The travel industry is highly regulated, with a body of travel-specific regulation and, in some markets, a requirement to register or to obtain a licence to do business.

Travel companies also need to be concerned about other areas of regulation, including laws relating to data protection, advertising and marketing and financial services.

The volume of regulation can seem overwhelming and we understand the importance of providing commercial and practical advice. Our clients are not in the business of regulatory compliance, they are in the business of selling travel services. It is our role to help guide you through the regulations in a way which is sensible, user-friendly and pragmatic.

We help our clients to grow, by launching new travel products and by entering new markets. We also help our clients to acquire or sell businesses, as well as resolving regulatory and commercial disputes which may arise.

Travel expertise

Travel experience

  • Secured a landmark legal victory for On the Beach against Ryanair in a first-of-its-kind case, setting an important legal precedent in relation to the rights of package holiday organisers like On the Beach to seek refunds from airlines.  The ruling has clarified the law and is expected to pave the way for similar claims in the future.

  • Acted for various travel companies in dispute with the CAA, including on ATOL terms and consumer enforcement proceedings.

  • Advised private equity investors on the regulatory and legal risks involved in the acquisition of travel clients, together with bespoke negotiation of ring-fencing arrangements with the CAA.

  • Advised various travel companies on their Brexit planning, which will allow them to continue to sell travel services between the UK and EU after Brexit.

  • Advised several travel companies in the wake of the failure of Thomas Cook Airlines and Monarch Airlines, including on their customer-facing obligations and in the successful recovery of substantial sums through insurance and chargeback claims.

  • Acted for travel companies on litigation arising from screen scraping.

  • Advised a leading tour operator group on various acquisitions, disposals and joint ventures in the adventure and skiing sectors.

  • Advised leading travel companies on the commercial and regulatory aspects of their international expansion programmes, including non-EU companies launching in the EU, and UK companies entering EU and ROW markets.

  • Advised various well-known retail brands on the commercial and regulatory aspects of launching a new travel business, including the negotiation of commercial agreements with suppliers, website compliance, ATOL applications and preparing compliant booking conditions.

  • Advised on ATOL, IATA and ABTA requirements, including new applications, change of control formalities and insolvency protection requirements.

  • Advised travel companies on the various issues arising from Covid-19, including the payment of refunds and refund credit notes, chargebacks, merchant acquirer security requirements and enforcing refund claims against suppliers.

  • Advised Hotelplan UK on the sale of ski holiday business Flexiski to Love Ski Ltd.

Travel FAQs

Yes. Companies which sell flights in the UK, whether on their own or as part of a package holiday, must obtain a licence from the Civil Aviation Authority known as an Air Travel Organiser’s Licence (“ATOL”).

Yes, aside from those which require an ATOL (see above), travel companies selling combinations of travel services (such as a package holiday) must comply with the Package Travel and Linked Travel Arrangements Regulations 2018. These set out a comprehensive scheme of consumer protection in the UK, which lays down requirements as to the sale of travel services, pre-departure and post-departure rights for the customer. These regulations also require the customer to be given the benefit of insolvency protection for certain sales so that the customer will be refunded and/or repatriated if the travel company becomes insolvent.

Yes. Travel companies have to arrange insolvency protection in the UK if they organise and sell package holidays, linked travel arrangements or flight-only, although there are many exemptions available for flight-only. The regime is split into two parts. The ATOL regime provides insolvency protection for the sale of flight-inclusive packages and flight-only, whereas the insolvency protection for non-flight packages and linked travel arrangements is to be provided by a financial bond, financial failure insurance or through operation of a trust account.

Yes, UK travel companies going through a change of control will need to ensure that they comply with the applicable rules for the CAA (in relation to ATOL), IATA and ABTA.

Currently, UK-based travel companies may use their UK insolvency protection arrangements to sell to customers throughout the EEA (and vice versa). Unless a new agreement is reached between the UK and the EU, this scheme will end at 11pm on 31 December 2020. UK travel companies will then have to make new arrangements to sell to the EEA, and EEA-based travel companies will similarly have to make new arrangements to sell into the UK.

"For me, the pre-eminent firm of travel lawyers. They're totally professional and the best at what they do."

Chambers UK 2024

"The team has a specialist knowledge of the regulatory framework for the travel sector combined with a deep knowledge of the travel industry. They are highly attuned to the needs of their clients and strong in achieving successful outcomes to difficult problems."

Legal 500 2024

"Fox Williams have great insight into the travel industry and can be relied upon to deliver advice that suits the commercial needs of the business."

Chambers UK 2024



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