either leave LTAs as they are or retain the LTA category but seek to limit how an LTA can be created. Simplifying the system may include replacing the two LTA types currently in existence with a single definition or introducing additional requirements that might clarify the circumstances under which a trader has facilitated the formation of an LTA. With the EU also contemplating reforms to LTAs, there is broad consensus that the definition must be simplified. The EU proposes that the definition of what constitutes a ‘package’ is extended to include the purchase of at least two services from separate traders if the purchases are made through a linked online booking process. The definition of LTAs would be narrowed so that it only applies to any combination of different services that do not meet the definition of a package where: “following the payment of a first travel service to a trader – the consumer would, at this trader’s invitation, purchase an additional type of travel service from a third trader at the latest 24 hours following the confirmation of the first contract.” The UK’s DFT notes that there are two types of LTA under the current 2018 Regulations: • type A LTAs: the selection and payment of 2 or more services for the same trip, under separate contracts with individual providers, upon a single contact with a point of sale • type B LTAs: the separate selection and payment of 2 or more travel services for the same trip through targeted linked booking processes within 24 hours without transferring the traveller’s payment details The UK government has floated the possibility of removing type B LTAs altogether and amending the definition of type A LTAs to require bookings to be made by selecting two or more services from a trader’s website (or another website of that trader) within a 24-hour period, on the basis “this could better suit online purchasing and addresses confusion reported to us around establishing a single visit to a point of sale.”5 If the UK pursues this proposal then there would be clear divergence with the EU position where type A LTAs become package holidays and type B LTAs are modified to expressly require cross-selling of the consumer from trader X to trader Y within a 24-hour period. Whichever way the UK lands on the scope of LTAs, in view of the complexity of the definitions and the confusion this causes to consumers, there is an argument 5 See UK government’s consultation document: https://www.gov.uk/government/consultations/packagetravel-legislation-consultation-on-proposed-amendments/package-travel-updating-the-framework-2025 6 CHRISTOPHER DEACON
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