Understand the key changes introduced by the Package Travel and Linked Travel Arrangements (Amendment) Regulations 2026 and what travel businesses should do to prepare ahead of April 2027.
The new Package Travel and Linked Travel Arrangements (Amendment) Regulations 2026 have arrived, amending the 2018 Regulations. The UK Government confirmed their aims when reforming this legislation were to protect consumers, maintain consumer trust in the travel sector, support growth in the industry, and strike the right balance between consumer protection and business burden. This represents a clear policy choice by the Government to extend consumer protection into areas that have previously sat outside the regime, and the UK is set to have one of the most comprehensive travel regulatory regimes in the world.
The reforms will not apply retrospectively, and so will only apply to holiday contracts entered on or after 6th April 2027. The main amendments are as follows;
Linked Travel Arrangements (‘LTA’)
Under the previous regime, Linked Travel Arrangements (LTAs) were travel combinations that have looser commercial connections than that of a package.
Previously, in an LTA type A situation, a trader facilitated the separate selection of and separate payment for bookings for the same trip through a single point of sale on a single visit or contact by the traveller with that point of sale. LTA type A has now been reclassified in the reformed regulations, and is now included within the package definition as travel services provided to a traveller under separate contracts with individual service providers, if a single trader has enabled, on a single visit to, or contact with, the trader’s point of sale, the separate selection of and separate payment for each of the travel services by the traveller.
LTA type B could be explained previously as a trader facilitating, in a targeted manner, the procurement of one or more additional service(s) from another trader where a contract with such other trader is concluded at the latest 24 hours after the confirmation of the booking of the first travel service. The reforms have removed the LTA type B category of linked travel arrangements altogether, which therefore removes other linked travel arrangements from protection. For example, a package will now be formed where a customer books one travel service and then another, in separate transactions during a single point of sale (e.g. a website, app, retail store). This is a huge extension which will result in the regulations applying to many businesses who previously were not deemed package providers. Practical examples of the regulations now applying to previously excluded businesses include;
Airlines which allow customers to book other services such as accommodation or car hire will now be classed as providing a package when a customer books 2 or more services within a single visit
Booking platforms with different tabs where separate services can be booked on a stand-alone basis will be classed as providing a package when a customer books 2 or more services within a single visit
Hotels could even be deemed package providers when selling local experiences, in addition to accommodation, when a customer books 2 or more services within a single visit
For many, this represents a fundamental shift in regulatory exposure, moving quickly from no regulation to full regulation. For businesses currently operating sales models which will be caught by the expanded package definition, early assessment is essential, and it is wise to review your booking terms and conditions as well as supplier contracts to ensure these are updated in time for any sales from 6th April 2027 onwards.
These businesses will also need to ensure that customers are provided with full package rights, including pre-contractual information and organiser liability. Changes will be required to booking journeys, operations, supplier and customer contracts, insurance and insolvency protection will need to be obtained.
Refunds from suppliers
Reforms also address a longstanding frustration for package organisers: recovering money from suppliers when things go wrong. Additional rights to refund and seek redress have been added, which are enforceable by organisers against suppliers.
Regulation 29 has been amended, setting out a 14 day supplier refund deadline under Regulation 29A. In the previous regulations, there was no statutory deadline for a supplier to refund an organiser after cancelling or failing to perform a travel service. Going forward, suppliers will be required to refund organisers within 14 days of cancellation or the date the travel service was due to be performed, whichever comes first.
Regulation 29B sets out the organiser’s right to claim damages and other redress from any supplier which contributed to the organiser’s liability to the traveller, and clarity is given regarding the right to redress versus the right to seek redress. This is good news for package holiday organisers. Whilst fairly recent case law confirmed that package holiday organisers can recover losses from suppliers in certain circumstances, the new rules place that right on a clear statutory footing and introduce a defined timetable within which suppliers of all types must refund package holiday organisers.
Again, businesses ought to review their contracts ahead of 6th April 2027, as the above updated emphasise the importance of well drafted supplier contracts.
