The Civil Aviation Authority (CAA) has confirmed an important change to the ATOL advertising rules that will affect how travel businesses promote ATOL-protected holidays and flights, particularly across digital marketing, social media and influencer channels. The revised rules take effect from 1 April 2026 and are intended to reflect modern advertising practices while maintaining clear consumer protection.
In summary, the CAA is updating and clarifying the rules on when ATOL protection needs to be referenced in advertising. Historically, these requirements were focused on broadcast advertising such as television and radio. From 1 April 2026, the approach will be broader in scope, but more flexible in how it is applied.
At a high level, the new position is as follows.
Scope of Media
The rule will apply across all forms of advertising, including digital ads, social media and influencer marketing. In the case of influencers, it will apply only where the ATOL holder has a contract with the influencer and editorial control over the content. The rule will not apply to paid search advertising, including AI‑generated search results.
When the rule is triggered
ATOL protection will only need to be referenced where an advert refers to an ATOL product. This includes advertising that shows a flight‑inclusive package price or otherwise clearly promotes a flight‑inclusive package. Pure brand advertising, destination‑led content, or adverts for standalone services such as accommodation‑only will generally be out of scope. Where a business sells only ATOL products, it may still choose to reference ATOL protection in brand advertising, but this will not be mandatory.
Geographic focus
The requirement applies only to advertising aimed at UK consumers.
How ATOL protection is referenced
The CAA will no longer prescribe exactly what must be said or shown. Instead, ATOL holders must include a reference to ATOL protection in a way that is proportionate to the format, space and style of the advert. Depending on the medium, this could include wording, use of the ATOL logo, audio references, hashtags or pinned comments.
Further guidance
The CAA has published practical guidance, including examples and a decision‑tree to help businesses assess whether a particular advert is in scope and how to comply. This guidance currently appears in Appendix A to the CAA’s decision document and is available on the CAA’s website, which will ultimately form a separate guidance note.
If you would like to discuss how these changes may affect your current or planned marketing activity, the Fox Williams travel team would be happy to help.
