Consultation outcome

Government response to 'Package travel – updating the framework 2025' consultation

Updated 2 December 2025

Executive summary

Going on holiday is a much loved and much anticipated part of the year. It is also a significant expense for consumers. Therefore, it is imperative that the legal framework provides them with appropriate protections, so they can book and enjoy package holidays with confidence. That confidence helps UK businesses to succeed and grow, but that also requires a proportionate and simple regulatory framework.

The Package Travel and Linked Travel Arrangements Regulations 2018 (‘regulations’) set out the current framework for the travel sector and build on the UK’s long history of protecting consumers. They establish a series of requirements for organisers of package holidays which aim to provide protections for travellers. This includes providing sufficient security for repatriations and refunds in the rare event of their own insolvency. The Air Travel Organisers’ Licensing (ATOL) scheme fulfils this obligation for package holidays that include a flight. The UK Civil Aviation Authority (CAA) manages the ATOL scheme on behalf of the Secretary of State for Transport.

The regulations are assimilated EU law and were made in 2018. The regulations stipulate that they must be reviewed every 5 years. The government’s previous call for evidence ‘Package travel legislation: updating the framework’ (from 18 September until 13 December 2023), targeted stakeholder engagement. Externally commissioned consumer research highlighted several areas within the regulations that could benefit from revision and reform. Following this, a consultation to test specific areas for improvement ran between 7 April 2025 until 30 June 2025.

The consultation set out how the government wishes to 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.

As set out in the consultation, the government’s policy objectives for the regulations are to:

• give consumers appropriate protections when buying package holidays, which are both a significant expense and an important leisure activity for people in the UK
• support growth in the travel sector and encourage innovation and collaboration by ensuring that regulation is clear and works well for businesses and consumers
• maintain trust in the travel sector, so consumers have confidence in booking package holidays
• enable some flexibility for business in deciding how to secure consumer protections

Our consultation set out a series of potential proposals to improve the operation of the regulations. These included:

• removing domestic packages from the scope of the regulations, unless they include transport of passengers
• revisiting the regulatory position on linked travel arrangements (LTAs) to either simplify, remove, or extend them
• exploring how to make the provision of insolvency protections more flexible for business
• relaxing the territorial restrictions on insurance cover
• refocusing how other tourist services form part of the rules

We would like to thank those that took the time to respond to the consultation. We were pleased to receive 113 responses from a wide range of interested parties. These included:

• approved bodies
• consumer groups
• airlines
• lawyers
• members of the leisure and hospitality sector
• accommodation providers
• many more

Key themes

There was a strong sentiment across stakeholders that consumers should continue to benefit from protections when purchasing package holidays. Providers of package holidays are rightly proud of their industry and what they offer. Alongside this, a number of key themes arose. These included areas both within and outside the scope of the consultation.

Domestic exemption

While the objective was broadly supported, concerns emerged about implementation challenges and potential weakening of consumer protections specifically associated with ‘packages’ (versus linked travel arrangements)

Linked travel arrangements (LTAs)

Consultation consensus was that LTAs are complex for businesses and misunderstood by consumers, who believe they offer stronger protections than they do (also echoed in the 2023 ‘Package travel regulations: legislating the framework’ call for evidence response)

Insolvency cover

Trust providers supported the proposal to allow organisers to combine trust protection with bonding (not just insurance). However, stakeholders raised concerns that increased flexibility without concurrent reforms (for example clearer trust account rules, enhanced insurance obligations, and stronger oversight) could weaken consumer protection and widen the gap between regulatory intent and industry practice – redress from third parties: despite ongoing issues of enforceability and the need for solid business-to-business contracts, the majority of respondents were in favour of changes to update Regulation 29 to:

• establish a 14-day period for refund of cancelled services
• clarify the ‘right to redress’ versus ‘right to seek redress’

Territorial restrictions on insurance cover

A general consensus that the current regulations provide the safeguards needed for both industry and consumers. While the insurance market had suffered in recent years, there were positive signs of a re-emergence of interest from insurance providers in the package travel sector.

Other tourist services (OTS)

Consultation responses on removing the ‘significant proportion’ criteria were inconclusive. While it was evidenced that smaller operators may meet the 25% threshold more often than larger ones, the current balance between ‘significant proportion’ and ‘essential feature’ was considered effective and proportionate, providing a workable benchmark without requiring legislative change.

Enforcement of the regulations

Enforcement of the regulations continues to be an issue, especially in relation to overseas third party suppliers.

Broader concerns

Throughout the call for evidence and consultation, several pertinent issues arose. These included the need to restructure liability claims and clarify the hierarchy of payment provisions amongst travel insurers, credit card providers, and travel operators. Stakeholders consistently highlighted the disproportionate compensatory obligations the regulations place on travel operators versus other parties (for example travel insurers or credit card companies), especially in relation to being the compensator of last resort. The interplay between the ATOL requirements and the regulations for providers of both flight and non-flight options remains a burden to businesses.

From our own assessment and extensive industry and stakeholder engagement, it is clear that the confidence currently felt in the package travel sector is underpinned by the protections offered by the regulations. Knowing that they will be properly looked after by their tour operator if things go wrong is a strong driving factor as to why consumers continue to choose to book package holidays. Therefore, any changes must contribute to economic growth and business opportunity and increase vibrancy and choice in the market, while simultaneously maintaining consumer confidence.

Linked travel arrangements

Having carefully considered responses, and following extensive engagement with stakeholders, the government intends to bring forward legislative changes to make the following key changes to the regulations.

Absorbing LTA Type A into the definition of a package

This would provide full package protections when consumers make a booking in circumstances similar to current Type As, effectively extending consumer rights while simplifying business compliance.

Removing LTA Type B entirely

The government plans to eliminate Type B arrangements (where a trader facilitates booking of a second service from another trader within 24 hours). The rationale is that these arrangements provide minimal consumer protection and are easily circumvented. This removal would support domestic sector growth, allowing small businesses like B&Bs to refer customers to local activity providers without triggering package regulations.

Regulation 29

The government is also proposing to modify Regulation 29, which deals with redress for third parties. The key changes include:

• establishing a 14-day period for refund of cancelled services
• clarifying that the regulations mean the ‘right to redress’ versus the ‘right to seek redress’

These changes aim to help package travel organisers recover costs from suppliers more effectively, enhancing business resilience and ensuring the costs of consumer protection are distributed more equitably.

We will also consider how to best treat other issues highlighted in the consultation responses and that were not able to be addressed through legislation.

The government will legislate to implement these reforms by June 2026 under the provisions of the retained EU law (Revocation and Reform) Act 2023.

The remainder of this document is structured as follows:

• Part 1 provides information about how the consultation was conducted, the number and type of respondents, and how the responses were analysed
• Part 2 summarises the responses that we received to each of the consultation questions, including quantitative and qualitative insights
• Part 3 sets out the government’s response to the consultation, outlining the measures that we intend to take forward

Part 1: conducting the consultation

The consultation ran from 7 April 2025 to 30 June 2025. There were 113 responses to the consultation. Of these, 36 were submitted over email and the rest were submitted through our online Qualtrics survey.

Note about data handling

Responses were collected through an online Qualtrics survey, and through responses submitted by email. Many email respondents did not follow the template when submitting their responses, including submitting overarching answers to many questions, or giving qualitative written answers to quantitative questions. Responses were mapped to the relevant specific question when possible, and qualitative answers were coded into a quantitative category when possible and relevant.

Where a question had a ‘do not know’ category, but no ‘something else’ category, the ‘do not know’ category was expanded to ’do not know/other’ where there was no pre-existing ‘other’ category. In some cases this was better suited for the qualitative responses submitted by email.

Some respondents submitted duplicate responses. Where these were different, the most recent response was kept and the preceding answers removed. Not all respondents gave details about who they were.

Demographic information

None of the email participants were asked to provide demographic information.

Stakeholder type

We coded all respondents into stakeholder groups based on the information provided by the respondents in response to being asked ‘what type of stakeholder are you?’, and additional information they provided including the name of the respondent organisation where this question was not answered.

The largest group of respondents were accommodation providers (31%). This was followed by trade associations (19%) and travel agents (19%).

There were 6 respondents who did not provide sufficient information to identify the stakeholder group they fell into.

Stakeholder group	Number of respondents	% of responses
Accommodation	35	31%
Aggregator	2	2%
Airline	2	2%
Approved body	3	3%
Financial services	7	6%
Industry consultant	2	2%
Lawyers	3	3%
Leisure and hospitality	8	7%
Trade association	21	19%
Travel agent	21	19%
Other – consumer group	1	1%
Other – local authority	1	1%
Other – individual	1	1%
Unknown	6	5%

Which of the following best describes your business?

The majority of respondents (38%, n= 43) reported being independent-owner operated.

Business type	Number of respondents	% of responses
Aligned to an airline	4	4%
Independent - owner operated	43	38%
Non-independent	5	4%
Other (please specify)	19	17%
No response/Not asked	42	37%

How many employees does your business have?

The respondents represented the views of businesses of a variety of sizes, with 26% (n=29) having 0-9 employees, and 23% (n=26) having 250+ employees.

Number of employees	Number of respondents	% of responses
0-9	29	26%
10-49	11	10%
50-249	5	4%
250+	26	23%
No response/Not asked	42	37%

How is your business predominantly conducted?

The businesses predominantly operated both in person and online (42%, n=47).

Online or in person	Number of respondents	% of responses
Both	47	42%
In person	7	6%
Online	21	19%
No response/Not asked	38	34%

Which of the following do you provide?

27% (n=40) provided both international and domestic offers, compared to 22% (n=25) who offered domestic only offers and 6% (n=7) who provided international only offers.

Services provided	Number of respondents	% of responses
Domestic only offers	25	22%
International only offers	7	6%
Mix of both	30	27%
No response/Not asked	51	45%

Which sector does your business predominately fall in?

Sector	Number of respondents	% of responses
Hospitality	11	10%
Leisure	8	7%
Tourism	33	29%
Other (please specify)	18	16%
No response	43	38%

Part 2: summary of question responses

In this section, we outline the key themes identified in the responses provided to the questions that we asked in our consultation. Where relevant, we have presented both quantitative and qualitative analysis. Most respondents did not answer all of the questions, with response rates varying from 99 to 65%. This was anticipated as, given the nature of the regulations, not all stakeholders would have an interest in all the questions. A breakdown of responses is given in Appendix 1.

Domestic: how rules should apply to UK-only package holidays

Questions 1-3 were designed to better understand the appetite and drive for, and concerns about allowing for a domestic exemption to UK package holidays. We asked respondents:

• do you think that domestic only arrangements that do not include travel should be exempt from the regulations?
• if you offer or have considered offering domestic packages, what impact does the current regulatory regime have on your decision to put together domestic packages?
• would removing domestic packages that do not include a travel element from the scope of the regulations support businesses to: a) offer more choice? b) offer lower cost options?

With respect to exempting domestic only arrangements that do not include travel from the regulations:

• 65% of respondents answered in favour
• 27% responded ‘no’
• 8% gave ‘do not know/other’ responses

Those in favour predominantly consisted of:

• accommodation providers
• leisure and hospitality businesses
• tourism organisations, such as airlines and aggregators

Consumer groups, one local authority, and legal representatives were largely against the proposed changes. The approved bodies represented the views of their members, which included those for and against the proposal.

Those in favour said that proposals could benefit smaller businesses that are currently unable to navigate what is seen to be a complex regulatory environment. Accommodation providers described the current system as “prohibitively difficult or impossible for small businesses”.

Accommodation providers were concerned that, in offering a package, they would be legally responsible for the whole arrangement and would be liable if something went wrong with all elements, including those provided by a third party. In addition, they cited not just financial protection requirements, but also public liability insurance challenges. These were seen as currently preventing them from offering value-added services. For example, accommodation providers offering a voucher for a meal in a local restaurant.

In parallel, critics of the changes highlighted that there could be confusion as to:

• which packages were in or out of the scope of the regulations
• who would be legally responsible for delivery of the package
• in some cases, where the legal jurisdiction lies as, without the reserved nature of the regulations, different devolved legislation would apply in each of the home nations of the UK

When exploring the implications of the proposal, 60% of respondents felt the changes would benefit consumers and businesses. Within that 60%:

• 11% of respondents answered that this would enable businesses to offer more choice
• 4% felt it would enable businesses to offer lower cost options
• 45% felt that it would enable businesses to do both of these
• 16% did not feel either of these benefits would occur
• 24% gave a ‘do not know’ response

Industry representatives highlighted significant economic benefits in exempting domestic packages from the regulations. Within their response, the Tourism Alliance drew upon their own survey results, expressing that 74% of businesses would develop new product offerings if freed from the regulations, potentially boosting income by an average of 9%. The survey suggested that, with domestic tourism currently generating £32.9 billion annually, such an increase could translate to an additional £3 billion in domestic tourism expenditure and create over 40,000 new jobs.

Similarly, exempting domestic packages was seen as a means for Local Visitor Economy Partnerships (LVEPs) and Destination Management Organisations (DMOs) to develop more varied and attractive combined offerings without what they viewed to be disproportionate regulatory burdens.

Other points raised in favour pertained to the relatively stable landscape of UK tourism. The Professional Association of Self-Caterers UK (PASC) noted that the domestic market has unique characteristics that make current regulations less relevant. For example, 73% of domestic holidaymakers use private vehicles rather than package transport services. In addition, industry groups argued that the risk profile for domestic products is significantly different from international travel, citing that there were only 24 bankruptcies in the ‘holiday and short stay’ sector in 2024 (just 0.1% of all UK bankruptcies).

In contrast, consumer groups and legal representatives emphasised the importance of maintaining the protections the regulations provide for consumers. They emphasised that exempting domestic packages could create an uneven playing field for consumers if differing protections were offered for UK packages compared to those overseas, or UK packages with travel compared to those without. Research from Which? indicates consumers believe that the same problems can arise on holidays in the UK as abroad, and reiterated that a package organiser’s responsibility towards consumers should not change depending on the holiday location.

Critics also highlighted that the regulations contain important consumer protections not replicated elsewhere in consumer law, such as requiring organisers to provide assistance during disruptions. They argued that section 75 of the Consumer Credit Act or chargeback rules are insufficient alternatives, particularly for group bookings or payments made by alternative means.

It was also raised that, under normal consumer law such as the Consumer Rights Act 2015, businesses selling packages may still, in some cases, be held accountable for the performance of the whole package, irrespective of whether elements were provided by third party suppliers.

Finally, deregulation of the domestic market was proposed as potentially having an adverse effect on SMEs (small and medium-sized enterprises), micro businesses, and consumers. This was due to concerns regarding larger businesses potentially entering into the market and exploiting the exemption to avoid providing packages which, in turn, could push smaller businesses out of the market and expose consumers to more unprotected holidays.

Regulation of linked travel arrangements (LTAs)

Question 4 was designed to understand:

• whether LTAs meet the needs of industry and consumers
• what benefits there are in the current system
• whether greater benefits could be secured by a reformed LTA model

In response to what should be done regarding the regulatory position on LTAs:

• 6% of respondents wanted it ‘kept as is’
• 29% wanted the regulatory position to be ‘simplified by extending the scope of Type A and removing Type B’
• 54% wanted ‘something else’
• 11% answered ‘do not know’

The deep dive into the qualitative answers, however, revealed a discordance between the qualitative and quantitative answers, as will will now explore.

Stakeholders across the spectrum acknowledged that LTAs are complicated, poorly understood, and pose significant challenges for both consumers and the travel industry. A key concern was that consumers often believe they have protections that do not exist under LTA arrangements (LTAs – unlike packages – do not impose liability for performance of the holiday on the organisers). This position was echoed in respect to accountability when problems arose, with ambiguity over “responsibility for delivery of services and the resolution of complaints, particularly where multiple providers are involved” creating confusion for traders. Additionally, there was a perception that LTAs are not actively offered as a product, but instead result from specific sales practices employed by traders. Those actively selling them tended to be larger businesses, such as airlines, who tended to engage with Type Bs.

A strong message across stakeholders was to reclassify LTAs as packages. While the value of LTAs as an anti-avoidance mechanism was recognised, it was felt that it would be simpler for both businesses and consumers if certain aspects of the current LTAs were absorbed into the definition of a package. Incorporating the LTA definition into the package definition also received high levels of support from members of approved bodies. For example, in ABTOT’s (Association of Bonded Travel Organisers Trust Limited) survey results, 61% supported incorporating the LTA definition into the definition of a package.

For those that expanded on how to achieve this, a common view was to specifically convert Type A LTAs into packages while abolishing Type B LTAs completely. Some proposed a more comprehensive solution of abolishing LTAs as a standalone category and, instead, treating the booking of any combination of travel services within a defined period (for example, 24 to 48 hours) via the same commercial entity or website as a package.

Some stakeholders advocated for completely removing LTAs from the regulatory framework without any subsequent redefinition of what constitutes a package. Instead, these stakeholders suggested enhanced information requirements to ensure consumers clearly understand when they are booking services without Package Travel Regulation protections. However, the complete removal of LTAs without any parallel enhancement of consumer protections was cautioned, with concerns that their removal would lead to the reopening of the loopholes they were intended to close. Stakeholders warned that businesses should not be permitted to exploit the absence of LTAs to avoid package organiser responsibilities while creating the impression of bundled offers. In addition, this approach was deemed as high risk by some stakeholders who viewed the continued evolution of travel technology and increasingly sophisticated booking journeys as prime for exploitation.

Of those who wished for a simplification of the current system, suggestions were made to expand the definition of Type A to include both single point of sale and targeted linked booking processes. Calls were made for an enhanced definition of ‘targeted’ to ensure that LTAs only arise where the second service is clearly promoted by the first trader. Some stakeholders also suggested removing the 24-hour rule, arguing that “links can easily be delayed beyond this window, undermining the Regulation’s intent.” Conversely, others recommended maintaining but clarifying that “an LTA is only created where a business arrangement exists between 2 businesses.”

Flexibility over how insolvency protection is provided

Questions 5 to 8 were designed to explore whether there was any appetite or ability to make the requirements for insolvency protection more flexible. The questions explored whether increasing flexibility in how businesses can get insolvency protection would benefit businesses to meet their obligations under the regulations.

They asked stakeholders to identify:

• any risk associated with increased flexibility in insolvency protection, particularly for compliance and enforcement
• other ways the cost to package travel businesses of securing insolvency protection could be reduced without compromising consumer protections
• the risks and or benefits of keeping the regulations as they are

On whether increasing flexibility on insolvency protection would benefit businesses to meet their obligations under the regulations:

• 57% responded ‘yes’
• 13% responded ‘no’
• 30% answered with a ‘do not know’ or gave an ‘other’ response

Stakeholders expressed diverse views on the benefits of broadening insolvency protection flexibility. While many supported reforms for greater flexibility, there was strong emphasis on maintaining robust consumer protection and clear regulations.

Those in favour of increased flexibility cautioned that, to make it work in practice, additional reforms would be required.

These included:

• enhanced insurance obligations
• clearer trust account rules, particularly on issues of transparency and fidelity insurance
• robust data-sharing agreements
• strengthened oversight

They also detailed how a hierarchy of liability would need to be established to provide clarity as to which provider would be liable in the event of a claim. Concerns were raised that, without these structures in place, introducing flexibility could aggravate the existing deficiencies in consumer protection, most notably widening the gap between regulatory intention and real-world enforcement. This could, in turn, make it more difficult to ensure consumers are adequately safeguarded in the event of a travel organiser’s insolvency. It was also raised that, while the concept may be appealing, the uptake on combined flexibility may be fairly low.

Of those in favour of retaining current requirements, respondents felt that the current regulations offer simplicity, clarity, and strong consumer safeguards. It was highlighted that increased flexibility could cause confusion over refund responsibilities and lead to subsequent poor consumer outcomes. Concerns were raised about how any changes could impact the insurance market stability.

An alternative approach that was mooted was the establishment of a centralised protection fund, similar to the ATOL model. This was proposed as a way of spreading risk and reducing individual costs, but still guaranteeing consumer refunds in the event of insolvency.

In addition, the cost and complexity of insolvency protection for tour operators was cited as being significantly increased by 2 core issues:

• dual regulation under ATOL and Package Travel Regulations (PTR)
• being compensators of last resort

Regarding dual regulation, for businesses offering flight and non-flight packages, they must currently comply with both ATOL and PTR requirements. This duplication was put forward as creating unnecessary administrative burdens and a driving factor for increased costs. The desire for a unified regulatory framework with a single, integrated system was proposed as a way to streamline compliance, reduce duplication, and improve operational efficiency. Regarding their position as compensators of last resort, this was argued as having substantial impact on businesses and their ability to remain buoyant. Suggestions were put forward that a hierarchy of payment provisions would help alleviate some of the current common issues faced by providers.

Territorial restrictions on insurance cover

Question 9 to 11 were designed to better understand whether relaxing the territorial restriction on where insurers are authorised would provide any risks or benefits to businesses and consumers.

In response:

• 24% of respondents wanted to ‘retain the requirements as they currently are’
• 29% wanted to ‘relax territorial restrictions to allow supply by those regulated outside the UK, subject to protections being developed’
• 12% wanted ‘something else’
• 34% did not know

Overall, the appetite for expanding territorial permissions was not particularly strong. On the whole, respondents cautioned the impact relaxing standards could have on both consumers and the UK insurance market.

Those in favour tended to favour extending territorial restrictions by means of a reciprocal agreement with other countries, such as those in the EU. This was due to the perception of similar standards and familiarity with claims processes from when the UK was a member state (and shared the same regulatory requirements). In addition, they recognised the need to ensure business and consumer protections remained in place. Suggestions were made that the Financial Conduct Authority (FCA) would need to play an active role in the monitoring and assessment of any countries to ensure they met the same standards as those based in the currently permitted regions. Some respondents believe that with proper regulation, non-UK providers could offer “good quality reliable services”.

Those against extending the territorial restrictions emphasised the need to maintain robust consumer protections, the importance of regulatory clarity, and upholding fair treatment for UK businesses.

On risks to consumer protections, concerns were expressed that allowing non-UK insurers could reduce standards and leave consumers exposed. This was raised in the context of concerns over lack of regulatory oversight and the difficulty of monitoring and enforcing standards for non-UK providers, especially without FCA involvement. Fears over the quality and reliability of cover were raised. Respondents highlighted that increased competition may lower costs but could also compromise the quality and claims-handling of insurance products. There was particular emphasis on concerns regarding how dispute resolution would work in a non-UK insurance market.

Additional risks were highlighted, including that changes could drive up costs for UK businesses or cause established UK insurers to exit the market. There were suggestions that safeguarding client funds in trust or escrow (an agreement where a neutral third party holds assets or funds until specific conditions of a contract are met) are seen as effective and beneficial alternatives. In addition, some respondents felt that the current regulations were working, and that they were seeing more capacity in the UK insurance market, indicating optimism about market stability.

How other tourist services form part of the rules

The aim of questions 12 to 14 was to understand the roles played by the ‘significant proportion’ criteria and ‘essential feature’ in the current definition of other tourist services and what should and or could be done to improve this area of the regulations.

Regarding the significant proportion criteria:

• 14% wanted to ‘retain the current definition as is’
• 55% wanted ‘the significant proportion criterion to be removed’
• 12% wanted something else
• 21% did not know

In the free text responses, views were mixed on how best to approach the significant proportion criteria.

For respondents who wished to retain the significant proportion criteria, the clear and objective nature was cited as an important factor. It was also viewed as providing consistency across providers. This was especially pertinent in relation to online sales where the working understanding of 25% (based on EU recitals) assisted with automated package classifications and booking systems. This objectivity was deemed as important, especially with the issues posed by the subjective nature of ‘essential feature’.

Of the respondents:

• 73% of respondents believed that it was not clear what forms an ‘essential feature’ of the package
• 19% believed it was clear
• 8% responding with ‘do not know’ or gave an ‘other’ response

Relying on essential features alone was seen as problematic, both with respect to how businesses sell other tourist services and how consumers perceive them. An essential feature for one traveller may not be the same for another.

For those that valued ‘significant proportion’, views were split on whether the working understanding of 25% should be placed into legislation or left as it currently is. While drafting 25% into the law was seen as adding certainty, it was also viewed as potentially too restrictive.

Those in favour of removing the significant proportion criteria cited issues with dynamic pricing. As prices fluctuate seasonally, the criteria were viewed as disproportionately impacting smaller accommodation providers who offer higher ticket ‘add-ons’. For example, a value B&B offering a round of golf would be caught by these requirements whereas a high-cost hotel offering the same round would not. However, even for those in favour of its removal, the subjectivity of essential feature was viewed as an issue as it may be interpreted differently by tour operators, consumers, and regulators.

There was a clear message that clarifying the meaning of an essential feature is favoured with most respondents finding the concept unclear and subjective, with concerns that it relies too much on individual judgement rather than objective measures.

Additional comments highlight the need for flexibility for accommodation providers and warned against making small add-on services trigger full regulatory compliance, as this could have an impact on growth in the SME sector.

Overall, the responses reflect a split between those wanting more flexibility and those prioritising clarity and objectivity in the regulations.

Redress from third parties

The purpose of question 15 to 19 was to examine the case for clarifying what the right to redress should mean in practice. They asked for views on:

• whether the regulations should be changed to require suppliers to provide redress to organisers within 14 days
• whether any time limit for payment of redress applies only in narrower circumstances than Regulation 29 (for example, only where the third party has cancelled or wholly failed to provide the relevant service)
• what else could improve package travel organisers’ ability to get timely and effective redress from suppliers
• the difficulties and benefits of leaving the legislation as it currently is

There was appetite across stakeholders for the introduction of a time-limited period for redress to be provided for in law. When asked whether the regulations should be changed to require suppliers to provide redress to organisers within 14 days:

• 57% responded ‘yes’
• 18% responded ‘no’
• 25% gave ‘do not know’ or ‘other’ responses

Of those in support, concerns were raised at the conduct of third-party suppliers where their failure to compensate in a timely manner was leaving travel providers carrying a financial burden, both in respect to refunding consumers, as required under the regulations, and pursuing claims against third parties. One approved body highlighted that 60% of members are dealing with monthly supplier cancellations, at an average cost to members of £45000 per year.

Those in support of amending the Regulation to account for a time limit for payment of redress cited that suppliers should be subject to the same timeframes for refunds as businesses are with consumers. While some called for a 7-day supplier refund period, most supported 14 days. When asked should any time limit for payment of redress apply only in narrower circumstances than Regulation 29 (for example, only where the third party has cancelled or wholly failed to provide the relevant service):

• 28% responded ‘yes’
• 42% responded ‘no’
• 30% responded ‘do not know/other’

However, in the free text section, there was a strength of opinion in favour of the need:

• for a clear set of circumstances to which the timeframe could be applied
• to avoid further dispute due to the associated costs and additional burdens this would place on providers

A targeted approach of 14 days for cancellations or failure to provide was seen as a fair balance between supplier and organiser’s duties. Respondents across demographics highlighted the interaction between Regulation 29 and Regulation (EC) No. 261/2004 (which sets out the rights of air passengers in the event of flight cancellations, denied boarding and long delays). They highlighted the need for clarity as to which one would apply under each circumstance.

In addition to the introduction of time-limited refunds, those in favour of amending Regulation 29 cited the need to update it to reflect the outcome of the recent Beach versus Ryanair case, where the judge stipulated that the Regulation provided for a right to redress, not just a right to seek redress. Respondents put forward that the legislation should be amended to reflect this understanding.

As to leaving the legislation as it currently is, respondents were less supportive of the benefits of this, but instead highlighted the overall difficulties associated with Regulation 29, which the proposed amendments would not address.

The first difficulty was the issue of enforcement. Respondents raised that amending Regulation 29 would do little to assist with the current lack of enforcement. Respondents raised that this was particularly problematic for providers based abroad. Pursuing claims under Regulation 29 was highlighted as being difficult, especially for SMEs due to:

• size and commercial leverage disparity between organisers and suppliers
• the cost of pursuing redress through the UK courts
• the inability and difficulty to pursue international or cross-border claims against suppliers based abroad 

In addition, they raised that there was a lack of guidance or enforcement offered by the CAA, Competition and Markets Authority (CMA), or government to assist, with tour operators being left to pursue actions by themselves. Greater concentration of resources on enforcement was seen as more beneficial than changing the legislation.

The second point related to contracts. Respondents believed that businesses should have solid contracts in place. Some raised that contracts should be secure and in place, something which would negate the need for Regulation 29 at all. Others raised that contracts are not always in place or can be an issue to negotiate favourably, especially in areas of power imbalance, such as in the case of monopolisation of service provision or size of travel organiser versus third party supplier.

On balance, stakeholder responses supported changes to introduce:

• certainty to the meaning of the Regulation
• a time-limited period for payment of redress for set criteria

Although the issue of enforceability remains, it was viewed that making the legislative changes would allow for a more fair and balanced position for organisers.

Part 3: government response

The government is committed to retaining key consumer safeguards while supporting business growth in the travel sector. In our consultation we presented a set of proposals to bring about growth and increase consumer choice. The variety of responses received demonstrate the breadth and strength of opinions surrounding the regulations. Across each area, there was no single consensus on how best to proceed. Any changes must, therefore, be proportionate and either fix problems or bring about opportunities that non-legislative avenues would not achieve.

Having carefully considered responses gathered as part of the extensive engagement with stakeholders over the call for evidence and consultation period, the government intends to take forward the following measures:

• 2 key changes to LTAs:

  • absorbing LTA Type A into the definition of a package: This would provide full package protections when consumers make a booking in circumstances similar to current Type As, effectively extending consumer rights while simplifying business compliance
  • removing LTA Type B entirely: eliminating Type B arrangements (where a trader facilitates booking of a second service from another trader within 24 hours). The rationale is that these arrangements provide minimal consumer protection and are easily circumvented. This removal would support domestic sector growth, allowing small businesses like B&Bs to refer customers to local activity providers without triggering package regulations

• update third-party redress provisions: establish a 14-day period for refund of cancelled services and clarify redress rights, helping organisers recover costs from suppliers more effectively

These will further embed the core consumer protection principles that underpin the attractiveness of package holidays, while simplifying compliance and supporting all businesses in the sector to get a fair deal. The government will legislate to implement these measures using retained EU law powers.

Throughout the call for evidence and consultation, several pertinent issues arose. These included the need to restructure liability claims and clarify the hierarchy of payment provisions amongst travel insurers, credit card providers, and travel operators. The use of retained EU law (REUL) powers limits the nature of changes we can make. In addition, to the previously mentioned legislative changes, we are committed to exploring issues raised by stakeholders that cannot be resolved using the current legislative vehicle.

In this section of the document, we set out more detail about how the reforms will be designed and how we intend to deliver them. We also address areas where changes will not be implemented, explaining why we have reached that conclusion.

Areas not for change

Domestic: how rules should apply to UK-only package holidays

As demonstrated in the consultation responses, the proposal to remove domestic holidays without a travel element split opinion. While the strength of positive feeling from businesses who would benefit from these reforms was tangible, the concerns and risks identified to consumers requires careful consideration.

The nature of package arrangements means that one supplier is responsible for taking payment for the entire set of goods and services. Often, this occurs up front and in advance of the package taking place. While we appreciate evidence on the low failure rates of UK hospitality businesses, should the booking organiser fail, without insolvency protection in place, the returning of monies paid back to consumers could require complex means to recovery. With many consumers not paying via credit card and, therefore, not being able to benefit from section 75 protections, we must consider these implications.

In addition, businesses in favour of the proposals flagged that the existing regulations and the inclusion of all domestic trips as packages, leave them liable for the performance of the entire package and goods and services delivered. However, in some cases, it may be that, even with the proposed exemption, the organiser would be subject to the provisions of the Consumer Rights Act 2015, where, for example, goods and services must be as described and delivered with reasonable care and skill. Removing domestic trips without travel from outside the scope of the regulations may not, therefore, have the desired effect of freeing organisers from liability claims or responsibility for performance. Moreover, where consumers have paid a single trader for the delivery of multiple services, they are likely to expect, and it is arguably equitable, that the trader will be liable for delivering those services.

Fundamental to the proposal was the protection of the travel element. Throughout the consultation and in policy and legal considerations, what constituted travel remained a key concern. Transport takes place not only at the start and end of a trip, but also during, for example in destination transport between events. Drafting the legislation in such a way that captured all these variables could leave this provision open to much debate and confusion which would create a difficult landscape for consumers and businesses to navigate.

The policy aim of the proposal was, and remains to be:

• to support business growth
• regulate in a proportionate manner
• retain consumer protections

We are still committed to achieving this. While we will not be taking forward the proposals to exempt domestic packages without travel from the regulations, we will be making changes to linked travel arrangements which we believe will achieve the same policy aim.

Flexibility over how insolvency protection is provided

The spirit of the proposal was to explore how to make the provision of insolvency protection more flexible for traders.

As to be expected, the principle of flexibility was welcomed. However, as outlined, respondents raised strong concerns on how and or if this would and could work in practice. For those in favour, we saw no compelling evidence on how the flexibility would work in practice versus principle. For example, while certain trust providers operate open technology and data sharing systems, there was no demonstration of this happening across the board. It was also clear that increased flexibility may only perpetuate existing concerns regarding duplication of claims, hierarchy and order of payments, and associated handling roles and responsibilities, and liability regarding shortfall funds.

Fundamentally, the presiding consensus was that allowing for increased flexibility would do very little to account for what is seen as the “bigger picture” issues. Namely, the current position of travel operators as insurers of compensators of last resort, and the requirement for travel operators conducting both flight and non-flight business to comply with 2 separate regimes. The government recognises that these issues continue to be a concern for the sector. Although they remain outside the scope of current reform proposals, we will continue to explore these areas, working with industry to better understand what is needed.

Given these factors, the government will not be making any immediate changes to this area.

Territorial restrictions on insurance cover

The consultation sought to explore whether relaxing the territorial restriction on where an insurer is authorised could widen the choice available to organisers which, in turn, may lower costs and make more packages available to travellers. 

The consultation responses indicated some confusion as to what was meant by the wording of the current regulations, namely:

Insurance

22-(1) Where an organiser, for the purpose of Regulation 19(5), relies on the arrangements under this Regulation, the organiser must have insurance under one or more appropriate policies with an insurer authorised in respect of such business in the United Kingdom, the Channel Islands or the Isle of Man, under which the insurer agrees to indemnify travellers in the event of the insolvency of the organiser.

Some respondents took the regulations to require insurers to be based in the UK, Channel Islands, or the Isle of Man. The government can confirm that the regulations require the insurer to be authorised for general insurance business in the UK, Channel Islands, or the Isle of Man.

There were calls for European-based insurers to be permitted (as was the case pre-EU withdrawal). However, as we have clarified previously, any insurer, irrespective of their geographical location, can provide insurance, providing they are authorised in respect of that business in the UK, the Channel Islands or the Isle of Man.

We heard no compelling evidence as to how the market could be expanded in a safe and workable way. In addition, some respondents highlighted how more UK insurers are moving back into the area.

Given the re-confirmation of the current legislation, the government will not be making any changes to this area.

How other tourist services form part of the rules

While it is appreciated that the requirements for ‘other tourist services’ to form a ‘significant proportion’ or be an ‘essential feature’ of a package may result in issues for some providers, the government believes that the combination of the 2 criteria provides for a measurable and consistent framework from which sale-based decisions can be made.

On balance, the ‘significant proportion’ aspect allows for a tangible measurement to filter out incidental add-ons and services. Removing this could inadvertently mean more services fall within the scope of a ‘package’. In an increasingly digital age, it is also appreciated that a numeric metric is of use to travel providers building online packages. However, cementing the 25% into legislation would remove the element of flexibility currently employed in the understanding of ‘significant proportion’.

We recognise that ambiguity over essential feature continues to provide some confusion, but this would be better addressed in updates to the current guidance rather than legislative change.

The government does not believe that making changes would achieve anything meaningful without creating unintended issues. In light of these factors, we will not be taking these proposals forward.

Areas for change

Regulation of linked travel arrangements (LTAs)

The intention of consulting on LTAs was to understand if there was a way to simplify what is seen as a burdensome and confusing requirement of the regulations.

Across respondents there was the consensus that LTAs are complex for businesses and misunderstood by consumers, who believe they offer stronger protections than they do.

Having considered responses, the government intends to make the following changes:

Change 1: absorb LTA Type A into package definition

This would provide full package protections when consumers make a booking in circumstances similar to current Type As. Many travel organisers already offer packages in LTA Type A circumstances. This change would simplify business compliance arrangements and provide for enhanced consumer protections

Change 2: remove LTA Type B entirely

It is clear that these arrangements provide minimal consumer protection. In removing Type Bs completely, we aim to support the policy objective of facilitating domestic sector growth. Removing Type Bs will allow small businesses (for example, B&Bs) to refer customers to local activity providers without triggering package regulations, while maintaining standard consumer protections. This supports the government’s economic growth mission.

These changes are intended to support growth in the market, by significantly simplifying compliance and reducing the scope of the insolvency protection requirements, while retaining consumer confidence in both the travel sector and the regulations.

Redress from third parties

Our consultation examined the case for introducing clarity to Regulation 29 alongside time limitations on redress from third parties.

It remains that business to business contracts remain the most appropriate avenue for businesses to agree their terms. However, for various reasons, as emphasised in the consultation responses, these can be lacking. This means that supporting a means for travel organisers to be empowered to take action remains a government priority.

While we appreciate that enforcement of the regulations will continue to remain an issue, we believe there is a strong case for amending Regulation 29 to provide greater rights and protections for travel organisers.

Having considered the responses, the government will take forward the following changes:

• establish a 14-day period for refund of cancelled services
• clarify that the Regulation confers a ‘right to redress’ and not just a ‘right to seek redress’

In making these changes, we aim to aid business resilience by helping organisers to recover costs from suppliers.

Conclusion

The government would like to thank all respondents for their submissions to this consultation. Your input has been invaluable and has informed the following conclusions:

• on the whole, the Package Travel and Linked Travel Arrangements Regulations 2018 work well but would benefit from specific targeted improvements
• for certain areas, making changes would potentially create greater risk and confusion for businesses and consumers. Having carefully considered all arguments, no changes will be made in the areas of domestic packages, flexibility over how insolvency protection is provided, territorial restrictions on insurance cover, or how other tourist services form part of the rules
• on balance, there are areas where changes would both support business growth and provide clarity for Industry, while also increasing and maintaining consumer protections. Targeted changes, as outlined previously, will therefore be made to Regulation of linked travel arrangements (LTAs) and redress from third parties
• it is understood that there remain difficulties with the regulations that the current legislative avenue could not resolve. The government remains committed to exploring these with industry

These measures are in line with the government’s growth agenda and firm commitment to supporting and retaining consumer protections.

The government will legislate in line with retained EU law requirements. Working to these timetables, we anticipate for legislation to put forward to parliament by June 2026.

Contact details

Email: Package Travel Team at packagetravel@businessandtrade.gov.uk

Write to:

Consumer Protection Team
Department of Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY

Appendix 1: responses to consultation questions

This Appendix gives a breakdown of the quantitative questions and answers. For these questions, respondents were able to pick from a fixed set of responses. For the qualitative questions, where respondents could give free text answers, responses are summarised in the summary of question responses section.

Domestic packages

Question 1: do you think that domestic only arrangements that do not include travel should be exempt from the regulations?

98% of respondents answered this question. Of these:

• 65% (n=72) responded ‘yes’
• 27% (n=30) responded ‘no’
• 8% (n=9) gave ‘do not know/other’ responses

Business	Yes	No	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	100%	0%	0%	35	100%
Aggregator	100%	0%	0%	1	50%
Airline	100%	0%	0%	2	100%
Approved body	0%	67%	33%	3	100%
Financial services	14%	86%	0%	7	100%
Industry consultant	0%	50%	50%	2	100%
Lawyers	0%	100%	0%	3	100%
Leisure and hospitality	100%	0%	0%	8	100%
Trade association	80%	15%	5%	20	95%
Travel agent	38%	38%	24%	21	100%
Other – consumer group	0%	100%	0%	1	100%
Other – local authority	0%	100%	0%	1	100%
Other – individual	0%	100%	0%	1	100%
Unknown	17%	67%	17%	6	100%

Question 3: would removing domestic packages that do not include a travel element from the scope of the regulations support businesses to offer more choice, offer lower cost options, both, or neither?

94% of respondents answered this question. Of these:

• 11% felt it would enable businesses to offer more choice
• 4% felt it would enable businesses to offer lower cost options
• 45% felt that it would enable businesses to do both of these
• 16% did not feel either of these benefits would occur
• 24% gave a ‘do not know’ response

Business type	Offer more choice	Offer lower cost options	Both	Neither	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	12%	3%	79%	0%	6%	34	97%
Aggregator	0%	0%	100%	0%	0%	1	50%
Airline	no data	no data	no data	no data	no data	0	0%
Approved body	0%	0%	0%	67%	33%	3	100%
Financial services	0%	0%	0%	71%	29%	7	100%
Industry consultant	0%	0%	0%	50%	50%	2	100%
Lawyers	0%	0%	0%	67%	33%	3	100%
Leisure and hospitality	29%	14%	57%	0%	0%	7	88%
Trade association	21%	0%	53%	5%	21%	19	90%
Travel agent	5%	5%	24%	24%	43%	21	100%
Other – consumer group	0%	0%	0%	100%	0%	1	100%
Other – local authority	0%	0%	0%	0%	100%	1	100%
Other – individual	0%	0%	0%	0%	100%	1	100%
Unknown	17%	17%	17%	0%	50%	6	100%

Linked travel arrangements

Question 4: do you think the regulatory position on linked travel arrangements should be kept as it is; or simplified by extending the scope of Type A and removing Type B, something else, do not know?

99% of respondents answered this question. Of these:

• 6% wanted it ‘kept as is’
• 29% wanted the regulatory position to be ‘simplified by extending the scope of Type A and removing Type B’
• 54% wanted ‘something else’
• 11% answered ‘do not know’

Business type	Should be kept as it is	Should be simplified by extending the scope of Type A and removing Type B	Something else	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	3%	46%	49%	3%	35	100%
Aggregator	0%	0%	100%	0%	2	100%
Airline	0%	50%	50%	0%	2	100%
Approved body	0%	0%	100%	0%	3	100%
Financial services	29%	43%	29%	0%	7	100%
Industry consultant	0%	0%	50%	50%	2	100%
Lawyers	0%	33%	67%	0%	3	100%
Leisure and hospitality	0%	38%	13%	50%	8	100%
Trade association	0%	30%	65%	5%	20	95%
Travel agent	10%	10%	67%	14%	21	100%
Other – consumer group	0%	0%	100%	0%	1	100%
Other – local authority	0%	100%	0%	0%	1	100%
Other – individual	0%	0%	100%	0%	1	100%
Unknown	33%	0%	33%	33%	6	100%

Insolvency protection

Question 5: would increasing flexibility to insolvency protection benefit businesses to meet their obligations under the regulations?

95% of respondents answered this question.

Of these:

• 57% responded ‘yes’
• 13% responded ‘no’
• 30% answered with a ‘do not know’ or gave an other response

Business type	Yes	No	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	82%	3%	15%	34	97%
Aggregator	0%	0%	100%	1	50%
Airline	100%	0%	0%	1	50%
Approved body	100%	0%	0%	3	100%
Financial services	43%	43%	14%	7	100%
Industry consultant	0%	50%	50%	2	100%
Lawyers	0%	0%	100%	3	100%
Leisure and hospitality	29%	0%	71%	7	88%
Trade association	47%	5%	47%	19	90%
Travel agent	67%	14%	19%	21	100%
Other – consumer group	0%	100%	0%	1	100%
Other – local authority	100%	0%	0%	1	100%
Other – individual	0%	100%	0%	1	100%
Unknown	0%	50%	50%	6	100%

Territorial restrictions on insurance cover

Question 9: what should we do concerning insurance cover for insolvency protection providers?

80% of respondents answered this question.

Of these:

• 24% wanted to ‘retain the requirements as they currently are
• 29% wanted to ‘relax territorial restriction to allow supply by those regulated outside the UK, subject to protections being developed’
• 12% wanted ‘something else’
• 34% did not know

Business type	Retain the requirements as they currently are	Relax territorial restriction to allow supply by those regulated outside the UK, subject to protections being developed	Something else	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	15%	25%	5%	55%	20	57%
Aggregator	0%	0%	0%	100%	1	50%
Airline	100%	0%	0%	0%	1	50%
Approved body	33%	33%	33%	0%	3	100%
Financial services	57%	14%	29%	0%	7	100%
Industry consultant	50%	0%	0%	50%	2	100%
Lawyers	67%	0%	33%	0%	3	100%
Leisure and hospitality	0%	14%	0%	86%	7	88%
Trade association	44%	25%	0%	31%	16	76%
Travel agent	0%	67%	14%	19%	21	100%
Other – consumer group	100%	0%	0%	0%	1	100%
Other – local authority	100%	0%	0%	0%	1	100%
Other – individual	0%	0%	100%	0%	1	100%
Unknown	17%	0%	33%	50%	6	100%

How often tourist services form part of the rules

Question 12: what should be done to the ‘significant proportion’ criterion included in the current definition of other tourist services?

97% of respondents answered this question.

Of these:

• 14% wanted to ‘retain the current definition as is’
• 55% wanted ‘the significant proportion criterion to be removed’
• 12% wanted something else
• 21% did not know

Business type	Retaining the definition as it is	The ‘significant proportion’ criterion be removed	Something else	I do not know	Number of respondents to this question	Question response rate (%)
Accommodation	3%	85%	3%	9%	34	97%
Aggregator	0%	0%	0%	100%	1	50%
Airline	0%	50%	50%	0%	2	100%
Approved body	0%	33%	0%	67%	3	100%
Financial services	43%	14%	43%	0%	7	100%
Industry consultant	0%	50%	0%	50%	2	100%
Lawyers	0%	100%	0%	0%	3	100%
Leisure and hospitality	13%	38%	13%	38%	8	100%
Trade association	10%	70%	10%	10%	20	95%
Travel agent	24%	38%	10%	29%	21	100%
Other – consumer group	0%	0%	100%	0%	1	100%
Other – local authority	100%	0%	0%	0%	1	100%
Other – individual	0%	0%	100%	0%	1	100%
Unknown	33%	0%	17%	50%	6	100%

Question 13: is it clear what forms an ‘essential feature’ of the package, so consumers and businesses understand when a package has been created?

85% of respondents answered this question. Of these:

• 19% responded ‘yes’
• 73% responded ‘no’
• 8% responded ‘do not know’ or gave an ‘other’ response

Business type	Yes	No	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	12%	85%	3%	33	94%
Aggregator	0%	0%	100%	1	50%
Airline	0%	50%	50%	2	100%
Approved body	33%	0%	67%	3	100%
Financial services	43%	57%	0%	7	100%
Industry consultant	0%	100%	0%	1	50%
Lawyers	0%	100%	0%	3	100%
Leisure and hospitality	20%	80%	0%	5	63%
Trade association	11%	78%	11%	18	86%
Travel agent	37%	58%	5%	19	90%
Other – consumer group	0%	100%	0%	1	100%
Other – local authority	0%	100%	0%	1	100%
Other – individual	0%	100%	0%	1	100%
Unknown	0%	100%	0%	1	17%

Redress from third parties

Question 15: should the regulations be changed to require to provide redress to organisers within 14 days?

92% of respondents answered this question.

Of these:

• 57% responded ‘yes’
• 18% responded ‘no’
• 25% gave ‘do not know’ or ‘other’ responses

Business type	Yes	No	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	64%	15%	21%	33	94%
Aggregator	0%	0%	100%	1	50%
Airline	50%	50%	0%	2	100%
Approved body	100%	0%	0%	3	100%
Financial services	50%	17%	33%	6	86%
Industry consultant	50%	0%	50%	2	100%
Lawyers	no data	no data	no data	0	0%
Leisure and hospitality	14%	0%	86%	7	88%
Trade association	55%	35%	10%	20	95%
Travel agent	67%	14%	19%	21	100%
Other – consumer group	0%	100%	0%	1	100%
Other – local authority	100%	0%	0%	1	100%
Other – individual	100%	0%	0%	1	100%
Unknown	33%	17%	50%	6	100%

Question 16: should any time limit for payment of redress apply only in narrower circumstances than Regulation 29 (for example, only where the third party has cancelled or wholly failed to provide the relevant service)?

65% of respondents answered this question. Of those who responded to this question:

• 28% responded ‘yes’
• 42% responded ‘no’
• 30% responded ‘do not know/other’

Business type	Yes	No	Do not know	Number of respondents to this question	Question response rate (%)
Accommodation	25%	31%	44%	16	46%
#Aggregator	0%	0%	100%	1	50%
Airline	100%	0%	0%	2	100%
Approved body	33%	33%	33%	3	100%
Financial services	33%	33%	33%	6	86%
Industry consultant	0%	100%	0%	1	50%
Lawyers	no data	no data	no data	0	0%
Leisure and hospitality	14%	14%	71%	7	88%
Trade association	47%	33%	20%	15	71%
Travel agent	16%	68%	16%	19	90%
Other – consumer group	0%	100%	0%	1	100%
Other – local authority	100%	0%	0%	1	100%
Other – individual	0%	100%	0%	1	100%
Unknown	0%	100%	0%	1	17%