proposes an update to third-party redress provisions with the aim of helping travel organisers to recover costs paid to a consumer from the supplier of services more effectively. The UK has abandoned plans to exclude domestic-only package holidays from the protections provided by the regulations and, along with provisions relating to insolvency protection and insurance requirements, will leave the definition of ‘other tourist services’ unchanged. III. EU PROPOSALS FOR REFORM At a similar time to the UK’s 2023 call for evidence, on 29 November 2023 the European Commission proposed various amendments to the package travel directive. The EU’s proposals are said to have a closer link to the Covid-19 pandemic and the way in which the industry responds to consumer needs in a time of crisis, with the European Commission identifying the following areas of focus: • rules on voluntary vouchers and clarifications or additional rules on refunds where packages are cancelled due to unavoidable and extraordinary circumstances, including with regard to insolvency protection • guidance or additional provisions on the national insolvency protection systems, plus the potential creation of an EU insolvency back-up fund • the potential creation of a special fund/special funds at national or Union level to cover refunds in times of crisis without requiring the insolvency of the relevant package organiser • a possible limitation of pre-payments to be made by package travellers, reducing the need for insolvency protection, and avoiding/limiting the risk for travellers of having to wait for refunds, in particular, in times of crisis • recommendations or rules on refunds from providers of travel services (e.g. airlines) to package organisers • possible alternatives to the current rules on linked travel arrangements if similar guarantees can be provided in a simpler way, e.g., through certain rules on intermediaries and insolvency protection requirements for certain service providers. The EU’s proposed reforms were approved by the European Parliament during a first reading in September 2025. 4 CHRISTOPHER DEACON
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