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, it does not propose to go as far as removing the concept of a LTA entirely. The definition of LTAs in the EU 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” thereby retaining a form of Type B LTA in the EU. In view of the complexity of the definitions and the confusion this causes to consumers, the UK’s proposed approach to reform of LTAs is to be welcomed, providing a clearer and simpler regime for consumer protection and the way in which the travel industry bundles and sells package holidays. This might be deemed a bold move, but it is a straightforward one; by legislating to incorporate LTAs into the definition of a package, the UK is taking a big step in eliminating confusion for both consumers and providers. The proposal would also extend the package travel protections for lack of conformity under Regulation 15, demonstrating the UK’s confidence to diverge and lead the way in providing a high degree of consumer protection for both liability and insolvency issues to a wider range of holidays and travel bookings. For the EU, where the concept of LTAs looks likely to remain, there is an argument for imposing a clear obligation on travel providers to ensure consumers are aware of when an LTA has been created and what protections are offered. VII. WHAT SHOULD THE GOVERNMENT DO ABOUT INSOLVENCY PROTECTION AND INSURANCE FOR HOLIDAY BOOKINGS? Under the current regulations, organisers are required to arrange insolvency protection for consumers through bonds, insurance or setting up a trust account (with insurance in place for repatriation). The UK government consulted on the possibility of making the provision of insolvency protection more flexible for travel organisers by allowing them to combine arrangements, with a mix of trust and insurance or trust and bonding. It had also considered replacing the territorial restrictions on insurance cover for organisers, as policies must 9 PACKAGE TRAVEL REFORM AND THE UK
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