Meet your travel and tour operator regulatory duties

A. ATOL licensing

ATOL (Air Travel Organiser's Licence) is required if you sell flight-inclusive package holidays or flight-only arrangements to UK consumers as a principal, or as an agent for an undisclosed principal. ATOL provides insolvency protection for consumers through the Air Travel Trust Fund. It is a criminal offence to sell licensable arrangements without an ATOL.

There are four licence types: Standard ATOL, Small Business ATOL, Franchise ATOL and Trade ATOL. Each has different bonding, capital and reporting requirements. You must pay the ATOL Protection Contribution (APC) of £2.50 per licensable passenger booked and appoint an Accountable Person who completes the CAA's online training course.

ABTA membership is a separate, non-statutory trade-body bonding scheme. It does not replace the legal requirement to hold an ATOL where one is needed.

B. Package Travel Regulations 2018

The Package Travel and Linked Travel Arrangements Regulations 2018 (PTR 2018) apply when you sell a package combining at least two different travel services — transport, accommodation, vehicle hire (24 hours or more) or another significant visitor service (over 25% of the package cost) — for the same trip within 24 hours.

If you are the organiser, you must provide insolvency protection (bonding, insurance or trust account), give consumers pre-contract and standard information, and you are liable for the proper performance of the package. If you are a retailer, you must provide pre-contract information and pass on booking confirmations. For flight-inclusive packages, holding an ATOL satisfies the insolvency protection requirement. For non-flight packages, the protection is commonly provided through an ABTA bond or equivalent arrangement.

Linked travel arrangements — where you facilitate the purchase of separate travel services within 24 hours but they do not form a package — also trigger information and insolvency-protection duties, though these are lighter than the full package regime.

C. Consumer protection

The Consumer Rights Act 2015 requires that travel services are provided with reasonable care and skill, for a reasonable price (if not agreed in advance) and within a reasonable time. The unfair trading rules — formerly in the Consumer Protection from Unfair Trading Regulations 2008, now re-enacted in Part 4, Chapter 1 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) from 6 April 2025 — prohibit misleading actions and omissions about holiday destinations, prices, itineraries and insolvency cover. Aggressive sales practices (high-pressure upselling, creating urgency around limited availability) are also prohibited. The CMA can impose administrative fines of up to 10% of worldwide turnover for breaches under the DMCCA.