“It’s all so confusing, why is nothing simple”: Consumer difficulty navigating the complicated landscape of holiday protections

Executive summary

Consumer awareness of their rights, and effective enforcement of the rules, is essential to ensure the robust safeguarding and monitoring of consumer protections when booking holidays. The government is leading a number of initiatives to reform consumer rights within the travel industry and aid the recovery of the sector post-pandemic. The Department for Business and Trade (DBT) is currently considering ways to reform package travel legislation. Simultaneously, the Civil Aviation Authority (CAA) is undertaking a review of the ATOL scheme. Furthermore, the Department for Transport (DfT) has made a recent commitment to enhance consumer aviation policy by, among other things, strengthening the CAA’s consumer enforcement powers. This wide programme of reform presents an opportunity to ensure the important protections that come with holiday bookings continue to safeguard and empower consumers.

When it comes to booking a holiday, it is crucial for consumers to be aware of what their rights are and what protections are in place if things go wrong. Which? always advises travellers to book a package holiday, rather than purchasing individual elements separately. This type of booking benefits from high levels of protection under current legislation and helps ensure you get the holiday you paid for.

But there are many different ways in which a holiday can be booked these days, beyond the traditional package holiday. This can make it difficult and confusing for travellers to make informed decisions when choosing how and who to book their holiday with, especially when these decisions affect how well they are protected should something go wrong with their holiday. This complex landscape can lead to consumers experiencing financial and emotional detriment and ultimately harm their confidence in the market, which can become particularly evident and problematic during times of crisis. 

This report explores consumers' understanding of their protections when booking a holiday and how attitudes vary depending on the type of holiday being booked, be it a package, a DIY holiday or linked travel arrangement (LTA). We conducted a mixed methods research project with qualitative focus group interviews and a quantitative survey to delve into consumers' knowledge and perception of their rights when booking different types of holidays, looking at key consumer protections against insolvency, cancellations and inadequate performance of the travel services.

Our research found that consumers are generally good at identifying the protections afforded under package holidays and in turn really value these protections. Across the package holiday scenarios we tested in our qualitative focus groups and online survey, consumers were well versed in identifying; (i) what the holiday booking type was, (ii) the specific protections these holidays provided and (iii) the company responsible for fixing things when they went wrong on or before these holidays. The theme of fairness was strongly conveyed across the focus groups and online survey; almost 8 in 10 (79%) of UK adults thought that the amount of protection provided for package holidays was fair.

Consumers were surprised and angry at the lack of certain protections when individual services are booked separately (DIY holiday). This was driven by many participants thinking that they knew what the protections were when they were in fact incorrect. While some focus group participants said that they would not book holidays in this way in the future, due to this lack of protections, others said that they liked the flexibility this type of booking provides. This means that many consumers are likely booking in this manner, unaware of their lack of protection until something goes wrong. In addition, some participants expressed concern at the lack of insolvency protection for flight-only bookings and called for some universal coverage. 

We found consumers were very confused by the concept of linked travel arrangements, which are a combination of travel services booked from different companies under separate contracts but linked and facilitated by a single trader, and unsure as to what level of protection this type of booking comes with. Consumers were unsure about who should be responsible for their holiday if things went wrong, with a number of them feeling upset, vulnerable, concerned and angry when they were informed of what protections linked travel arrangements provide. When it comes to Type A arrangements, constituted by the separate selection and separate payment of travel services during a single visit to a travel company website or shop, our online survey found that almost half of consumers felt that the protections provided are unfair (47%), while only one in five (21%) thought they are fair. Linked travel arrangements in their current form create a landscape of confusion, burden and vulnerability to consumers, leaving them at risk of consumer harm.

Generally, it emerged that a lack of clear information during the booking process can drive confusion amongst holidaymakers, resulting in them thinking they know what protection they’ve got. This indicates that consumers could benefit from improved communication regarding both the presence (or absence) of their holiday protections. 

When considering attitudes towards protections for domestic UK holidays, we found that while some consumers believe that holidays abroad should offer more protections as they are likely to find themselves in more vulnerable situations when problems arise, the majority think that their rights should be the same (61%), whether the holiday takes place in the UK or abroad.

The research findings show that many consumers view travel insurance as the primary means of protection for their holidays. Insurance was the most common word that came to focus group participants’ and survey respondents' minds when asked what travel protection means to them. Over half (53%) of all survey respondents mentioned insurance, or being insured, in their response to what travel protection means to them.

Throughout the focus group interviews, it emerged that consumers’ views towards the fairness and appropriateness of their booking protections is linked to how effective they think these protections are in practice at safeguarding them from harm. Many participants were pessimistic about the ease of seeking redress and do not feel confident that the protections afforded under holiday bookings work well in practice. 

For package holiday protections we found that despite participants feeling reassured about the protections and saying they were fair, some were pessimistic about the ease and timeliness of receiving a refund or alternative arrangement they were entitled to. More than half of consumers felt it would be difficult to get a refund for package holiday issues (60%) and 57% felt it would be difficult to get a refund when holiday flights are cancelled. 

Recommendations for reform

The government is currently considering reforming consumer rights in the package holiday sector and whether there is scope for reducing requirements on businesses now that the UK has left the EU. Overall, this research provides evidence that consumers place considerable value on package holiday protections and that there are areas of improvements the government should consider as part of its review of the package travel rules. Most importantly, through its reform initiative, the government should seek to maintain high levels of consumer protection and consider opportunities to enhance current provisions for the benefit of travellers and businesses alike. The findings of this research highlight the need to:

• Review the information requirements on businesses selling package holidays and linked travel arrangements to ensure consumers are given clear, prominent and consumer friendly information, and consider the benefits of requiring travel businesses to inform their customers of what protections do not apply when booking individual travel services as opposed to packages to help them make informed decisions.
• Reform the rules on LTAs and their definitions to prevent businesses from circumventing the package holidays obligations, ensuring that consumers continue to benefit from high levels of protection as the market develops and new business models emerge. 
• Ensure that domestic package holidays are not exempted from the scope of the Package Travel Regulations as the government reviews the rules, maintaining a high level of consumer protection for travellers irrespective of the location of their holiday. 
• Grant stronger consumer enforcement powers to the CAA to tackle non-compliance in the airline industry and flight-inclusive packages, and ensure local authorities Trading Standards services are adequately resourced to monitor business practices and drive industry’s compliance with the package holiday and LTA rules. 
• Establish a single statutory-backed ombudsman in the aviation sector to ensure consumers can enforce their rights directly without the need to resort to the courts. 
• Review dispute resolution in the package holiday sector to give more travellers access to alternative means of resolving complaints other than the courts. 
• Consider options for an airline insolvency mechanism to ensure consumers booking standalone flights have sufficient protections in place in the event of an airline’s insolvency.

Introduction

You’ve spent months planning the perfect getaway, meticulously selecting your dream destination, hotel, and activities. As the departure date approaches, excitement reaches its peak. You’ve worked hard, saved diligently, and now, it’s time to savour your hard work. But just as you’re about to embark on your much-anticipated adventure, things take an unexpected turn for the worst. Your flight is cancelled at the last minute and you have to find and pay for an alternative way to get to your holiday destination in time which means losing out on the transfer and possibly the hotel stay altogether. Suddenly, the holiday of your dreams transforms into a daunting ordeal. It’s a stark reminder that even in the best-laid plans, the unexpected can happen. 

This is where holiday booking protections become a lifeline. If you’ve chosen a package holiday with robust protections, you’ll find yourself in a far more secure position than if you had booked each part of your holiday separately. You’ll have a safety net to fall back on, and the protections will ensure your well-deserved holiday can still be salvaged. As these important protections are reviewed by the government in an effort to simplify the rules and boost the sector post-pandemic, it is important to evaluate consumer understanding of their rights when booking a holiday to ensure that future changes to legislation provide clear and effective safeguards to travellers.

Yet, our research has shown that many people do not realise that not all holiday bookings offer equal and adequate protection. The key lies in consumer awareness - knowing your rights and what you are protected for - and the effective enforcement of consumer rights. The rules that govern consumer protections can be difficult to navigate for holidays and there is a risk that travellers might inadvertently make choices that lead to financial and emotional distress. These missteps can cast shadows on consumers’ trust in the market. 

When the pandemic-imposed travel restrictions were finally lifted, package holidays proved to be a popular choice for travellers seeking convenience, value for money and the reassurance that they are protected if anything goes wrong with their trip. Beyond their convenience and protection, package holidays took on an additional role. In a climate of soaring prices and cost of living pressures, package holidays became a budget-friendly beacon, offering a practical means of keeping holiday spending in check while providing that extra level of security and confidence for those eager to travel. 

In times of crisis, such as during the pandemic or the collapse of Thomas Cook, the importance of the strong consumer protections that come with package holiday bookings came into sharp focus. The consumer rights granted to package holiday bookings have proved effective in giving travellers clear and strong cancellation rights, and the security that their money would be protected against the holiday provider’s insolvency. But there is scope for improvement as the protections available to travellers need to be more consistent and clearer to enable consumers to make informed decisions when making a booking. 

The package holiday protections were first introduced in the UK over thirty years ago through the Package Travel, Package Holidays and Package Tours Regulations 1992, which implemented the European Directive on Package Travel in the UK. Since then consumers buying package holidays have benefited from a number of important safeguards including financial cover, the right to compensation in the event of cancellation and clear liability rules for the organiser of the package. 

At the time, the traditional package holiday consisted of pre-arranged packages created by a tour operator or travel agent. Innovations in the package travel market brought on by the internet paved the way for major reform of the holiday consumer landscape with the implementation of the Package Travel and Linked Travel Arrangements Regulations 2018 which implemented the updated European Package Travel Directive 2015 in the UK. This major reform sought to expand the scope and definitions of the traditional package to encompass new forms of selecting and booking a holiday while introducing the new concept of linked travel arrangements (LTAs) as a middle-ground between packages and DIY holidays (i.e. booking individual elements separately). However, existing rules can be complex to navigate and there is a risk consumers could be misled or lose money. There is a risk of further exacerbating confusion among consumers if new layers of complexity are introduced to the Regulations with the government proposing to exempt domestic holiday packages and low value holidays as part of its current review of the rules.  

For a number of years, Which? has pointed to the fragmentation of the travel regulatory landscape and the potential for confusion and poor understanding of consumer protections when travelling which can vary considerably depending on how, when and who travellers make a booking with. For example, when booking a holiday online, the rights of the traveller will depend on whether they are selecting travel services from the same or different businesses and whether these are offered and sold at a total price or as individual transactions with separate contracts. 

The refund and cancellation problems consumers and holiday businesses experienced during the pandemic point to a need to review these protections to ensure they are still adequately serving consumers and businesses, and that they coexist well with the other travel consumer protections such as the rights governing flights. As the government reviews European derived legislation post-Brexit, there are clear opportunities to fill gaps in protections and continue to support consumers’ confidence when booking holidays. 

In the context of soaring living costs, and amidst the multitude of booking options that can easily bewilder, there’s a need to empower consumers with the tools to make informed decisions when making these big purchases. It’s not just about informed choices; it’s about ensuring that the regulatory framework adequately protects consumers from potential harm and can be effectively enforced.  

Outline of report

This report details findings from Which? research on consumers' knowledge, understanding and attitudes towards holiday booking protections alongside Which? policy recommendations in these areas. 

Chapter 1: Booking protections. This chapter is dedicated to the protections provided to consumers during the booking process. It begins by examining package holidays and subsequently explores the booking of individual elements for a holiday (DIY holiday) and linked travel arrangements. The chapter ends by looking at the lack of clear information about protections that is made available to consumers at the point that they book their holiday, as well as views on domestic versus foreign holiday booking protections.

Chapter 2: Secondary protections. This chapter looks at the other protections that consumers put in place to protect themselves on their holiday. It focuses on consumers’ understanding of travel insurance cover and how they believe insurance protects them on their holidays.

Chapter 3: Protections in practice. In this chapter we see how consumers think these protections are enforced and work in practice.

Methodology

In the summer of 2023, Which? conducted a two-staged mixed methods research project to uncover what consumers really know about the protections they have when booking holidays. This research had two key stages; a qualitative stage consisting of online focus groups followed by a quantitative stage consisting of an online survey to test the prevalence of consumer opinions with the wider public. Both stages sought to understand the protections consumers think they have and who they think is responsible for implementing these protections when unforeseen problems happen before and during a consumer’s holiday. 

Qualitative research

To explore consumers' understanding of holiday booking protections and what they think happens when things go wrong, we undertook four sets of online focus groups with 31 consumers who had been on holiday in the last three years. We approached an independent recruitment agency, Roots, to recruit participants through a quota system designed to represent the various ways consumers book their holidays (see Table 1).

Table 1: Participants included in the research 

Additionally, participants were chosen to ensure a diverse range of factors, including age, gender, socio-economic status, and household composition. We also strived for a balanced mix of individuals who frequently embark on both domestic and foreign holidays.

The online focus groups were an hour and a half long and were moderated by a Which? Policy Researcher. These sessions were semi-structured, using a topic guide of questions and tools to explore participants’ knowledge and understanding of holiday protections. 

Figure 1: Structure of focus groups

At the start of the focus group, we initiated a discussion on holiday protections. We began by gathering participants’ initial thoughts and understanding of travel protections, including their tendency to purchase insurance for added protection. We provided an overview of key aspects of holiday booking protections, such as insolvency protection, cancellation coverage, and the performance of travel services, which served as the central theme for the remainder of the session. 

We implemented scenario testing of eight holiday booking scenarios in total - two in each focus group session. This included four package holidays (one for each focus group), two bookings with separately booked components, and two linked travel arrangements. Detailed descriptions of these scenarios are available in the annex of this report. To make these scenarios more vivid, we presented video demonstrations of the booking process for each holiday (see Figure 2). 

Figure 2: Screenshot of holiday booking scenario videos

Participants were informed of the two holiday booking scenarios and shown a series of potential issues that could arise before or during those holidays. Their task was to discuss the protections they believed these bookings provided when each of the potential issues happened. The group was divided into smaller breakout groups, with each one assigned to discuss the issues associated with a specific problem. For each problem, participants were prompted to consider three key aspects:

1. What would you do if this happened on your holiday?
2. What do you think you are protected for if this happens?
3. Who is responsible for fixing this problem?

After their discussions, the entire group reassembled, and each breakout group shared their insights with the wider group. The moderator concluded the scenario testing by informing participants about the actual protections in place for each scenario and problem, prompting them to share their reactions and reflections. 

Each focus group session concluded with a reflection exercise where participants shared the lessons they have learnt and any additional thoughts. For the groups that explored both domestic and foreign holiday scenarios (two of the groups), participants were asked whether they believed protections should differ between these two types of holiday.

Which? conducted a thematic analysis of the results to identify common themes in how consumers view and understand holiday protections, as well as their attitudes and feelings towards them. The insights from the qualitative focus groups served as the foundation for the development of our subsequent online quantitative survey. 

Quantitative research

To supplement our qualitative insights and obtain a wider population view on holiday booking protections among consumers, Which? commissioned an online survey conducted by the independent research agency Yonder. The survey was conducted between 18th to 20th August 2023 and was completed by 2,081 UK adults. The results were weighted to be nationally representative. 

The online survey mirrored the format of the focus group sessions. Initially, we gathered information on respondents' holiday booking behaviours, experiences and attitudes. Subsequently, we presented three holiday booking scenarios, encompassing a package holiday, a DIY holiday, and a linked travel arrangement holiday. 

Chapter 1: Booking protections

Summary of findings

1. Consumers are generally good at identifying the protections afforded under package holidays and in turn really value these protections.
2. Consumers can struggle to identify the protections that booking separately or linked travel arrangements (LTAs) afford. A lack of clear information can drive confusion amongst holidaymakers, with them thinking they know what protection they’ve got, when in fact they may be wrong. 
3. Consumers lack awareness of LTAs and are unsure whether these types of bookings count as a package holiday or not. 
4. While some consumers believe that holidays abroad should offer more protections than domestic holidays, the majority of consumers (61%) think that protections should be the same, regardless of location.

Background

Nowadays there are so many different ways in which a holiday can be booked. Each one offers a unique blend of convenience, flexibility, and personalisation. Some people prefer the ease and convenience of ready-made packages or the flexibility to create a tailored experience with a travel agent, while others like the adventure of piecing together individual components and book their holidays independently. But when it comes to deciding on the type of holiday that suits you best, it’s crucial to bear in mind that packages provide a high level of consumer protection and offer you peace of mind compared to other booking options.   

Prior to the research findings, this section provides an overview of the key consumer protections afforded to holiday bookings and the variations in the rules governing packages, linked travel arrangements and the separate selection of individual travel services. 

Package holidays are one of the most popular ways of booking a trip and offer holidaymakers a high level of consumer protection and security if things go wrong. Financial protection for package holiday bookings has a long history in the UK with the ATOL scheme first implemented in 1973 to ensure travellers would not be left stranded abroad in the event their tour operator went bust. At present, package holidays are governed by the Package Travel and Linked Travel Arrangements Regulations 2018 which implemented the 2015 European Package Travel Directive in the UK. The CAA and Trading Standards are responsible for the enforcement of the Regulations, with the CAA regulating flight-inclusive packages through the ATOL scheme and Trading Standards enforcing the rules on packages and LTAs.

According to the Regulations, a package holiday is defined as the combination of at least two or more different types of travel services that are combined or sold as all-inclusive for the purpose of the same trip and purchased from one trader, either online or offline in a shop, paid in a single transaction and for a total price. Packages can be ready-made by the travel business or customised and combined by the traveller to suit their needs and budget. Essentially, a package is formed when booking the combination of two or more of the following services: 

1. Transport, such as flights, trains, cruises and coaches
2. Accommodation, excluding when it is part of the carriage of passengers (eg sleeper trains)
3. Vehicle rental, including car and motorcycle 
4. “Other tourist services” that are not an intrinsic part of any of the above services but make up a significant proportion of the combined value of the holiday. Examples of these services include guided tours, events, spa treatments and ski passes.

Package holidays provide a number of important consumer protections in the event of the organiser's insolvency, changes and cancellations and in case the services you have paid for are inadequate and do not match what you originally booked. In particular:

Insolvency protection:

The Package Travel Regulations place an obligation on tour operators and agents selling package holidays to protect holiday payments by seeking financial guarantees in the case of insolvency. This is to ensure travellers can have their advance payments refunded or be repatriated if the collapse happens while they are on holiday. The ATOL scheme run by the Civil Aviation Authority (CAA) is the key mechanism for protecting flight-inclusive package holidays against the risk of insolvency. Businesses selling non-flight packages have access to various guarantee options for meeting their insolvency requirements, including through ABTA or ABTOT which administer financial protection schemes approved by the Department of Business and Trade (DBT).  

Cancellation and refund rights: 

Consumers have the right to a replacement holiday or to a refund in cases of “unavoidable and extraordinary circumstances” at the destination that would affect the performance of the package. In such cases, the Package Travel Regulations require travel businesses to refund passengers within 14 days of their holidays being cancelled or significantly changed, regardless of whether the travel organiser (be it a tour operator or travel agent) has received the money back from suppliers, such as accommodation providers or airlines.

In addition, consumers have some flexibility in cancelling the package holiday contract and are entitled to a refund subject to a termination fee. 

Performance of the package:

The package organiser, who combines and sells packages, is fully responsible for the performance of all the travel services included in the booking. If something goes wrong with the holiday and the traveller experiences inadequate service provision with either the package organiser or one of the suppliers at fault, consumers should contact the organiser in the first instance and expect that the issue is resolved. 

Additional benefits to consumers buying package holidays include the right to clear information when buying a package and protection against price increases. 

Linked travel arrangements (LTAs) are a looser combination of travel services. Unlike package holidays, they are the separate selection and purchase of travel services for the purpose of the same trip. Consumers have been increasingly creating their own customisable holidays by purchasing individual components separately - which is in part due to the rise of the low cost airline model offering travellers access to greater choice. The addition of LTAs in the 2018 Regulations was an attempt to capture changing holiday booking habits by providing greater protection to consumers who choose to book individual elements separately, as well as to ensure a level playing field among businesses selling holidays in this sector whose products might otherwise fall outside the scope of the Regulations.

There are two ways in which LTAs can be created, these are described in the Regulations as Type A and Type B:

Type A: During a single visit to a travel agency or online travel agent, a consumer selects and pays for one service from a holiday provider and then decides to add another, but the payment details and related information is not transferred and needs to be provided again with the consumer entering separate contracts for each of the services selected. For example, a consumer visits an online travel agent website and books and pays for a flight. Without leaving the website, they select and pay for another service such as a hotel or car hire. 

Type B: A consumer selects and books a service from a travel company's website, and following receipt of the booking confirmation the consumer is offered another element which needs to be selected within 24 hours from the initial purchase. For example, a consumer books a flight from an online travel agent. The email containing the booking details offers links to other services, such as car hire or accommodation,  prompting the consumer to click through and book another service within 24 hours from booking the flight. It is worth noting that if the consumer information and payment details had been pre-populated, then this would not be an LTA but a package. 

Consumer protections for LTAs are weaker than those that come with package holiday sales. Indeed, insolvency protection is only required for the first business facilitating the separate selection of services. In addition, if the facilitator of the LTA provides transport to the consumer, they also need to provide repatriation cover in case of their insolvency. Using the Route B example above, only the airline is required to provide insolvency protection. Unlike packages, the business facilitating the LTA is not responsible for the performance of all the services booked by the traveller but only for the service they provide. 

Finally, consumers creating a holiday by booking individual travel services separately do not benefit from the important protections contained in the Package Travel Regulations with respect to insolvency, cancellations or the performance of the holiday services. Instead, they have to rely on other consumer legislation such as the air passenger rights provisions contained in Regulation EC261/2004 in case of denied boarding, delays or cancellations affecting flights and Section 75 of the Consumer Credit Act if the booking was paid using a credit card or their travel insurance policy. There are some cases where flight-only bookings can be protected by the ATOL scheme and benefit from insolvency protection, when these are sold by third party sellers rather than directly from an airline, and when the flight ticket is not issued immediately after the booking. 

1.1 Package holidays 

Package holidays offer holidaymakers the convenience to book multiple parts of their holiday under one seamless transaction, courtesy of the same travel organiser. This comprehensive approach not only eases the planning process but, crucially, it can instil peace of mind for consumers, knowing that all elements of their holiday are planned and booked, and importantly is backed by the package organiser’s commitment to be responsible and ensure everything runs smoothly. 

Our research found that consumers were well versed in identifying; (i) what the holiday booking type was, (ii) the specific protections these holidays provided, and (iii) the business responsible for fixing things that may go wrong on or before these holidays.

Consumers know when they book a package holiday

The majority of consumers were able to recognise that booking multiple elements of a holiday together classed the holiday as a package. In our online survey, we presented respondents with the package holiday scenario to Venice, however, unlike in the focus groups, we did not inform them that it was classed as a package holiday (see scenario 2A in the boxes below [1]): Three in four (75%) respondents correctly identified that the booking is classed as a package holiday. 

Examples of holiday problems presented:

During the scenario testing we explored what the term ‘package holidays’ meant to participants in our focus groups. They said the term ‘package holiday’ instilled a sense of security and peace of mind. These quotes highlight participants’ awareness of the protective aspect of package holidays.

“Package holidays provide peace of mind and are easier”

“If you have a package holiday it will kick in if something went wrong”

Consumers know that package holidays mean they are well protected

When a consumer books a package holiday - say, a 10-night all-inclusive getaway to Malaga, complete with flights, accommodation, and meals - they enjoy comprehensive protection that blankets their journey from start to finish (see Table 2). Our research revealed that consumers had a high degree of certainty regarding their protection in cases where the holiday provider (61%) or airline (55%) faced financial difficulties, or if a component of the holiday was cancelled (57%) (Figure 3).

Table 2: Package holiday protections

However, there was less confidence in their protection if the service didn’t meet the promised standards, such as receiving a room without a sea view when they initially booked a room with one. A smaller proportion, four in 10 (39%) correctly identified they would be protected against inadequate service provision (Figure 3). 

Overall these figures showed that consumers generally have a good understanding of what problems they are protected for in package holidays and this is likely to be reflected in their real life purchase decisions when booking holidays of their own.

Figure 3: Consumer understanding of protections given for a package holiday booking 

When looking specifically at protections against insolvency, participants in our focus groups did a good job at recognising that they would be protected for this, both before and during their holiday. 

We presented a scenario in the focus group where participants had booked a package holiday to Scotland, involving train travel and accommodation within the country (see Holiday scenario 1B). In the event of the package organiser facing insolvency a week before the trip, participants felt that their money would be fully protected. Some remained hopeful that the holiday would still be able to take place if the providers of the individual elements of the holiday had already received their money. However, where this was not the case they expected to receive a full refund.

In the event of the package organiser facing insolvency during their holiday, be it the travel organiser or an airline (if different to the travel organiser), participants felt strongly that they would be supported to get home safely (see Holiday scenario 2A) - which is the case.

“They should be doing all they can to get you on another flight.”

Consumers know who is responsible when things go wrong

If the package holiday scenarios were disrupted by travel cancellations, participants all (correctly) agreed that alternative travel arrangements would be offered and provided. Consumers were also knowledgeable and knew that the travel organiser bears the responsibility for fixing the situation. This was particularly true for the train holiday around Scotland where we presented participants with the problem of their train operator cancelling the train they were due to take (see Holiday scenario 1B).

In this instance the online travel agent who organised the package holiday would be responsible for arranging alternative travel. All participants (correctly) agreed that the online travel agent is responsible for arranging other travel for them, “it is the holiday operator's responsibility”. This also came through in our holiday booking to Venice when the airline went bust mid-way through their holiday; “[the] package providers are the ones that should take responsibility for it.” (see Holiday scenario 2A).

These examples clearly demonstrate that consumers understand that the travel organiser bears the full responsibility for ensuring the satisfactory performance of all travel services included within the package holiday booking.

Consumers value package holiday protections

Following the scenarios testing in both our focus groups and online survey, we provided information about the protections associated with each package holiday booking (excluding insurance and credit card protections). We then sought their reactions, encompassing steps 4 and 5 outlined in Figure 4.

Figure 4: Process for holiday booking scenarios in focus groups

For the Venice package holiday, almost 8 in 10 (79%) UK adults thought that the amount of protection provided for the holiday was fair. This was also mirrored in the focus groups with participants really valuing these protections, with the theme of fairness being strongly felt across the groups. A strong element of this fairness for certain participants was that they expected these protections to be in place when the problems discussed occur. 

“Package holidays provide peace of mind and easier.”

“They are adequate, that is what I would expect as a consumer.”

“Adequate response to what you would expect around compensation and rearrangements.”

There were a few participants who were surprised by the level of protection benefits provided by package holidays, as they were previously unaware of them. As previously shown in Figure 3, one in 10 (11%) thought that this package holiday would not protect against insolvency, cancellations or the performance of the package services in the absence of insurance or credit card protections and a further 12% said that they did not know. This will be revisited in section 1.4, looking at the lack of clear information regarding booking protections when consumers make their holiday bookings. 

“I didn’t know you were covered that much for package holidays.”

“I wasn’t aware of the benefits that package holidays provided.”

This theme of participants really valuing package holiday protections became even more pronounced when they compared them to the protections provided by other booking types, such as LTAs. In one of the focus groups, we presented the package holiday scenario (Holiday scenario 2A) and informed participants that they would be protected against insolvency and cancellations. Following this, we introduced the LTA holiday scenario (Holiday scenario 2B), specifying that LTAs offered fewer protections compared to package holidays (see section 1.3 for specific details). This disclosure triggered a lively response among participants, who unanimously concurred that booking a package holiday was the superior choice as it provided considerably more protection compared to LTAs. 

Participant 1: “Book a package holiday”

Participant 2: “Package holiday”

Participant 3: “Package holiday”

Participant 1: “Livid!”

Participant 4: “It makes more sense going for the package”

Participant 5: “Everytime, everytime”

This showcases the high value consumers place on the protections provided by package holidays, especially when contrasted with another booking type (like LTAs) that offers fewer protections. Consumers’ strong preference for package holidays is evident in their recognition of the superior protection these bookings provide, enhancing their peace of mind and security when planning their trips.

Some consumers are pessimistic about the ease of seeking redress

Despite the reassurance and fairness consumers felt towards package holiday protections, some were pessimistic about the ease and speed of receiving the refunds and alternative arrangements they are entitled to when faced with unforeseen issues during their travel. One participant summarised this well on behalf of the focus group:

“Mistrust. All these protections are in place but [...] from past experience the travel company can be really really difficult to get them to do what they should do. Mistrust that you would get what you want. It requires a lot of effort and perseverance and can be quite upsetting.”

This suggests that, while consumers value these protections and think they are fair, some are sceptical about their practical functionality (i.e. how they operate) when needed. Such scepticism can lead to various consumer drawbacks, ranging from questioning whether making a claim is worthwhile and losing out on entitled compensation to experiencing stress and anxiety during the claims process. We will explore this in more detail in Chapter 3.

1.2 Booking individual travel services separately (DIY holidays)

While many holidaymakers like to book package holidays, others enjoy the flexibility and personalisation of booking individual elements separately, e.g. a flight booked directly with an airline and hotel booked directly with the hotel. Two scenario tests fell into this category (excluding the LTA scenarios), Holiday scenario 1A and 4B. Our research found that consumers were surprised and angry at the lack of certain protections afforded for these holidays. While some focus group participants said that they would not book holidays in this manner in the future due to this lack of protections, others said that they like booking in this manner and the flexibility it gives. 

Examples of problems arising on each holiday asked about:

Consumers were surprised and angry at the lack of protections

Throughout the testing of these booking scenarios and their problems there was surprise and anger at the lack of certain protections these bookings provided. This was driven by many participants thinking that they knew what the protections were when they were in fact incorrect. 

In our online survey, four in ten (40%) consumers said they knew what protections they are provided with when booking independent holidays, yet when we asked about specific protections a lot of them got this wrong. A third (32%) of these consumers thought that the holiday booking scenario to Malaga (Holiday scenario 1A) was ATOL protected. Additionally, 40% of them thought they would be protected against the airline going bust, while 23% thought they would be protected against the hotel going bust. 

These are all incorrect; when booking individual services of a holiday with different providers it doesn’t protect the consumer in the same way as a package holiday. A holiday of this type would not be ATOL protected nor provide protection against the airline or hotel going bust (see Table 3). 

Table 3: Booking individual elements separately holiday protections

The focus groups with this type of booking mirrored the findings of the nationally representative survey. The first focus group was given the booking scenario of making a flight booking with an airline to Malaga and then separately booking their hotel accommodation. They were given three different insolvency situations, shown under Holiday scenario 1A. 

When an airline goes bust at any stage of the holiday in this booking scenario, consumers' money will not be protected. When we informed participants of this and that they would have to arrange different flights for their return, they were very surprised.

“I am surprised [at] how little protections there are for non-packages holidays.”

A significant driver of this reaction seemed to be that participants expected their answer to be correct.

“I didn’t realise that if a flight company goes bust, insolvency isn’t included in compensation.” 

“I didn’t realise for how little you are covered.”

This, in turn, generated anger which one participant summarised well on behalf of the group. 

“I actually feel quite angry after this that as a consumer there isn’t any plan in place for insolvency for airlines. If we are parting with our hard earned money then why are we not protected at all. It’s put me off booking separate things”

This negative sentiment was also reflected in our online survey in which half of UK adults (52%) felt that the protections afforded for a holiday of this type were unfair. Only 17% of UK adults felt that these protections were fair. These figures are concerning as they highlight how many consumers feel these protections are insufficient, likely stemming from many of them thinking this holiday would offer greater protections. 

Many consumers are likely to be unaware of their lack of protections

As the final sentence in the previous quote highlights, “it’s put me off booking separate things”, learning about the lack of protections afforded resulted in some participants expressing their unwillingness to book these types of holidays in the future. One participant talked about how a past experience of theirs has influenced their booking tendencies:

“I had a bad experience last year from booking separately and wouldn’t book like that again. [The Airline] had taken people’s money for this flight and only then told everyone it was cancelled and [they] would have to rebook their flights. I would now only book a package.”

Despite learning about the lack of protections afforded for separate bookings, some participants maintained that they would continue to book their holidays in this manner as they like the flexibility and personalisation that booking separately affords them.

“I prefer to book separately. We like to drive our car to go on holiday and for that reason [we] like to book everything myself.”

“I quite like doing things separately, mixing things up.”

This section has shown that many consumers are booking holidays separately whilst unaware that booking in this way is leaving them vulnerable to a lack of protections. While some participants within our research, on learning the lack of protections, said they might consider changing their booking practices, many consumers making these bookings in real life are likely to persist in their current practices, unaware of the gaps in their protection until a crisis unfolds. This situation places thousands of consumers at serious risk of facing financial distress but also emotional turmoil as they seek to salvage their cherished holidays, all while vital booking protections remain out of reach.

Consumers questioned the lack of flight-only protections

A number of participants identified this precarious situation that many consumers could find themselves in and questioned why individual flight bookings were not protected against insolvency in the same manner as package holidays.

“Why can’t there be some universal coverage, whether you buy a package holiday or not you should be covered regardless. There should be something covered in what you pay.”

“If everyone paid an extra £1 on their flight tickets that would sort it out.”

“For big airlines you really should have some level of insurance. If something happens to those companies that have a massive reputation you should have some level of protection as a consumer as they haven’t fulfilled their duties towards you. When you are paying this money it is like you are signing a contract with them. They should have some level of accountability. If something goes wrong on their side they should be accountable. Consumer rights should be looked into.”

Recommendations

As this research shows, consumers often find themselves in the dark about the limited protections when booking individual elements of a holiday separately. This knowledge gap can leave them exposed to financial and emotional detriment if something goes wrong before or during their trip. It is important to promote consumer awareness of their protections when booking individual travel services, and consideration should be given to how information is provided at the point of booking. This is particularly important when it comes to booking flights with online intermediaries, as the rules regarding refunds rights and legal responsibilities can benefit from clarification. 

A key government proposal to enhance protection for travellers is to establish an insolvency framework for airlines so that standalone flight bookings benefit from the same refund and repatriation mechanism of package holidays in case the airline becomes insolvent. Which? have long called for a review of the financial protections available to air passengers that make individual flight bookings. At present, travellers affected by an airline insolvency have limited protection and have to rely on secondary measures to protect their payment against this eventuality, such as getting a travel insurance policy that specifically covers scheduled airline failure, known as SAFI, or seek a refund through their debit or credit card provider. Crucially though, travellers in these circumstances who still need to travel or require repatriation have to organise and pay for alternative arrangements independently which can come at a significant expense. 

The high-profile collapses of Monarch Airlines in 2017 and Thomas Cook in 2019 required significant government intervention at public expense to repatriate thousands of passengers stranded abroad, whether they were protected by the ATOL scheme or not [2]. As a result, the government commissioned a review of passenger protections which, among its recommendations,  urged the government to introduce an airline insolvency mechanism to ensure the timely compensation and repatriation of passengers whose return flight was booked with an airline that becomes insolvent while they are abroad. It also highlighted the need to raise awareness among passengers and for businesses to actively inform them when they are not protected at the time of booking. 

No progress has been made on these proposals since the announcement for an Airline Insolvency Bill in the 2019 Queen’s Speech. As the Civil Aviation Authority (CAA) makes progress on a reform of the ATOL scheme that aims to strengthen the ATOL holders’ financial health and enhance consumer protections, there is an opportunity to consider alternative measures for protecting passengers such as extending the scope of the ATOL scheme to include airline flight-only bookings. 

The government should: 

• Consider options for an airline insolvency mechanism to ensure consumers booking standalone flights have sufficient protections in place in the event of an airline's insolvency.
• Assess the benefits of requiring travel businesses to inform their customers of what protections do not apply when booking standalone services to help them make informed decisions. 

1.3 Linked travel arrangements

The final type of holiday booking we tested in our research were linked travel arrangements (LTAs). An LTA is when a consumer buys one service from a holiday operator and is then prompted to buy another service, but their information and payment details aren’t transferred. We included one Type A LTA (see Holiday scenario 2B) and one Type B LTA (see Holiday scenario 3B). Our research found that consumers (i) lack awareness of LTAs, (ii) are unsure whether these types of bookings count as a package holiday, (iii) are unsure what protections are provided, and (iv) do not know who they would go to if something went wrong. 

Again, following the presentation of each holiday booking, participants were given a number of problems shown below that could arise on each holiday and asked to discuss using the following questions:

1. What would you do if this happened on your holiday?
2. What do you think you are protected for if this happens?
3. Who is responsible for fixing this problem?

Examples of problems arising on each holiday asked about:

Consumers lack knowledge about LTA protections

Similarly to the previous section on booking individual elements of the holiday separately, a significant proportion of consumers wrongly thought that they were protected under this booking type. In our online survey, 31% of consumers incorrectly thought that the Type A LTA holiday offered protection against airline insolvency and 1 in 4 (24%) incorrectly thought it offered protection against hotel insolvency.

Concerningly this shows that many consumers could be booking LTA holidays, oblivious to the fact that their holiday may not be protected against insolvency. An LTA holiday booking doesn’t protect the consumer in the same way as a package holiday. A holiday of this type would offer limited insolvency protection; holidaymakers only have protection against the insolvency of the travel business they made the initial booking with, not the individual service providers [3]. An LTA holiday also doesn’t offer the same protection for the performance of the travel services that package holidays do. With many consumers unaware of this or misinformed, they are at serious risk of financial and emotional detriment if the travel business they are dealing with faces insolvency, leaving them to pick up the pieces of their holiday alone. Our online survey found that almost half of consumers felt that the protections provided under the Type A were unfair (47%), while only one in five (21%) thought they were fair. 

Table 4: Linked travel arrangement holiday protections

Consumers were unsure who they would go to

A key element of the lack of understanding of the protections for LTAs was that participants were unsure who they would go to, or in other words, who is responsible for certain elements of their holiday, given the nature of how their booking was made. In our focus group that was given a Type A linked travel arrangement, they were presented with a scenario of the airline going bust before the holiday starts.

In this scenario participants weren’t sure whether they were best to contact the airline or the online travel agent. 

“[Our group] would contact the website and see what they can do and then we would also contact the airline as we believe they would be primarily responsible and see if we were ATOL protected and if they could assign us to another flight.”

This confusion was also the case for the Type B linked travel arrangement (Holiday scenario 3B). 

In this situation of making it on holiday and discovering that the hotel was closed due to going bankrupt, some participants felt they would be best placed to contact the website they made the payment through, while another participant thought that they “would be looking at ATOL”. This raised a discussion amongst a small group of participants over whether the airline bore any responsibility for the hotel booking given they facilitated the booking through the email they sent to the holidaymaker advertising the hotel. 

Not knowing who to contact when problems arise can delay the possibility to remedy any issues and further panic holidaymakers when they are already in a stressful situation. Having to salvage their holidays, especially if they are already abroad, can leave consumers vulnerable to spending more money to save themselves, money that they may not have, to get back to their home. Many consumers would find it emotionally draining contacting a travel company when something goes wrong, only to be told it is not their responsibility.

Drivers of consumers’ lack of understanding of LTA protections

Taking a step back, it was clear during the focus groups that two of the main drivers for the lack of understanding of the protections amongst participants were that;

• firstly, there was a lack of awareness of LTAs, and 
• secondly, confusion whether these types of booking counted as a package holiday or not.

 Looking firstly at lack of awareness, almost none of the focus group participants had ever heard of the term ‘linked travel arrangement’. This lack of awareness also came across in our survey in which the majority (63%) of UK adults said they had not heard of the term ‘linked travel arrangement’ before (13% had and 24% were not sure if they had). It is unsurprising that the vast majority of consumers have not heard of the term before as holidays are rarely advertised in such a way. This can burden consumers who may try to research the protections their holiday booking affords, coming across a new term which they are unfamiliar with and unsure whether it relates to their booking.

Other consumers may question whether their holiday constitutes a package holiday when they are making or have made an LTA booking. This question was a crucial factor in one focus group’s discussion of the protections afforded for the Type B LTA where the airline emailed the holiday booker advertising hotel options. When asked to feed back whether their smaller sub-group thought that this holiday provided protection against the airline going bust before the holiday started, a member of the group said:

“We were unsure whether it fell into the category of a package holiday, it would obviously depend on the actual booking because obviously the airline sent you a link which you booked your hotel through. Whether it would be a third person booking or fall into [a package holiday]. And it would be more protections if it was a package holiday but we were unsure whether it would be that.” 

This summary from the participant shows that a booking like this, without clearly clarifying exactly what the booking type is or protections provided, creates a level of burden on consumers to work out whether they are booking a package or not. 

“I really wasn’t aware of the differences. This has made me a lot more work.”

By extension, this means that many consumers might believe that they have booked a package holiday when in fact they have booked an LTA, leaving them less protected than they would think they were. 

Consumers were upset and angry at the lack of protections

The reaction of participants when informed of the LTA protections, or better said the lack of protections, were strong and emotional, much more so than the DIY holiday reactions (section 1.2). Participants felt upset, vulnerable, concerned and angry when they were informed what would actually happen under each of the problems arising. Figure 5 illustrates some of these reactions.

Figure 5: Participant reactions to LTA protections

There was also a level of deception felt by one participant. They felt that the term linked travel arrangement shows that holiday operators are aware the different parts of the booking are linked and therefore they should bear more responsibility for other elements of the booking; 

“They are using the term linked loosely here. If they are saying it is linked then [the airline who facilitated the hotel booking] should help you with the accommodation [if the flights are cancelled].” 

These reflections by participants, and the lack of knowledge evidenced previously, shows that linked travel arrangements in their current form create a landscape of confusion, burden and vulnerability to consumers, leaving them at risk of consumer harm. Not knowing what type of booking they have made or who to contact when problems arise can leave holidaymakers vulnerable as they look to fix difficult and stressful situations. If they thought they knew who to contact, only to be told that they are not protected or the company isn't responsible, this could be emotionally and psychologically damaging. These situations can lead to consumers facing a distressing dilemma, one where they must reach deeper into their pockets to secure their own well-being, sometimes without the financial means to return home. It's a nightmarish scenario, and it's easy to understand why many consumers may find themselves feeling a sense of helplessness when caught in the web of a troubling LTA holiday.

Recommendations 

The view across the industry and government is that LTAs may be too complex, difficult to enforce and confusing for consumers. A recent stakeholder poll from the Chartered Trading Standards Institute (CTSI) suggests that this definition is also problematic for the travel industry and regulators, and holiday companies may not always realise if they have facilitated an LTA and what protections should apply to the traveller. Likewise, it is difficult for consumers and enforcers to demonstrate that the different services selected as part of these arrangements were in fact linked and facilitated in a targeted manner.

Not only are LTAs confusing, but it is not possible for the traveller to know whether and at what stage their money is protected when booking an LTA, as it depends on whether and when the facilitator has passed on their money to the service providers [4]. For example, looking at the holiday scenario 2B, the insolvency requirement only applies to the facilitator of the LTA, which in this case is the online travel agent. If the facilitator goes bust, the traveller is protected and will either receive a refund (if the money wasn’t passed to the service provider) or they will be able to go on their holiday as planned as the insolvency does not affect the service providers. However, if the service provider goes bust and the facilitator has already passed on the consumers’ money to them, then there is no protection and the traveller will be out of pocket and unable to go on their trip. 

The difficulty in identifying LTAs can lead to potential abuse with ‘flight-inclusive’ LTAs - the loose definition of LTAs, and the fact that they are difficult to prove, may lead to businesses offering products that may appear as LTAs, when in fact they are packages. If it can be shown that after buying a flight, a consumer receives an email with a link that enables them to select and purchase a hotel room or other service within the relevant 24 hour period, then this would appear to be an LTA. However, we have seen examples in the past where a consumer is able to purchase a flight and accommodation or other services together in a single transaction without having to re-enter their details more than once, yet the service is not defined by the facilitator as either a package or an LTA. 

At present, the government is considering options to simplify, retain or remove the definition of LTAs from the Package Travel Regulations as part of its proposed post-Brexit reform of package holiday legislation. 

The introduction of LTAs was a strategic move to safeguard against businesses finding creative ways to avoid complying with the package rules. By incorporating LTAs into the framework, it served as a countermeasure to ensure consumers enjoyed a certain level of protection. However, the prospect of removing LTAs from these rules and stripping away any consumer protection opens the door for businesses that may potentially exploit this gap to avoid the more robust requirements that package organisers are subject to. Any change to the Regulations should ensure that holiday businesses are not encouraged to take advantage of LTAs in order to have fewer consumer obligations and avoid liability should things go wrong.

The government should: 

• Reform the rules on LTAs and their definitions to prevent businesses from circumventing the package holidays obligations, ensuring that consumers continue to benefit from high levels of protection as the market develops and new business models emerge. 

1.4 Lack of clear information and confusion

This chapter so far has evidenced that consumers are quite adept at recognising the protections that come with package holidays, and they really value these protections. However, a different story unfolds when it comes to identifying the protections associated with booking separately or LTAs. Some consumers struggle to identify the protections and, in turn, many feel the lack of certain protections is unfair. One of the causes of this disparity is the lack of clear information during the booking process, leaving consumers with a false sense of security. In many cases, they believe they’re well-protected, when, in reality, they lack a clear understanding of the protections they truly have.

The lack of clear information at the point of booking works both ways; there is a lack of information when holiday protections are not provided but also a lack of information for holidays such as package holidays that do provide consumers with protections against insolvency, cancellations and inadequate service provision. This was evidenced in our focus groups in which one participant called for greater transparency regarding a lack of protections.

“There should be more transparency on websites. Even if it is just bullet points saying that are you aware if you book this you are only covered for x,y,z.”

Conversely, the previous section on package holidays showed that many consumers are unaware of the protections afforded. This was directly raised by one focus group participant showing that package holiday providers can do more to promote their protections.

“I wasn’t aware of the benefits that package holidays provided.”

Currently, a lack of clear communication can leave consumers unsure whether they need to purchase secondary protection, such as insurance, to ensure they are protected against things going wrong before or after their holiday.

“It is difficult to know when things have insurance policies or protections within them or if you need to get them separately.”

Improved communication surrounding protections at the point of booking, in regard to both the presence and the absence of certain protections, could support consumers’ understanding of their protections and knowing whether they need to purchase secondary protections for their holiday.

Recommendations

Travel businesses are required to give their customers a set of specific pre-contractual information about their holiday and the statutory consumer rights that apply when selling packages and LTAs. However, our research shows that consumers would benefit significantly from clear, concise and upfront information when they embark on the booking journey. Improving the way information is presented would empower consumers to better understand the level of consumer protection they are entitled to. As part of its review of the Package Travel Regulations, there is scope for the government to improve the information and wording requirements on businesses to ensure it is consumer friendly. 

While the Package Travel Regulations establish information requirements for businesses selling packages and LTAs, there are currently no requirements on these same businesses to provide information to consumers when selling individual travel services. 

The government should:

• Review the information requirements on businesses to ensure consumers are given clear, prominent and consumer friendly information. 
• Consider the benefits of requiring travel businesses to inform their customers of what protections do not apply when booking individual travel services as opposed to packages to help them make informed decisions. 

1.5 Domestic holidays

The Package Travel Regulations apply to all package holidays and linked travel arrangements sold by UK businesses whether they take place in the UK or abroad. This has been the case since package protections were first introduced in 1992. Consumers value the protections provided by package bookings because, as reflected in this research, these rules give them confidence that their money will be protected, and in case of problems, their package organiser will make sure the holiday can go ahead as planned.

Currently, the government is proposing to exempt domestic packages from the rules. This would mean that people choosing to holiday in the UK would no longer benefit from the insolvency protections or the strict liability rules placed on businesses for ensuring the proper performance of the package. CTSI has also expressed concern about these proposals, pointing to consumer complaint data from Citizens Advice. This shows that more complaints have been made for UK holidays (2,636 complaints) than overseas holidays (2,244 complaints) between January and August this year [5].

Most consumers don’t know if the current system is the same or different but felt they should be the same

In our survey we asked respondents whether they thought UK holidays provide more or less travel protections than holidays abroad. The majority of consumers did not know that the protections are currently the same, with only 28% correctly identifying that they offer the same protections. Just over 1 in 10 consumers (12%) thought that UK holidays provide more protections, while just over 2 in 10 consumers (22%) thought that holidays abroad provide more protections. Almost 4 in 10 (38%) of consumers said they did not know. 

Despite most consumers not knowing the current system, the majority of consumers think UK holidays should provide the same  travel protections as holidays abroad. 6 in 10 (61%) consumers said that they think the protections should be the same, while a much smaller proportion thought that holidays abroad should provide more protections (19%) or that UK holidays should provide more protections (5%). 

Figure 6: The majority of consumers think that UK holidays should provide the same protections as holidays abroad

Some consumers felt that holidays abroad pose a greater risk

As mentioned previously, almost 2 in 10 UK adults (19%) thought holidays abroad should provide more protections than holidays in the UK. Those who thought this said that being abroad throws up more risks to consumers, hence why they should be provided with more protections.

“I think there is more at risk with foreign holiday travel where you are miles from home in a foreign country hence more of a requirement to take out enhanced cover compared to holiday in home country.”

The risk of medical emergencies and being stuck in a foreign country were some of the risks mentioned.

“You may need to be repatriated if there is a problem in a foreign country. Complications may arise if you have a medical emergency. There is more risk with diseases etc”

“Usually you have paid more, and generally you're using the airports services for a longer period of time when going abroad. There's greater risk of injury and losing items etc if going further away than the UK as well.”

Participants also raised the issue with foreign holidays, depending on the location, that they may not speak the local language. This can leave consumers more vulnerable when something goes wrong as they find it harder to seek help and support from local businesses or people.

“My expectations are different. Holiday in the UK I can manage. If abroad, [I may not] speak the language, I need more help.”

“You may need more help and support when abroad, don’t speak the language etc. In the UK it is a lot easier”

However, the majority of consumers felt that the protections should be the same for a multitude of reasons

Conversely, 6 in 10 consumers said that they think the protections should be the same (61%). There were a number of reasons consumers gave for this sentiment. Firstly, as the below quotes demonstrate, respondents flagged that the same issues can arise on domestic holidays.

“Because holidays abroad and holidays in the UK require the same cover, for example cancellations of transport, especially trains; accidents; accommodation cover being unfit for purpose, etc.”

“Because regardless of where you are, you can still have issues in travel that may need compensating”

There was also the feeling that companies' responsibility should not change depending on where their services are delivered.

“You should be entitled regardless of where you are”

“Whoever is providing the travel has a duty to care to protect their customers from harm. It should be the same whether it be in the UK or abroad.”

A number of participants raised the point that UK based holidays can still be as expensive as foreign holidays and hence consumers should be treated the same.

“The costs involved for holidays in the UK and abroad can be similar so why shouldn't you get the same protection.”

Finally, participants also mentioned the importance of not adding to the confusing landscape of holiday protections and creating split protections making it harder for consumers to navigate. 

“Because one shouldn’t offer more protection than the other - I want to know that regardless of where I am, I get the same treatment.”

“I just feel it just confuses people and they feel cheated if it's not the same.”

“To avoid confusion, to have [a] clear sense of understanding, to feel confident knowing it's been looked after, to enjoy [your] holiday without worrying about protection.”

This section highlights a difference in consumer perspectives. Some consumers feel that they should be offered greater protections when travelling abroad as they are likely to find themselves in more vulnerable situations when problems arise. The majority of consumers however feel the protections should be the same for multiple reasons; the same problems can arise, companies' responsibility should not change, UK holidays can be just as expensive and divergence in protections would make it harder for consumers to navigate the already confusing landscape of holiday protections. 

Recommendations

As participants in this research highlighted, while some risks commonly associated with holidays abroad, such as being stranded and needing repatriation, may be less of an issue in the UK, domestic holidays are not always cost-effective. Moreover, given the nature of these holidays, involving several parties providing different services, they can lead to complex disputes if something goes wrong. It is therefore important for consumers that the organiser of the package continues to maintain responsibility for the delivery of the different travel services.

Consumers clearly benefit from, and appreciate, having a set of holiday rights that are clear and consistent regardless of where their trip takes place. By creating exemptions to the rules and removing protections for domestic package holidays, there is a risk of undermining consumers’ confidence in the package holiday sector. Travellers would face a more confusing and fragmented landscape. Arguably, excluding some holidays from the rules is bound to bring more legal uncertainty for consumers and businesses.  

It is crucial that the long-standing holiday protections UK consumers benefit from are not watered down in an attempt to deregulate the domestic holiday market. Consumers booking domestic holidays are vulnerable to business insolvencies in the same way as those buying overseas holidays, and as such they should continue to benefit from the insolvency protections afforded by the current rules, particularly in the context of the rising cost of living and as more people are choosing to holidaying in the UK rather than abroad. Likewise, consumers need to have confidence that the different elements of their holiday package will be delivered as described, and that the travel organiser, who is taking payment for the various services, is responsible for their performance should things go wrong. 

The government should:

• Ensure that domestic packages remain in the scope of the Package Travel Regulations, maintaining high levels of consumer protection for travellers irrespective of the location of their holiday. 

Chapter 2: Secondary protections

Summary of findings

1. Many consumers view insurance as the primary means of protection for their holidays.
2. Insurance was the most common word that came to respondents' minds when asked what ‘travel protection’ means to them.
3. There is a serious risk however if consumers think that their insurance covers them for more than it actually does.

Background

In the world of travel planning, where the unexpected can be just around the corner, a savvy traveller knows the importance of an extra layer of protection. That’s where travel insurance and credit card payments come to the rescue, offering a safety net when other consumer protections may not apply.  

Where possible, consumers should pay for their holiday using a credit card so they can benefit from the financial protection under Section 75 of the Consumer Credit Act. This establishes that the credit card provider shares the same legal responsibility as the trader in case the services can no longer be provided. If the holiday company pulls the plug on your long-anticipated  trip or becomes insolvent, you hold the key to a possible refund directly from the card company as long as the payments are worth over £100. However, credit card protection is not helpful if you’re stranded abroad due to a company’s insolvency and need assistance with repatriation.

When you’re gearing up for an exciting  holiday, it is always advisable to get a good travel insurance policy at the time of booking. There are some protections that only insurance can provide. It’s there to protect your personal belongings from any unexpected mishaps or to cover those unforeseen medical emergencies or those dreaded hospital bills while you’re far away from home in a different country (which can be very expensive and can quickly drain your wallet). 

Some travel insurance policies can even provide cover whether it’s the cancellation of your dream vacation, travel disruption or the unexpected insolvency of your airline or holiday provider. These can be a helpful complement to the statutory consumer rights that come with package holiday bookings. However, as other consumer rights apply to these circumstances, making a claim may not be as straightforward when you are entitled to other means of redress, such as from the airline or package organiser. It’s like having multiple safety nets; sometimes finding the right path to rescue can feel complex to navigate. 

Many consumers view insurance as the primary means of protection for their holidays

Excluding insurance and credit card protections impacted participants’ thinking

In our research, we explored booking protections in Chapter 1 and uncovered a common thread: consumers often struggle to identify the protections provided under different booking types, especially when it comes to holidays where individual elements are booked separately or LTAs. For package holidays, the picture was a bit clearer and consumers were better at identifying the protections afforded. But a sense of surprise lingered among many consumers as they grasped the depth of protections available. 

As we delved deeper in our focus group discussions, it became evident that one of the driving forces behind these consumer revelations was the disclaimers provided asking participants to exclude insurance and credit card protections.

The focus of this research project was to explore consumers’ knowledge and understanding of holiday booking protections, i.e. the protections they are afforded when they make their booking that the travel business is responsible for if something goes wrong before or during their holiday. Asking focus groups participants to exclude insurance and credit card protections from their thinking allowed us to focus on the protections that come with each holiday booking. However, through running the focus groups and online survey in this manner, it highlighted that many consumers view insurance as the primary means of protection for their holidays. 

Participants often returned to insurance throughout the scenario testing

For two of our focus groups, after learning the protections afforded under the holiday bookings asked about, a number of participants mentioned insurance in their main takeaway from the session. In one focus group participants were given two holiday scenarios, a booking of individual elements separately to Malaga and a train-travel package holiday around Scotland. 

When asked to reflect on the session and if anything they have learnt would change how they book their holidays in the future, a number of participants said that they would continue to protect their holidays through insurance cover and view this as their primary means of protection. 

“I am going to keep buying travel insurance no matter what kind of holiday I book, for peace of mind if anything.” 

“I always make sure we get good insurance… nothing will really change.”

This was clearly stated by one participant who, despite learning that the package holiday around Scotland provided protection against insolvency, cancellation and inadequate service provision, still viewed insurance as their primary means of protection. 

“Insurance is probably more important.”

This was also evidenced in one of the focus groups when participants were asked to reflect on the protections provided by one of our LTA holiday scenarios (3B).

One participant fed back that they believed that travel insurance would offer all the protections discussed (insolvency, cancellation and inadequate service provision), providing the primary protection where LTA protections are lacking.

“That is where I would definitely think of travel insurance… I would make sure I have travel insurance that would cover all these protections.”

Members of another focus group were asked to reflect on the whole session. For one participant, their main reflection was that they were pessimistic about the ease of seeking redress through the holiday booking protections and instead feel that insurance offers the better route. 

“[I’m] pessimistic. Yeah they do give those protections but the level of service you are going to get to get any compensation will be a real hassle so this is why i feel it is important to have things like travel insurance that specialise in things like this. I get they are in place, but to get service what you need out of them will be difficult. Nice to know there is a safety net but wouldn’t trust it so much as travel insurance.”

Mistrust and pessimism surrounding how consumer’s think protections work in practice is shown here to result in consumers viewing insurance as their primary source of protection and means of redress. This sentiment can result in them having difficulties seeking redress as they are entitled to this from other means, such as from the airline or package organiser, resulting in them getting stuck in a frustrating back-and-forth between insurance and travel firms. 

Insurance is often the first thing that comes to consumers’ minds

Consumers' focus on insurance also came across at the start of our focus group sessions and online survey (ie prior to the holiday booking scenario testing) where participants and respondents were initially asked “What does the words ‘travel protection’ mean to you?”. Beginning both the focus groups and survey with this open question allowed us to explore what first comes to mind to consumers when they think of protections, before getting into the detail of the different types and modes of travel protection. 

During this initial focus group discussion, insurance was the word that was mentioned most often. This showcases how insurance is at the forefront of their minds when thinking about holiday protections, viewing protections as something they need to purchase themselves, rather than the legal rights that come with the booking they make.

“[The] important thing is to insure yourself for everything. It is protection.”

“I always take out insurance and that protects for a multitude of things.”

Many consumers view insurance as the primary safety net for anything that goes wrong, even for protection against a flight or holiday cancellation for which insurance might not be applicable. Most policies do not provide cover when it is possible to claim the costs elsewhere by other parties, such as airlines or package holiday companies. 

“[Insurance] provides reassurance, not just if cancelled but if someone is unwell.”

This was also evidenced in our online survey. Respondents were asked to write what the words ’travel protection’ means to them. As shown in the word cloud (Figure 7) below, the most common word mentioned was insurance. 

Figure 7: Word cloud of the most commonly occurring words to what the words ‘travel protection’ mean to respondents

Looking closer at each respondent’s response, insurance was the most common phrase that came across. Over half (53%) of all survey respondents mentioned insurance, or being insured, in their response to what travel protection means to you. This was much higher than other words and phrases identified, such as protection against incidents arising, protection against health related problems and that protection provides ‘cover’, all of which were only mentioned by one in five respondents. This further shows how insurance is viewed as the key element of holiday protections for UK consumers. 

Consumers are right to think about insurance but risk having problems when things go wrong

Insurance is obviously an important aspect of consumers’ holiday protections and participants in our research are correct to take insurance policies out. There is a risk though that consumers overestimate the level of insurance cover they get which may lead to picking an inadequate policy and to experiencing difficulties when making a claim. Through viewing insurance as the primary means of protection for their holiday, as evidenced in this chapter, consumers are at risk of thinking their insurance provides greater protection than it does, which in turn risks putting them in vulnerable situations when things go wrong.

Previous research and investigations by Which? has highlighted difficulties when seeking redress from insurers, a lack of effective cover during the pandemic, and limited availability of cover against the insolvency of an airline or holiday business. 

During the pandemic, travellers experienced a significant level of disruption and difficulty in accessing refunds for their cancelled travel plans. Many flights continued to operate but passengers were unable to travel due to government advice either in the UK, or the destination country, and other restrictions such as quarantine rules. At the time, Which? found that consumers struggled to get the refunds they were owed, and when making claims to the travel company, insurer or credit card company, they were continually passed from one firm to another and financially impacted by long delays in processing their refund claims, resulting in a stressful and convoluted process.   

With the introduction of travel restrictions in 2020, a significant number of major travel insurance providers pulled out from the market, and over time those who were buying new insurance policies for new bookings faced inadequate cover and increased costs [6]. We found that policy holders were overestimating how comprehensively their travel insurance covered them against Covid-19. Half believed their policies protected them if the Foreign, Commonwealth and Development Office (FCDO) advised against travel to their destination - a protection that had been almost entirely withdrawn across the market - and newer customers were most likely to believe they had it [7]. This demonstrates that in times of crisis and mass disruption, sudden changes in the market can sometimes dilute the protective power of insurance products for consumers. It serves as a stark reminder of the crucial role played by adequate statutory protections and the need to ensure they are effectively enforced. 

Previous research from Which? shows that consumers cannot always rely on travel insurance for claims related to airline and holiday business insolvencies. Insights from a recent Which? travel insurance provider survey shows that only 46% of policies cover airline bankruptcy and 35% cover holiday company bankruptcies as standard, while a survey of policy holders revealed that airline insolvency claims were the most likely to be rejected (rejection rate of 14%) followed by holiday company bankruptcy (12%) [8]. In addition, this survey highlighted problems in liability between firms as it found that the third most common reason insurers give for rejecting a claim was that another firm is responsible for the losses incurred and therefore should pay instead.

Not everyone will need insolvency cover if they are already protected elsewhere, either because they booked a package holiday or made their payment using a credit card. For this reason, it is important that consumers are adequately and clearly informed at the point of booking their holiday of what protections they are entitled to. They should have the tools to make an informed decision about how much extra protection they require from their travel insurance policy, tailored to their specific needs.

Some consumers may intentionally choose to duplicate their coverage when it comes to insolvency protections, relying on both Section 75 and a travel insurance policy. Their choice is driven by a lack of confidence that their consumer rights alone will be enough. We had a participant in one of the focus groups who did not feel comfortable just relying on the protections that come with their booking.

“I always ensure I get secondary insurance, I wouldn’t just rely on ATOL. That gives you an extra level of protections.”

Recommendations

It is clear that consumers may think that travel insurance is the ultimate safety net for everything that can go wrong with a holiday. However, reality tells a different story, especially when it comes to insolvency and the impact of disruption where other statutory consumer protections come into play. And as previous research by Which? presented above shows, it can be difficult for travellers to seek redress from insurers when other consumer rights apply and another company is responsible for the losses incurred. It is important that consumers don’t get stuck in a frustrating back-and-forth between holiday firms and insurance providers when things take a turn for the worse with their trip, causing unnecessary time-wasting and stress.  

When consumers are in the process of booking a holiday, be it a package holiday deal, LTA, or individual travel services, they should be given clear and upfront information about the statutory protections that come with the booking. This knowledge equips consumers to evaluate what additional measures, if any, could protect their holiday, and what level of cover to seek when looking for a travel insurance policy. No one wants unpleasant surprises while on holiday.

Chapter 3: Protections in practice 

Summary of findings

1. Consumer’s views towards the fairness and appropriateness of booking protections and secondary protections are tied to how well they think the protections work in practice.
2. Many participants were pessimistic about the ease of seeking redress and do not feel confident that their protections work well if things go wrong. 
3. More than half of consumers felt it would be difficult to get a refund for package holiday issues (60%) and 57% felt it would be difficult to get a refund when holiday flights are cancelled.

Background

To unlock the advantages of booking protections on air travel and package holidays, the protections must be clear, coherent and effectively enforced. Yet, over the years, we’ve witnessed a cloud of confusion and a lack of awareness surrounding consumer rights. Issues in rule enforcement, particularly in times of crisis, and discrepancies between the frameworks governing air travel and package holiday rights have emerged and have hit consumer confidence as a result. 

In May 2020, Which? found that trust in the travel industry plunged to a record low as airlines and holiday companies denied and delayed refunds for coronavirus cancellations. At the time, our quarterly Consumer Insight Tracker showed that trust in airlines and holiday companies dropped from a net score of +9 in February 2020 to -12 in May 2020 – a drop of 21 points, and the lowest score ever recorded in the seven years Which? has collected the data. This was the second time since Which?’s records on consumer trust began that the net score for trust in airlines and holiday companies dropped below zero – the only previous occasion net trust in the industry entered negative figures was briefly after the collapse of Thomas Cook in September 2019, when the net score decreased to -1 [9]. 

At the start of the pandemic, as flights were grounded and travel restrictions imposed, a troubling scenario unfolded for many consumers. Holiday providers, facing unprecedented challenges, told their customers that they couldn’t receive a refund but should re-book their holiday or accept a refund credit note instead. The majority of holiday operators struggled to refund their customers within the legal time limit of the Package Travel Regulations (that is fourteen days from the cancellation), while some providers were only issuing partial refunds as they experienced difficulties securing refunds back from the airlines for flight-inclusive package holidays. 

The Competition and Markets Authority (CMA) stepped in to investigate unfair practices in the holiday sector and to support consumers seeking redress for holidays that were cancelled due to lockdown restrictions in the UK and abroad. The regulator also launched an investigation on airlines who refused to pay refunds to passengers who were legally unable to travel due to lockdown restrictions. The issue explored by the CMA in their investigation on BA and Ryanair is an evident inconsistency between Regulation EC261 on air passenger rights, as retained in UK law, and the Package Travel Regulations. Indeed, Regulation EC261 does not cover whether consumers should be refunded when they are legally prohibited from travelling but their flight goes ahead - which is not the case with the Package Travel Regulations which allow consumers to cancel their package and receive a full refund ‘in the event of unavoidable and extraordinary circumstances’. 

As 2022 marked the lifting of all travel restrictions and the sector prepared to a full reopening, we saw another unexpected twist unfold in August. Consumer trust in airlines took another nosedive, as many passengers and holidaymakers’ found themselves navigating a landscape of delays and cancellations, strike action and airport staff shortages. In a survey of passengers affected by the 2022 summer chaos, we found that trust in airlines was particularly poor, with those who didn’t book their flight as part of a package holiday more likely to lack confidence in future airline treatment (45%) compared to those who booked a package holiday (31%).

Fast forward to the summer of 2023, and a sense of deja vu loomed as disruption to travel plans once again reared its head. This time, strike action, flight cancellations, and the unexpected NATS air traffic control failure added to the mix, further shaking consumers' trust in the travel market.

Research findings

The main purpose of this research project was to explore consumers’ knowledge, understanding and views towards holiday booking protections. We aimed to uncover how well consumers were acquainted with different protections available and whether they thought these protections were fair when applied to various booking scenarios. 

Our aim wasn’t to delve into the detail of how well consumers think these protections perform when in real life problems arise. But, as we went through the focus groups sessions, an interesting connection became evident. Consumers’ perceptions of fairness and value when it came to booking protections and secondary protections were tied to their thoughts about how effectively these protections actually work in practice.

We have already glimpsed into consumers’ perspectives on how holiday protections translate into real-life experiences in earlier chapters. In Chapter 1, when looking at package holiday protections, we found that despite participants feeling reassured about the protections and saying they were fair, some were pessimistic about the ease and timeliness of receiving a refund or alternative arrangement they were entitled to. This gives rise to a range of consumer woes, from questioning the worth of making a claim and missing out on the rightfully deserved compensation to those grappling with stress and anxiety while navigating the claims process.

In Chapter 2 we explored how consumers view travel insurance as their primary means of protections, which can result in consumers overestimating the level of cover they get and lead them to making the wrong decision when booking a holiday and choosing an insurance policy. Additionally, one participant was pessimistic about the ease of seeking redress through holiday booking protections and instead felt that insurance offers the better route. This belief risks consumers being passed between insurance providers and holiday firms when things go wrong with their trip, causing unnecessary time-wasting and stress.  

Many consumers are pessimistic about the ease of seeking redress

In our survey we asked respondents how easy or difficult they think it would be to get a refund for package holiday issues or when holiday flights are cancelled. For both metrics more than half of consumers felt it would be difficult; 6 in 10 (60%) consumers felt it would be difficult for package holiday issues and 57% when holiday flights are cancelled. This is concerning as it means that many consumers have either had personal difficulty getting a refund, know someone else who has had difficulty or perceive holiday companies or insurance firms as difficult to make a claim with. This could impact consumers' willingness to make a claim in the future. 

Figure 8: More than half of consumers felt it would be difficult getting a refund

In our first focus group, participants were presented with the holiday booking scenario around Scotland and given a situation of inadequate performance of the package. 

From our focus group discussions, a unanimous consensus emerged: all participants firmly believed they had the right to receive a refund from the travel organiser when their holiday experience fell short. However, in the midst of this shared understanding, a range of different opinions emerged.

For some, they weighed up their perceived difficulty of getting a refund from the company with the amount of money they believe they are entitled to claim. A few participants even expressed reluctance to go through the process for smaller amounts, citing this perceived difficulty as the deciding factor. One member of the group summarises this well on behalf of the focus group.

“Unanimously we said it has to go back to the holiday operator in that instance. However there were little caveats there because everyone said [...] there was other stuff involved, like how easy it is going to be to get a refund and if it is a bit of a hassle and also cost was factored into it. If you are looking at a £20 breakfast, is it really worth your time and hassle.”  

While this refund is likely to be of small monetary value, it is concerning to see that consumers feel that they need to weigh up the costs and benefits of making a claim due to the perceived difficulty of making a claim. This means that many consumers could be experiencing financial harm by not receiving money they are likely entitled to. 

Conversely, consumers making a claim can experience harm as a result of poor complaint handling practices or having to wait a long time to receive redress. The timeliness of refunds can be crucial for participants who may have certain elements of their holiday cancelled. Receiving a prompt refund can allow consumers to rebook the lost element of their holiday quickly, prior to prices rising. One focus group participant mentioned that this was not the case for them in the past. 

“I had a holiday cancelled when Thomas Cook went bust - by the time we got the refund everything else was too expensive to book”

This chapter has suggested that consumers harbour a profound lack of confidence in both the travel and insurance sectors. Their outlook is clouded with pessimism when it comes to seeking redress, and they remain sceptical about the practical effectiveness of protections that come with their holiday booking. This climate of uncertainty can cast a shadow of financial hardship over consumers. This could be losing out on money they are entitled to if they choose not to pursue their rightful claim, as well as having to spend more money in a last-ditch effort to salvage a holiday when timely refunds elude them. In previous research by Which? we have heard countless stories from consumers who have shouldered the financial burden, endured stress, and navigated time-consuming challenges, all in the pursuit of their deserved refunds through small claims court.

Recommendations

Following years of unprecedented strain and chaos for travellers, it is vital that the government’s strategy to aid the recovery of the travel sector delivers reforms that boost consumers’ confidence in the airline and holiday industry. Consumers need to be better protected when things go wrong, particularly as businesses may not fulfil their legal obligations and deny or delay claims. Effective and consistent enforcement of the rules and resolution outcomes is of paramount importance, particularly as issues with complaint handling practices and the difficulties when trying to resolve what are often complex disputes involving different parties directly can leave consumers with no clear routes to redress with many having to take their cases to the small claims courts. 

It is therefore crucial that the regulators are equipped with adequate tools and resources to effectively enforce consumer rights governing package holidays and air travel. Which? strongly believes the government should strengthen the public enforcement system in air travel and holidays, and deliver a fair and coherent approach to consumer rights in this sector. 

This can be achieved by bringing forward legislation that will grant stronger powers to the CAA for air travel and flight-inclusive holidays, in the same way that the CMA is finally being granted access to a wider enforcement toolkit that includes fining powers under the Digital Markets, Competition and Consumers Bill, and by ensuring local authorities Trading Standards are given adequate resources to enforce packages and LTAs rules. 

In addition, the government should review the dispute resolution framework in the aviation sector by mandating membership for airlines and establishing a single statutory-backed mandatory ombudsman scheme to ensure consumers can enforce their rights directly without the need to resort to the courts. 

When passengers struggle to receive a satisfactory response to their complaint from the airline, they can escalate it to the Alternative Dispute Resolution (ADR) scheme provided the airline has signed up to one, or alternatively to the CAA’s own Passenger Advice and Complaints Team (PACT). Passengers who tried these options unsuccessfully can resort to the small claims court to resolve their dispute. 

A Which? survey looking at dispute resolution found that the airlines and holiday sector scored the lowest among eleven sectors, with only 37% of consumers saying they feel confident that businesses in this sector would resolve their complaints satisfactorily [10]. An effective complaint handling system and regulatory framework is fundamental in creating and maintaining trust in the aviation and holiday sectors by supporting travellers who experience poor service. 

A holiday represents an expensive purchase for most people and the involvement of different providers can lead to complex disputes. However, the package holiday sector is only partially covered with ADR only available to customers of ABTA members through ABTA’s arbitration service, with claimants having to pay substantial fees to register a dispute. At present, a large number of travellers have no access to ADR while those who do might be deterred given the cost of making a claim.

The government should: 

• Grant stronger consumer enforcement powers to the CAA to tackle non-compliance in the airline industry and ensure local authorities Trading Standards services are adequately resourced to monitor business practices and drive industry’s compliance with the rules. 
• Establish a single statutory-backed ombudsman in the aviation sector to ensure consumers can enforce their rights directly without the need to resort to the courts. 
• Review dispute resolution in the package holiday sector to ensure more travellers have access to alternative means of resolving complaints other than the courts. 

For the annex, download our full report:

Footnotes

[1] The number denotes which focus group the scenario was tested in and the letter denotes whether it was the first or second scenario tested.  ↑

[2] National Audit Office, Investigation into government’s response to the collapse of Thomas Cook, 2020. At the time, the Department for Transport concluded that it would be difficult to discriminate between ATOL and non-ATOL customers at overseas airports so a repatriation of ATOL customers only was not possible.  ↑

[3] However, and confusingly, the facilitator selling an LTA must provide insolvency protection only if it receives direct payments from the consumer for one or more of the travel services forming part of the LTA. Repatriation cover is only applicable if the LTA facilitator is also responsible for the carriage of passengers (e.g. an airline).  ↑ 

[4]  A facilitator selling an LTA must provide insolvency protection only if it receives direct payment from the consumer for one or more of the travel services forming part of the LTA.  ↑

[5] ‘Trading Standards urges UK trips to stay in PTRs’, Travel Weekly, October 2023.  ↑ 

 [6] Sobers, Dean (2021) ‘Is your travel cover COVID-proof?’, Which? Money, January 2021, pp.10-14.  ↑

[7] Ibid.  ↑

[8] Sobers, Dean and Gadir Maha (2023) ‘Have you packed your travel insurance?’, Which?, July 2023, pp. 33-35.  ↑

[9] Trust in the travel industry plummets to record low amid coronavirus refunds scandal, Which?, May 2020.  ↑

[10] The survey was conducted by Yonder, on behalf of Which?. 2145 UK adults were surveyed online between 13th and 15th August 2021. Data were weighted to be representative of the UK population by age, gender, region, social grade, tenure and work status. Findings are included in ‘Which? Response to Reforming Competition and Consumer Policy consultation’.  ↑

About

Which? is the UK’s consumer champion, here to make life simpler, fairer and safer for everyone. Our research gets to the heart of consumer issues, our advice is impartial, and our rigorous product tests lead to expert recommendations. We’re the independent consumer voice that works with politicians and lawmakers, investigates, holds businesses to account and makes change happen. As an organisation we’re not for profit and all for making consumers more powerful.

Citation

Our preferred citation for this publication is: 'Which? (2023), “It’s all so confusing, why is nothing simple”: Consumer difficulty navigating the complicated landscape of holiday protections' with the URL for this page.