fairness and inclusion for all travellers, not take the industry a step backwards when there is already so much more that needs to be done, for example on accessible air travel. As a starting point, any changes made to the 2018 Regulations must not introduce additional layers of complexity. There is already a lack of understanding as to some aspects of the 2018 Regulations amongst consumers, and any amendments must look to improve transparency and consumer trust in the industry, not take it backwards. HOW SHOULD LINKED TRAVEL ARRANGEMENTS (LTAS) BE REGULATED? LTAs are formed when a combination of two or more types of travel services is linked, but sold separately under different contracts. The current definition of an LTA is complex, making it difficult for consumers to understand when they have purchased an LTA. When provided with a definition of an LTA, over 73% of respondents said that they still found the difference between an LTA and a package holiday confusing or that they did not understand at all.4 When even further explanation was given, 46% of consumers still did not properly understand the protections. The nature and extent of consumer protections under LTAs are also complex. Consumers may mistakenly believe they are well-protected; however, unlike package holidays, LTAs only provide insolvency protections. This confusion extends to travel organisers themselves, as evidence suggests that organisers may not realise that they have created an LTA, or the obligations they owe to/ protections enjoyed by consumers under an LTA. LTAs do not benefit from the Regulation 15 protections that apply to package holidays. Regulation 15 holds the package holiday organiser responsible for any lack of conformity during the performance of a travel service forming part of the package. As things stand, consumers of LTAs are at risk of having to rely on alternative means of redress should a problem arise, notably in any claim for personal injury damages following an incident while on holiday. The UK government’s consultation notes that LTAs are confusing, rarely used and challenging to enforce. In response, the UK government is proposing to 4 Chartered Trading Standards Institute (CTSI) “Wish you were clear” poll, p.5 5 PACKAGE TRAVEL REFORM AND THE UK: PIONEERING DIVERGENCE
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