Consultation on reforming Package Travel Regulations (PTRs) launched

In April 2025, the Department for Business & Trade (DBT) launched another consultation on reforming the PTRs (more information from the DBT here). This follows the initial consultation published in September 2023. The latest consultation seeks targeted feedback on a number of key proposals that remain under active consideration by the DBT. Details of what is included in these proposals are outlined in this article.

What is included in the PTR reform proposals? 

• Supplier refunds: the DBT is still considering ways in which to make it easier for package organisers to recover refunds from third party suppliers, including whether to impose a 14-day deadline on suppliers in which to make refunds. This is an area where package organisers could really benefit from a better framework, and mandated timescales for refunds would help. However, one of the key issues here (as seen during the pandemic) is the overlapping obligations between airlines and package organisers and this isn’t something which has been explicitly referenced by the DBT in the proposal.

• Domestic packages: removing domestic packages from the scope of the PTRs, unless they include transport of passengers.

• Linked Travel Arrangements (LTA): simplifying the definition of an LTA as follows:
  • Removing LTA Type B’s (the separate selection and payment of two or more travel services for the same trip through targeted linked booking processes within 24 hours without transferring the traveller’s payment details) from the definition; and
  • Amending LTA Type A’s to require bookings to be made by selecting two or more services from a trader’s website (or another website of that trader) within a 24-hour period.

• Other tourist services: re-defining when a combination of an “other tourist service” and another element (e.g. transport or accommodation) creates a package holiday or a linked travel arrangement. Currently, the other tourist service must either: (i) be an essential feature of the trip; or alternatively (ii) amount to a significant proportion of the total value of the trip (typically considered to be 25% or more). The DBT is considering abolishing (ii) so that the only test is whether the other tourist service is an essential feature and is asking stakeholders whether this would provide more clarity.

• Insolvency protection: the DBT is considering whether to add more flexibility to the insolvency protection mechanisms for non-flight packages by allowing a combination of a trust account and a bond to be provided (in addition to the current option of a bond plus insurance). DBT is also asking for feedback on other ways in which the cost of securing insolvency protection could be reduced for travel companies without reducing the protections available to consumers. In our opinion, this is an opportunity for travel businesses to suggest ways in which some allowance/discount ought to be made for credit card bookings (on the basis that the customer has a right to a refund from the card issuer).

• Location of insurance provider: currently, the providers of financial failure insurance must be authorised in the UK, Channel Islands or Isle of Man. The DBT is considering whether to relax the territorial restriction in order to allow more insurers to come into the market.

Areas of reform that will not be pursued

Areas of reform which the DBT has decided not to pursue include:

• Extenuating circumstances: the DBT was considering whether the strict obligations set out in the PTRs (such as the 14-day deadline for refunds) should be relaxed in extenuating circumstances, however, has decided not to pursue this.
• Minimum cost threshold: the DBT was considering whether to set a financial threshold for the value of a package holiday before the PTRs apply. However, feedback received for this proposal was largely negative, and the DBT has decided not to pursue this proposal.
• Business travel exemption: the DBT was considering extending the scope of the PTR exemption for business travel so that the exemption applies even without there being a business travel agreement in place (as is currently required). The DBT is not pursuing this proposal on the basis that it is not an area of concern for the travel industry.

The deadline for responses is 30 June 2025.

Travel regulation lawyers

To discuss the consultation or any of the aspects covered in this article, please get in touch with a lawyer from our travel team or your usual Fox Williams contact.

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