These Regulations amend the Package Travel and Linked Travel Arrangements Regulations 2018 to abolish the legal category of 'Linked Travel Arrangements' and expand the definition of 'package' to include services facilitated by a single trader during a single contact.
The instrument mandates that third-party service providers must refund travel organisers or retailers within 14 days of a cancellation or non-performance.
These changes apply to all package travel contracts and related travel services entered into across the United Kingdom on or after 6 April 2027.
Arguments For
The legislation states that travel organisers and retailers require a statutory right to refunds from third-party service providers within 14 days when services are cancelled or not performed.
The document indicates that certain travel services formerly classified as Linked Travel Arrangements (LTAs) will now fall under the definition of a 'package' if facilitated by a single trader during one visit or contact.
Proponents argue via the explanatory note that the changes clarify the rights and obligations of organisers by preventing them from absolving themselves of responsibility through declarations of acting merely as intermediaries.
The instrument invokes powers under the Retained EU Law (Revocation and Reform) Act 2023 to simplify and amend existing consumer protection frameworks.
Arguments Against
Travel service providers may face increased administrative and financial pressure due to the new 14-day mandatory refund window for payments made by organisers.
Legal scholars might note that the abolition of the 'Linked Travel Arrangement' category could reduce specific insolvency protections for consumers who book services that no longer meet the revised 'package' definition.
Industry bodies may express concern about the transition period, as the new rules apply to any contract entered into on or after 6 April 2027, requiring rapid updates to booking systems and terms.
Stakeholders might question the lack of a full impact assessment, given the removal of five schedules of information requirements and the reclassification of various travel business models.
Citation, commencement and extent
- -(1) These Regulations may be cited as the Package Travel and Linked Travel Arrangements (Amendment) Regulations 2026 and come into force on 6th April 2027 (the 'commencement date').
- (2) These Regulations extend to the United Kingdom.
- (3) The amendments made by regulation 2 apply to the Package Travel and Linked Travel Arrangements Regulations 2018 ('the 2018 Regulations').
- (4) The amendments made by regulation 2 and 3 do not have effect in relation to-
- (a) any package travel contract as defined in regulation 2(1) of the 2018 Regulations; or
- (b) any linked travel arrangement as defined in regulation 2(3) of the 2018 Regulations entered into before the commencement date.
This section establishes the official name of the regulations and sets the start date for the new rules as 6 April 2027.
It confirms the legislation applies throughout England, Scotland, Wales, and Northern Ireland.
It also clarifies that these changes do not apply retroactively to travel contracts or arrangements made before the commencement date.
Amendment of the Package Travel and Linked Travel Arrangements Regulations 2018
- -(1) The 2018 Regulations are amended as follows.
- (2) In regulation 2 (interpretation)-
- (a) in paragraph (1) in the definition of 'trader' omit ', trader facilitating a linked travel arrangement';
- (b) omit paragraphs (3) and (4);
- (c) in paragraph (5), in the definition of 'package'-
- (i) after paragraph (a) omit 'or';
- (ii) after paragraph (b) insert-
'; or
- (c) those services are provided under separate contracts with individual service providers if a single trader has facilitated, on the occasion of 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.'.
(3) In regulation 3 (application)-
- (a) in paragraph (1), omit sub-paragraph (b) and the ', and' before it;
- (b) in paragraph (2)-
- (i) in sub-paragraph (a) omit 'and linked travel arrangements';
- (ii) in sub-paragraph (b) omit ', and linked travel arrangements facilitated,';
- (iii) in sub-paragraph (c) omit 'and linked travel arrangements'.
(4) Omit regulation 26 (insolvency protection and information requirements for linked travel arrangements).
(5) In regulation 28 (liability for booking errors) in paragraph (2) omit paragraph (b) and the 'and' before it.
This section removes references to 'linked travel arrangements' and their associated insolvency protections from existing law.
It expands the legal definition of a 'package' to include travel services booked via separate contracts if they were facilitated by one trader during a single interaction.
These changes effectively reclassify many former arrangement types into the stricter 'package' regulatory framework.
(6) Omit regulation 29 (right of redress) and insert-
' Right to a refund
29A. -(1) Where-
- (a) a third party has agreed to provide a travel service;
- (b) the travel service forms part of a package provided by the organiser or, in a case under regulation 27, the retailer to a traveller; and
- (c) the third party fails to perform or cancels the performance of the whole or part of the travel service,
the third party must refund to the organiser or, in a case under regulation 27, the retailer any payments which the organiser or retailer has made to the third party within 14 days.
(2) The 14 days referred to in paragraph (1) commence on the earlier of the day-
- (a) following the day on which the third party cancels the performance of the whole or part of the travel service; or
- (b) on which the relevant travel service was due to be performed.
(3) The third party may deduct from any refund that they are required to make under paragraph (1) any refund of the price of the travel service described in paragraph (1) that the third party has paid to the traveller, in respect of the non-performance or cancellation, under the passenger rights legislation or the international conventions as defined in regulation 16(10).
Right of redress
29B. Where an organiser or, in a case under regulation 27, a retailer-
- (a) pays compensation,
- (b) grants a price reduction, or
- (c) meets other obligations,
the organiser or retailer has a right of redress, including damages, from any third party which contributed to the event triggering the obligation to pay compensation, provide a price reduction or meet other obligations under these Regulations and may bring a claim in civil proceedings to enforce that right.'.
This section creates a new statutory right for travel organisers and retailers to receive refunds from third-party service providers if a service is cancelled or not performed.
The third party must pay the refund within 14 days of the cancellation or the date the service was due.
It also establishes a clear right for organisers to seek legal redress and damages from third parties whose actions lead to the organiser having to compensate a traveller.
(7) For regulation 30(1) (rights and obligations under these Regulations) substitute-
' 30. -(1) A declaration by an organiser of a package that-
- (a) the organiser is acting exclusively as a travel service provider, as an intermediary or in any other capacity, or
- (b) a package does not constitute a package
does not absolve that organiser from the obligations imposed upon them under these Regulations.'.
- (8) In regulation 31(1) (enforcement authority) for ', 25 and 26' substitute 'and 25'.
- (9) In regulation 32(1) (due diligence defence) for ', 25 or 26(10)' substitute 'or 25'.
(10) In regulation 33(1) (liability of persons other than principal offender) for ', 25 or 26(10)' substitute 'or 25'.
(11) In regulation 34(1) (prosecution time limit) for ', 25 or 26(10)' substitute 'or 25'.
- (12) In regulation 35 (saving for civil consequences) for ', 25 or 26(10)' substitute 'or 25'.
(13) Omit the following Schedules-
- (a) Schedule 6 (Information to be provided to the traveller, where the trader facilitates an online linked travel arrangement within the meaning of regulation 2(3)(a) and the trader is a carrier selling a return ticket).
- (b) Schedule 7 (Information to be provided to the traveller, where the trader facilitates an online linked travel arrangements within the meaning of regulation 2(3)(a) and the trader is not a carrier selling a return ticket).
- (c) Schedule 8 (Information to be provided to the traveller, where the linked travel arrangement is an arrangement within the meaning of regulation 2(3)(a) and the contract is concluded in the simultaneous physical presence of the trader (other than a carrier selling a return ticket) and the traveller).
- (d) Schedule 9 (Information to be provided to the traveller, where the trader facilitates an online linked travel arrangement within the meaning of regulation 2(3)(b) and the trader is a carrier selling a return ticket).
- (e) Schedule 10 (Information to be provided to the traveller, where the trader facilitates an online linked travel arrangement within the meaning of regulation 2(3)(b) and the trader is not a carrier selling a return ticket).
This section prevents travel organisers from avoiding their legal responsibilities by claiming they are merely intermediaries or that a booking is not a 'package'.
It also updates enforcement and liability rules to reflect the removal of linked travel arrangements.
Five schedules containing specific information requirements for those arrangements are repealed.
Consequential amendments
- In consequence of the amendments made by regulation 2-
- (a) in the Government of Wales Act 2006( 4 ), in Schedule 7A, in Part 2, in paragraph 74(c), after "linked travel arrangements within the meaning of the Package Travel and Linked Travel Arrangements Regulations 2018 (S.I. 2018/634)" insert 'as they stood on 5th April 2027', and
- (b) in the Civil Aviation (Air Travel Organisers' Licensing) Regulations 2012( 5 ) in regulation 4, in the definition of 'trader' omit ', trader facilitating a linked travel arrangement'.
This section makes technical adjustments to other laws to ensure consistency with the new regulations.
It modifies the Government of Wales Act 2006 to clarify which version of the travel regulations applies and removes references to linked travel arrangements from the Civil Aviation (Air Travel Organisers' Licensing) Regulations 2012.
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