Background
The Package Travel and Linked Travel Regulations 2018 provide the current framework for the travel sector and protection of consumers. As the regulation stipulates that they must be reviewed every 5 years, the Department for Business & Trade (DBT) published its response following the consultation from April to June 2025.
The government's policy objectives are to strengthen consumer protection while supporting the growth of the UK’s package holiday sector. The government considered the key themes of the PTR’s involving LTAs, insolvency protection and modifying Regulation 29.
Linked Travel Arrangements (LTAs)
The government intends to make two key changes to the LTAs:
(i) Absorbing LTA Type A into the definition of a “package”, and
(ii) Removing LTA Type B entirely.
Type A of the LTA applies where a business facilitates the separate selection and payment for bookings of the same trip through a single booking session. This change would provide full package protection when a consumer makes a similar booking to the current Type As. These arrangements will become packages under the reformed rules, requiring agents to place an appropriate insolvency protection in place. This would effectively extend consumer rights whilst simplifying business compliance.
Examples of Type A LTA’s:
Case Study 1:
A traveller visits a travel agent and purchases a plane ticket, making payment and concluding the contract. Then, without leaving the travel agency, he wishes to also buy accommodation for the purpose of the same trip. He concludes a contract for the accommodation and then pays separately for this second service either at the agency or on checking out of the hotel. This would under the new rules be a package.
Case Study 2:
After a traveller books and pays for a flight on an online travel agent’s website they are invited to book car hire for their holiday on the booking confirmation page. The traveller subsequently selects and pays for car hire for the same trip under a separate contract though the same website during the same single visit. This would be an LTA as the online travel agent has facilitated the traveller’s separate selection and payment of two travel services for the purposes of the same trip during a single visit to their website. Under the new proposed rules this would now be deemed a package.
Guidance is also provided as to what would not constitute an LTA and therefore a package in the form of the Governments third case study:
A traveller calls a travel agent’s telephone booking line. The traveller books and pays for return flights, then hangs up. Half an hour later, the traveller decides they wish to book their accommodation via the same travel agent. They call again, and book and pay for a hotel. This would be neither a LTA nor a package as the purchases were in separate contacts with the travel agent’s point of sale.
Additionally, the government aims to eliminate Type B arrangements, where a trader facilitates a booking of an additional service from another trader within 24 hours. This would provide minor consumer protection and are easily bypassed. Abolishing Type B arrangements would support domestic sector growth, allowing small businesses to refer customers to local activity providers without creating regulatory obligations.
LTA Type B Case Study 1:
A traveller has purchased a return flight to New York from an airline and when the booking was confirmed, the airline sent them an invitation to book a hotel room in New York through a link to a hotel booking site. Under the existing rules, as the traveller booked a hotel room on the linked website within 24 hours of purchasing their flight, an LTA was created. This means that if the airline became insolvent while the traveller was in New York, and the return flight cancelled as a result, their repatriation would be covered by insolvency protection that the airline would be obliged to have in place as an LTA facilitator. In addition, the airline would have to ensure that when the traveller receives the link for the hotel reservation they are clearly and prominently informed that the flight and hotel will not constitute a package. Under the new rules this will neither be an LTA nor a package.
Case Study 2:
Shortly after a traveller books and pays for a flight on an online travel agent’s website they receive an email inviting them to book car hire for their holiday. The traveller subsequently clicks on the link on the email and finds that the car hire is booked without them needing to re-enter their trip dates or payment details. Under the existing rules this would be a package as the two services are purchased through a linked booking process, within 24 hours, and where the traveller’s details have been transmitted from the travel agent to the car hire company. Under the new rules this will not be a package, nor an LTA.
Case Study 3:
A traveller books accommodation on a B&B website. Having done that the traveller clicks through to a page on the B&B’s website called “Local Attractions”. Here, the B&B owner has listed a number of recommended local restaurants, attractions, and ‘things to do’. Inspired by this recommendation, the traveller books tickets to the local theme park. This is neither a package nor a LTA as the B&B owner provided a range of useful information (rather than encouraging the traveller to book in a targeted manner)
Regulation 29
There is also an intention to modify Regulation 29, which specifically deals with the right to redress from third parties. The government proposes a stricter 14-day period for refund of cancelled services. The DBT clarified that the regulations confer a statutory right to redress in specified circumstances rather than a mere right to seek redress. The changes aim to facilitate package travel organisers to recover costs from suppliers such as airlines and hoteliers more effectively, strengthening business resilience and ensuring costs of consumer safeguarding are distributed more equitably.
Response from industries
ABTA has welcomed the government's response to the PTRs consultation, in agreement that the Regulations generally work well, especially through COVID. ABTA Director of Public Affairs, Luke Petherbridge, provides support for the proposal to improve clarity around the rights of the travel companies to seek redress from suppliers.
ABTOT’s Membership Director also supports the government’s decisions to incorporate Type A LTAs and to abolish Type B LTAs, agreeing that this could provide clarity for the industries and consumer confidence. However, AITO stated concerns about unnecessary regulatory burden, particularly for smaller specialist tour operators. Adding that members continue to face substantial costs for circumstances outside of their control.
UK “staycation” trend
The consultation discussions are occurring during a strong staycation trend in the UK. The UK staycation sector is estimated to experience a growth from USD 32.8 million in 2025 to 59 million in 2035. This growth creates opportunities for agents building UK tourism. Understanding the new framework that governs the sale of packages could help agents navigate the travel market in a period of strong growth.
Legislation to implement these reforms is anticipated by June 2026, under the provisions of the Retained EU Law (Revocation and Reform) Act 2023 as result of the Brexit decision.
Be prepared to review and amend your booking terms and conditions and consider if you need to change the way you sell your products and trips.
Author: Alexandrina Solomon
