes grey areas.

• Stronger B2B refunds → Airlines, hotels, and other suppliers will have to refund organisers faster, reducing the risk of organisers being out-of-pocket in mass cancellations.

• Crisis resilience → Better rules for vouchers and refunds will make future pandemics or large-scale disruptions easier to manage legally.

• National flexibility → Some Member States (e.g., Germany, Netherlands) may still impose their own prepayment limits.

Timeline Going Forward (as of 23 November 2025)

• Trilogue negotiations: Ongoing (expected to intensify in December 2025 – February 2026).

• Provisional political agreement: Likely Q1 2026.

• Formal adoption by Parliament & Council: Mid-2026.

• Publication in OJEU + transposition period: Application from 2027 or 2028.

Antravia is monitoring the trilogues closely and can help EU-based clients model the financial impact on trust accounts, bonding requirements, liquidity ratios, and contract templates once the final text emerges. The reforms are evolutionary rather than revolutionary as stronger consumer rights but more workable for the industry than the original Commission ideas.

Impact of Abolishing Linked Travel Arrangements in the EU Package Travel Directive Reforms

As of November 2025, negotiations on the reform of the EU Package Travel Directive are still underway. Both the European Parliament and the Council now support removing the Linked Travel Arrangements category entirely. This represents a significant shift from the European Commission’s original proposal, which suggested keeping LTAs but clarifying the rules. The final text is expected in early 2026, with implementation taking effect in 2027 or 2028.

Linked Travel Arrangements were created in 2015 to regulate facilitated bookings and click-through combinations where the traveller booked a flight on one site and, through a targeted link or data transfer, booked a hotel or other service on a different site within twenty-four hours. LTAs triggered only limited obligations. The facilitator had to provide insolvency protection for its own service and provide prescribed information, but the organiser liability regime and repatriation obligations that apply to packages did not apply.

The abolition of LTAs changes this structure completely. Once LTAs are removed, the current LTA scenarios will fall into two simpler categories. Tight integrations involving data transfer or targeted add-on prompts within twenty-four hours will be treated as full packages. This means that the trader will need full insolvency protection and will assume organiser liability for the entire trip. Loose click-throughs that involve only a general hyperlink without data transfer will fall outside the Package Travel Directive entirely and will be treated as standalone bookings. In those cases, only general consumer law applies and the trader must make it clear that the booking does not carry package travel protection. Clear standalone purchases remain unchanged.

Impacts on Stakeholders

Travelers benefit from stronger protection whenever multi-component bookings are tightly linked online. They also benefit from a much clearer rule set because they will either have full package rights or none at all rather than the limited halfway protection offered under the LTA model. Travelers may lose the minimal insolvency protection that currently exists for some loose combinations, because these will no longer fall within the Directive.

Airlines and large online travel platforms benefit from reduced liability on loose click-throughs. It becomes easier to design booking flows without triggering unintended regulatory categories. At the same time, many popular flight plus hotel combinations will now count as packages, requiring platforms to carry full organiser liability and insolvency protection. This is the most significant operational change for major players.

Traditional tour operators and travel agents benefit from a more level playing field. Larger platforms will no longer be able to offer flight plus hotel combinations under a lighter regulatory regime. This reduces grey areas around compliance and decreases litigation risk.

Smaller platforms and metasearch sites face a mixed outcome. Compliance becomes simpler because they no longer need to classify interactions as LTA Type A or Type B. However, if the booking journey includes structured facilitation or data transfer, they may fall into the package regime and will require new insolvency arrangements.

Insolvency protection providers are likely to see increased business volume because more products will require full protection. At the same time, the overall risk pool may shift depending on whether low-risk click-throughs fall entirely outside the Directive.

For the wider market, the abolition of LTAs brings greater legal certainty and fewer classification disputes. Traders must redesign certain booking flows and add clearer disclosures to ensure consumers understand when they are not purchasing a package. Some platforms may reduce cross-selling to maintain standalone status, and there may be a modest increase in compliance costs that feeds into consumer pricing.

Financial and Operational Consequences for Travel Businesses

Removing LTAs increases insolvency protection costs for airlines, large online travel agencies, and any business that uses targeted upsells or tight data integrations. Many journeys that previously involved limited LTA protection will now require bonds, insurance, or trust account structures that protect the entire trip.

Liquidity management becomes simpler because businesses no longer need to work within the partial protection rules that applied only to LTA facilitators. Compliance teams will spend less time determining classification and more time managing a straightforward package or standalone model.

Booking systems and website flows must be reviewed. Platforms that wish to avoid package status may remove data transfers, timed prompts, or structured facilitation. Those that choose to offer packages will need to update insolvency protections and customer communications.

Traders must continue to provide information when a booking is not a package. The Directive will require clear statements that the traveller does not benefit from package travel rights when purchasing standalone services.

Abolishing LTAs also removes one of the biggest sources of divergent national interpretation across the EU. This improves cross-border operational consistency for travel companies operating in multiple Member States.

Industry and Consumer Perspectives in 2025

Industry groups representing tour operators, online platforms, and travel agents generally support the abolition of LTAs. They argue that LTAs created unnecessary complexity, carried high compliance costs, and were poorly understood by both consumers and businesses. They also note that many platforms avoided offering flexible combinations because of uncertainty about falling into the LTA rules.

Consumer organisations take a more nuanced view. They recognise that the LTA category often failed to deliver meaningful protection but note that some travellers will lose the limited insolvency cover that LTAs currently require. However, consumer groups support abolition if accompanied by clearer package definitions and better transparency for standalone services.

Summary

The removal of Linked Travel Arrangements is the most significant simplification in the forthcoming reform of the Package Travel Directive. It eliminates an unclear and inconsistently applied category and moves the market toward a cleaner structure of either full protection or no protection. Most operators will experience either a positive or neutral impact. The main operational burden falls on large online platforms and airline websites that previously relied on LTA status to facilitate dynamic combinations.

Antravia is supporting clients across Europe and UK in preparing for these reforms. We are reviewing product classifications, modelling new insolvency protection costs, and updating booking engine designs to ensure compliance. Any business that facilitates add-on sales or dynamic combinations should undertake a structured compliance review now. Contact us for an impact assessment as the final trilogue text moves toward publication.

Applicability to Businesses Outside the EU and UK

The PTD primarily applies to businesses established in the EU or targeting EU consumers. However, it has extraterritorial effects: Non-EU/UK companies (e.g., from the US or Asia) selling packages or LTAs directly to EU residents, even if via websites accessible in the EU, marketing in EU languages, or accepting EU payments, may fall under its scope if national courts deem them "directed" at the EU market (per Brussels Ia Regulation).

Enforcement occurs through consumer claims or authorities, potentially requiring compliance with information duties, liability, and even insolvency protection. UK businesses post-Brexit are treated as non-EU, but mutual recognition may apply in specific cases. Consult national authorities or legal experts for cross-border operations to mitigate risks like fines or blocked sales.

EU and UK Package Travel Regulations Compared with US Consumer Protections in 2025–26

As we have seen above, the European Union and the United Kingdom operate some of the strongest travel consumer-protection regimes in the world. The EU’s Package Travel Directive, currently undergoing amendment (see sections below), and the UK’s retained Package Travel and Linked Travel Arrangements Regulations, supported by a 2025 consultation, both create comprehensive, mandatory protection for package holidays. These regimes govern organiser liability, insolvency protection, information standards, pricing rules, and refund rights.

The United States takes a completely different approach. There is no federal law equivalent to the EU or UK package rules. Instead, the US system relies on a mix of state-level seller-of-travel laws, specific airline rules issued by the Department of Transportation, and voluntary industry schemes. As a result, mandatory protections for US travellers vary widely depending on the state of residence, the type of trip, and the provider involved. This leaves significant gaps for multi-component holidays and tour packages.

Antravia outlines the major regulatory differences to help operators understand their obligations across markets.

Scope and Legal Framework

As we have seen above, the EU applies a single directive across twenty-seven Member States, covering packages and linked travel arrangements. The UK regime remains almost identical to the pre-Brexit directive, with domestic reforms under discussion. The United States has no equivalent federal law. Some states define tour packages for registration and bonding purposes, but these definitions have no nationwide effect.

The EU and UK define a package as any combination of at least two travel services sold for an inclusive price or purchased through a linked booking process. The US has no federal definition and offers no uniform protections for multi-component trips.

Linked travel arrangements exist in EU and UK law as a lighter category with limited protection, although both jurisdictions are considering removing this structure because of its complexity and limited consumer benefit. The United States does not recognise the concept.

Insolvency Protection

Insolvency protection sits at the core of the EU and UK regimes. Organizers must protect all customer prepayments through approved mechanisms such as bonds, insurance, trust accounts, or national funds. In the UK this includes the ATOL scheme for flight-inclusive packages.

The United States does not impose federal insolvency protection requirements on tour operators or sellers of travel. Only four states require bonding or trust arrangements for businesses selling to their residents. Outside these states, consumers rely on credit card chargebacks, optional travel insurance with financial default coverage, or voluntary schemes such as the one million dollar USTOA programme.

This creates a sharp contrast. EU and UK travellers are guaranteed full refunds and repatriation if the organiser collapses. US travellers have no comparable guarantee unless the operator participates in a voluntary scheme.

Organizer Liability and Information Rules

The EU and UK impose full organizer liability for the performance of the entire package, even when the fault lies with a supplier. Mandatory information standards apply before and after booking. These rules cannot be contracted out.

The United States relies mainly on contract law. Organizer liability is determined by the company’s terms and conditions unless a specific state law applies. There are no equivalent federal information forms or mandatory disclosures for multi-component holidays.

Pricing and Refunds

The EU and UK allow price increases only in limited circumstances and cap increases at eight percent unless the traveller is offered the right to cancel. Refunds for cancellations must be processed within fourteen days. Proposed amendments in Europe may accelerate refunds in crisis situations.

The United States imposes no federal limits on price changes for packages. Refund rules are driven by the provider’s contract. The only strong federal refund protections apply to airlines under the DOT framework. These include automatic refunds for cancelled flights, rules on significant schedule changes, and enhanced baggage and wheelchair protections.

Extraordinary Circumstances and Force Majeure

The EU and UK define extraordinary circumstances and specify when travellers are entitled to refunds or alternative arrangements. These provisions were tested widely during the pandemic and will be clarified further under the EU amendments.

The US system leaves force majeure largely to contract interpretation. Outcomes vary significantly between operators.

Seller of Travel Registration

EU and UK organizers do not need to register as sellers of travel because protection arises through the package itself.

In the United States, registration is required only in California, Florida, Hawaii, and Washington. See our blog on this. These states also impose bonding or trust requirements. Importantly, these rules apply extraterritorially. A foreign operator selling to residents of those states must meet the registration and bonding obligations even if they have no physical presence there.

Voluntary Industry Schemes

Because the US lacks mandatory rules for organizers, voluntary protections play a significant role. The USTOA one million dollar travellers assistance programme provides insolvency protection for participating operators, although it covers only a small portion of the industry. Membership bodies such as ASTA offer guidance but no financial protection fund.

Such schemes are not necessary in the EU or UK because insolvency protection is compulsory.

Airline Passenger Rights

EU carriers are subject to EU Regulation 261 for delays, cancellations, and denied boarding. These rules apply alongside the package travel protections. The UK maintains a similar regime through retained EU law.

The United States has a strong and expanding DOT regime for airline passenger rights, including automatic refunds for cancellations and new rules on mandatory price transparency. These protections apply only to air travel, not to tours or multi-component holidays.

Key Takeaways for Travel Businesses

EU and UK organisers must comply with the full package travel regime whenever they sell a package, regardless of where the customer lives. Non-compliance exposes businesses to significant regulatory and civil liability.

US organisers generally operate without mandatory insolvency protection and face lower regulatory burdens. They only need to register and bond if selling to residents of California, Florida, Hawaii, or Washington. However, US operators selling packages to EU or UK consumers must comply with EU or UK law if the sale meets the package definition, which often requires EU or UK recognised insolvency protection.

For consumers, EU and UK travellers enjoy robust financial guarantees that prevent loss of money if the organiser fails. US travellers booking non-USTOA packages face higher financial risk, and outcomes depend heavily on the operator, the state of residence, and the payment method used.

The US framework prioritises business flexibility, while the EU and UK prioritise strong consumer safeguards. As global travel continues to integrate, many US operators are beginning to adopt trust accounts or bonding voluntarily so they can compete in regulated markets.

Antravia supports travel companies across Europe, the UK, and the United States with financial modelling, compliance structure design, and cross-market strategy. Contact us for support as the EU amendments and UK reforms take shape through 2026.

References

• Civil Aviation Authority (CAA) 2023, ATOL Reform – Consultation and Policy Updates, UK Civil Aviation Authority. Available at: https://www.caa.co.uk/atol-protection/trade/atol-compliance-and-regulations/atol-reform/

• Civil Aviation Authority (CAA) 2023, UK Civil Aviation Authority launches next stage of ATOL reform, UK Civil Aviation Authority. Available at: https://www.atol.org/news-and-blogs/2023/01/24/uk-civil-aviation-authority-launches-next-stage-of-atol-reform/

• Directive (EU) 2015/2302 of the European Parliament and of the Council of 25 November 2015 on package travel and linked travel arrangements [2015] OJ L 326/1. Available at: https://eur-lex.europa.eu/eli/dir/2015/2302/oj

• EFTA 2024, Factsheet – Directive (EU) 2015/2302 on Package Travel and Linked Travel Arrangements, European Free Trade Association. Available at: https://www.efta.int/eea-lex/32015l2302

• European Commission 2023, Package Travel Directive – Travel and Timeshare Law, European Commission, Consumer Protection. Available at: https://commission.europa.eu/law/law-topic/consumer-protection-law/travel-and-timeshare-law/package-travel-directive_en

• European Commission 2023, Proposal for a Directive of the European Parliament and of the Council amending Directive (EU) 2015/2302 on package travel and linked travel arrangements, 29 November 2023. Available via: https://commission.europa.eu (Package Travel Directive – Review section)

• European Parliament 2024, Revision of the Package Travel Directive – EU Legislation in Progress, European Parliament Think Tank (Legislative Train and Briefing). Available at:
  https://www.europarl.europa.eu/legislative-train/
  and: https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2024)757642

• HM Government 2018, The Package Travel and Linked Travel Arrangements Regulations 2018, SI 2018/634, legislation.gov.uk. Available at: https://www.legislation.gov.uk/uksi/2018/634/contents

• HM Government 2018, Directive (EU) 2015/2302 as retained in UK law, legislation.gov.uk. Available at: https://www.legislation.gov.uk/eudr/2015/2302

• ICAEW 2023, ATOL News – June 2023: Update on ATOL Reform, Institute of Chartered Accountants in England and Wales. Available at: https://www.icaew.com/regulation/working-in-the-regulated-area-of-audit/become-a-licensed-practice/atol-news/june-2023

• UN Tourism 2025, UN Tourism World Tourism Barometer – January 2025, UN Tourism. Available at: https://www.untourism.int (World Tourism Barometer data)

• UN Tourism 2025, International tourism up 5% in first half of 2025 despite global challenges, UN Tourism News Release. Available at: https://www.untourism.int/news/international-tourism-up-5-in-first-half-of-2025-despite-global-challenges

• UN Tourism 2024, International tourism recovers pre-pandemic levels in 2024, UN Tourism World Tourism Barometer (summary). Available at: https://en.unwto-ap.org/news/worldtourismbarometer_jan2025

• US Department of Transportation 2025, Refunds – Aviation Consumer Protection, U.S. Department of Transportation. Available at: https://www.transportation.gov/individuals/aviation-consumer-protection/refunds

• European Commission 2020, EU Air Passenger Rights, Your Europe Portal. Available at: https://europa.eu/youreurope/citizens/travel/passenger-rights/air/index_en.htm

• Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights [2004] OJ L 46/1. UK retained version at: https://www.legislation.gov.uk/eur/2004/261

• USTOA 2025, USTOA $1 Million Travelers Assistance Program, United States Tour Operators Association. Available at: https://ustoa.com/travelers-assistance

• State of California Department of Justice 2025, Seller of Travel – Registration Requirements, Office of the Attorney General. Available at: https://oag.ca.gov/travel

• Florida Department of Agriculture and Consumer Services 2025, Sellers of Travel – Business Services, FDACS. Available at: https://www.fdacs.gov/Business-Services/Sellers-of-Travel

• Washington State Department of Licensing 2025, Sellers of Travel – Professional Licenses, Washington DOL. Available at: https://dol.wa.gov/professional-licenses/sellers-travel

• Hawaii Department of Commerce and Consumer Affairs 2025, Travel Agency Program – Professional and Vocational Licensing Division, State of Hawaii. Available at: https://cca.hawaii.gov/pvl/programs/travel/

• Hawaii Department of Commerce and Consumer Affairs 2013, Information and Instructions – Application for Travel Agency Registration, DCCA PVL. Available at: https://files.hawaii.gov/dcca/pvl/programs/travel/application_publications/travel-agency-registration/Information-%20Instructions%20-%20Application%20for%20Travel%20Agency.pdf

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Content published by Antravia is provided for informational purposes only and reflects research, industry analysis, and our professional perspective. It does not constitute legal, tax, or accounting advice. Regulations vary by jurisdiction, and individual circumstances differ. Readers should seek advice from a qualified professional before making decisions that could affect their business.
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