Keywords: Package travel; Linked Travel Arrangements (LTAs); UK package travel reform; Package Travel and Linked Travel Arrangements Regulations 2018; Directive (EU) 2015/2302; consumer protection; lack of conformity; serious personal injury; insolvency protection; travel organisers; thirdparty redress; vouchers and refunds; unavoidable and extraordinary circumstances; UK–EU regulatory divergence; Department for Business and Trade (DBT) I. INTRODUCTION As the package travel industry recovered from the Covid-19 pandemic, legislators in both the UK and EU turned their minds to package travel reform following the implementation of Directive (EU) 2015/2302, which came into force in July 2018 and was implemented in the UK via the Package Travel and Linked Travel Arrangements Regulations 2018 (“the 2018 Regulations”). While the EU’s emphasis was on ensuring the industry could respond in future times of crisis, notably regarding consumer ability to receive timely and effective refunds of monies paid where travel services could not proceed, the UK’s proposals for reform extend to the fundamental scope of package travel legislation. The UK’s 2018 Regulations are assimilated EU law, being derived from the EU’s second directive on package travel. Therefore, while there is an overlap in the intentions of each legislator, the UK can now make its own journey when reforming the UK’s position on package travel regulation. Following a consultation during the summer of 2025, on 02 December the UK government announced plans to amend the UK’s package travel legislation in a way that would “retain the key safeguards of consumer protections that underpin the regulations while making the most of the opportunity to reform the framework, so that it supports the sector’s growth and provides greater choice for consumers.”2 Key proposals include removing Linked Travel Arrangements (LTAs) and absorbing them into the definition of a package holiday. While the UK government has bold legislative intent to reform key aspects of the 2018 Regulations, it remains to be seen how far the final iteration of the updated regulations will go. To what extent might we ultimately see pioneering divergence given the reality of the close alignment in the UK and EU’s travel 2 Department for Business & Trade, UK Government response to ‘Package travel – updated the framework 2025’ consultation, 02 December 2025: https://www.gov.uk/government/consultations/package-travel-legislationconsultation-on-proposed-amendments/outcome/government-response-to-package-travel-updating-theframework-2025-consultation 2 CHRISTOPHER DEACON
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