DBT also considers it too complex to draft legislation in a way that captures the various ways in which the travel element of a domestic only package is provided, extending not just to transport at the start and end of a trip, but also to travel/ transport during the package holiday. The proposal to remove some UK-only domestic package holidays from the protections offered by the package travel regulations notably gave rise to the following concerns: • Research published in November 2024 by the UK DBT and conducted on its behalf by Verian demonstrated that consumers are prepared to pay a premium for package holidays due to the protections provided by the package travel regulations4, including an additional premium of £106 for a domestic package holiday. Removing domestic package holidays from the scope of these protections would have disadvantaged consumers, reduced choice, increased costs and removed insolvency protections and protections that ensure the proper performance of travel services. • The creation of two separate regimes for domestic and international travel would have resulted in increased confusion for consumers. UK-only package holidays can be equally and sometimes more expensive than international travel, with similar issues arising if things go wrong. There is a strong argument, therefore, that they should not be subject to different regulations or responsibilities on the part of the package organiser. To further support its position following the consultation, the UK government cites research from Which? that consumers believe the same problems can arise in the UK as abroad, reiterating that a package organiser’s responsibility to the consumer should not vary depending on the holiday location5. • Removing some UK-only domestic package holidays would have disproportionately affected certain sections of society, including those with lower incomes, senior citizens and those with disabilities who may need or want to avoid international travel6. Legislative reform should ensure fairness and inclusion for all travellers, not take the industry a step backwards 4 https://assets.publishing.service.gov.uk/media/67e69c1337baea91c58c9ffa/Package_Travel_-_Updating_ the_Framework_-_Consumer_Research_Report.pdf 5 “It’s all so confusing, why is nothing simple”: Consumer difficulty navigating the complicated landscape of holiday protections - Which? https://www.which.co.uk/policy-and-insight/article/consumer-difficultynavigating-the-complicated-landscape-of-holiday-protections-anXu65o9DZ1P 6 Research conducted by the UK’s DFT in 2024 showed that people with some health problems or disabilities are more likely to choose to holiday in the UK, either through a package holiday or an LTA, but are less likely to travel overall: Research into the Package Travel and Linked Travel Arrangements Regulations 2018 (PTRs) – a discrete choice experiment, Table 9, p.25 6 CHRISTOPHER DEACON
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