Package travel reform and the UK by Christopher Deacon

Package travel reform and the UK: pioneering divergence in a closely aligned market or following in the shadow of the EU? Christopher Deacon1 I. Introduction. – II. UK proposals for reform. – III. EU proposals for reform. – IV. An overarching concern. – V. Should the PTRs continue to apply to UK-only package holidays? – VI. How should Linked Travel Arrangements (LTAs) be regulated? – VII. What should the government do about insolvency protection and insurance for holiday bookings? – VIII. How should ‘other tourist services’ be dealt with when forming part of a package? – IX. An opportunity for the UK to evolve without straying too far from the EU’s shadow. This article examines the United Kingdom’s proposed reforms to its package travel regime following implementation of Directive (EU) 2015/2302 via the Package Travel and Linked Travel Arrangements Regulations 2018, now assimilated EU law. Against the backdrop of parallel but distinct reform initiatives in the EU, it analyses how the UK government’s 2025 consultation and subsequent response signal both continuity and potential divergence from the EU framework, particularly regarding the scope of package travel legislation and the treatment of Linked Travel Arrangements (LTAs). Key UK proposals include abolishing LTAs by absorbing Type A LTAs into the definition of a package, removing Type B LTAs, retaining protections for domesticonly packages, and leaving the definition of “other tourist services” unchanged, while seeking to improve thirdparty redress mechanisms and reconsider aspects of insolvency protection and insurance requirements. The article contrasts these developments with the EU’s crisisdriven proposals, which focus on refunds, voluntary vouchers, insolvency protection and a narrowed but retained concept of LTAs. It argues that the UK’s move to subsume LTAs into the package definition constitutes a relatively bold simplification that may enhance consumer clarity and extend Regulation 15 lackofconformity protections, including for serious personal injury, to a wider range of holidays, while raising questions about regulatory alignment for operators active in both markets and the future trajectory of UK–EU convergence in package travel law. 1 Partner, Stewarts.

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