In this article, Senior Partner at Travlaw, Matt Gatenby, gives our Day#1 Thoughts on PTR Reform following the long awaiting publication of the response to the consultation on the UK Package Travel Regulations….
Package Travel Reform – The Day 1 Travlaw View
The long awaited response on Package Travel Reform dropped today, 2nd December 2025. There is a tight time table for implementation now, so this is the final outcome of what has been a somewhat drawn out process that has spanned some two years. Proposals have been made, consulted on, reflected on … and here is what we are left with. Spoiler – it’s not much! However, our Day 1 thoughts – as always, we don’t’ just tell you the news, we give you analysis!:
- Linked Travel Arrangements – Not an amazing shock here. We predicted that LTAs would disappear, and that is what has happened. It is not true to say that nobody was creating and protecting bookings via the LTA route, but the absorption of Type As into the definition of packages and removal of Type Bs is not likely to cause much of a ripple. We still harbour a slight concern that this may create an unintended gap in regulation for some types of bookings, but only time will tell. This change will not affect the majority of businesses and will remove some of the considerations for new entrants and SMEs that found the whole concept particularly confusing.
- Redress / Regulation 29 – This is a bigger change. A regular question we field here at Travlaw is whether the potential for recovery of costs etc… by Tour Operators will improve following this consultation. Organisers big and small have struggled both in the Covid-19 pandemic and outside of it with obtaining redress from suppliers who are the cause of payments to customers. Examples run the gamut of frankly all possible scenarios, but a common situation is where an airline cancels a flight, leaving a tour operator with limited or no choices and often having to pay to get package customers on a different route, or cancel and provide a full refund. Another example would be an Organiser being sued for an act or omission of a supplier hotel, leading to a personal injury – and then the hotel being non-responsive when a claim arises.
The change here “beefs up” the wording to make it clear that there is a right to redress as opposed to the “right to seek”, which is nuanced but notable. Establishing a 14 day period for refunds from suppliers to Organisers is, on paper, huge – hard to overstate that. This creates a double right to recovery, a) a refund to the package Organiser within 14 days, whilst b) increasing up the right to make any other claim against the supplier at a later date in addition to any pure refund.
However, the importance of well drafted supplier contracts increases as a result. In basic terms this a real result for Organisers, many of whom have long lamented the lack of “teeth” in the Regulations.
And that is, as they say, that. It leaves a number of proposed changes on the proverbial cutting room floor. Here are our quick takes on what they were and what it means:
- Domestic exemption – This was always an odd suggestion, with large areas of support but also large areas of concern around crating a multi-tiered playing field. The suggestion in the Response is that it is something that the Government may come back to in time.
- Changes to Insolvency protection – Slightly more surprising that this was completely dropped as continuing the development of this area was widely acknowledged as sensible. Our take on this is that the current system fundamentally works. Again, there is a suggestion that change may yet happen, but just not under this consultation. It will, however, be interesting to see if the same thinking is applied to the ongoing ATOL consultation.
- Territorial restrictions on insurance cover – Another element that clearly saw a lot of positive comments in terms of the possibility for sensible change, particularly around widening the market for providers for financial protection. However, this one also seems to have been deemed “fine as it is”, so no changes needed. Whether overseas insurance providers will want to go through authorisation by the Financial Conduct Authority will now determine whether the market will grow.
- Changes to the definition of Other Tourist Services – Fascinating, academic arguments a-plenty on this one, most of which carried weight. As such, the decision was not just keep the status quo. Our view is that this is probably a sensible approach – in practical reality this is not a point that becomes critical that often, albeit it can be important when it does.
Summary
Overall, the Department for Business & Trade have clearly had concerns that more changes might cause more confusion and overall minimise the stated aims of supporting business growth and maintaining consumer protections. The promise of potential changes in years to come will depend, in our view, solely on ministerial desire to do so, which may be a vain hope.
Last word for those of you that enjoy the mechanics of how all this works – the changes can be made by the Government under the EU law (Revocation and Reform) Act 2023, albeit only if done by June 2026, which at this stage does not seem to be an issue. No other form of enactment is needed.
The full document from the Department for Business & Trade can be found here.
For more thoughts and analysis, see www.Travlaw.co.uk or reach out to Advice@Travlaw.co.uk.
