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CTSI calls for holiday protections and terms and conditions to be simplified to help consumers

Posted 02/06/23

Almost three quarters of UK consumers don’t read T&Cs.

The Chartered Trading Standards Institute (CTSI) has urged the Government to address what it says is “consumer confusion” when it comes to how much protection customers receive when booking holidays.

Different levels of protection currently exist for UK consumers if they are booking separate types of holiday and travel services (such as flights, accommodation and car bookings).  The level of protection depends upon how a booking is made and the time it takes to make the bookings.  These will either be regarded as “package holidays” or “Linked Travel Arrangements” (LTA).  CTSI is calling for the law to be made as simple as possible as part of a forthcoming planned review of the Package Travel and Linked Travel Arrangement Regulations 2018 legislation so that they are easier to understand for consumers and to ensure they are protected from being misled or losing money. 

In its latest policy report, Wish You Were Clear, CTSI has found that:

  • The vast majority (88%) of consumers said that they support a review of the legislation governing holiday protection;
  • Around one in five consumers incorrectly believe that they are more protected when booking a Linked Travel Arrangement than when booking a package.
  • Almost three quarters (73%) of people said that they only skim read holiday terms and conditions or don’t read them at all.

CTSI public polling and feedback from travel/holiday experts showed that Linked Travel Arrangements are not seen as fit for purpose. Consumers are confused about the protection they receive when booking a holiday: in most cases, consumers don’t even know what an LTA is, let alone the fact that it provides them with less protection than booking a package.  CTSI is calling for:

  • Simplifying the wording and information provided to consumers from travel organisers – to include information about a holiday, information needed prior to or during a holiday, and information regarding liability and protection of money
  • Reform of the 2018 Package Travel and Linked Travel Arrangement Regulations
  • Clear warnings to consumers when no financial protection is provided.

CTSI Lead Officer for Holiday and Travel Law, Bruce Treloar, said: “Our public polling evidence shows that almost three quarters of people (73%) couldn’t tell the difference between a package holiday and a Linked Travel Arrangement, even when they were given a definition. A stakeholder poll also confirmed that businesses don’t always realise when they create an LTA and that the vast majority think that the definition of LTAs is problematic.

“Our paper also highlights the need for only essential information to be given to consumers and for enforcement powers to be increased as part of the Digital Markets, Competition and Consumer Bill (DMCC Bill).  There’s no doubt that package holidays and LTAs are a very complex issue but there needs to be greater protection and clearer information given to consumers when they book holidays.”

CTSI’s public poll surveyed 1,000 consumers across the whole of the UK, across all age groups. Consumers were given comparative information about the protection levels when booking a package holiday or a linked travel arrangement as part of the poll and almost 88% of consumers subsequently either said that they support a review of the legislation or had no opinion either way.

John Herriman, Chief Executive of CTSI said: "Our research shows that consumers do not appreciate that package holidays and linked travel arrangements have different levels of protection and that sometimes they may think they are booking a package holiday when they are actually booking a linked travel arrangement. CTSI also believes that businesses are confused and that regulators don’t fully understand LTAs.

“It’s also worrying that almost 50% (47.8%) of consumers think that they are more protected or aren’t sure about the levels of protection when booking an LTA compared to a package holiday.

“It’s clear that things need to change. We are calling on the Government to either reform or scrap LTAs, so long as what is put in their place means that consumers are not detrimentally affected.”

Linked travel arrangements were introduced as part of the revised 2018 Package Travel and Linked Travel Arrangements Regulations (PTRs) in a bid to provide consumers with more protection when booking holidays independently. Despite the good intention, CTSI believes that this has not happened.

John added: “Our policy papers seeks to open a timely dialogue with the UK Government and wider stakeholders about the need to reform the existing legislation in a way which recognises the impact of the current legislation on consumers."

Samantha Bradbury, Membership Director of ABTOT comments “As an approved bonding association, we understand all too well the importance of financial protection and the need to protect consumer monies. We appreciate that LTAs were created in the 2015 Package Travel Directive to provide greater consumer protection for consumers choosing to book flights, accommodation and another service separately or by purchasing a flight and then booking another service via a link. However, it seems from CTSI’s findings that the introduction of LTAs has instead created consumer confusion.  We support CTSI’s aims to open a dialogue with the UK Government to address this confusion in the anticipated review of the UK 2018 Package Travel legislation.”



Notes to editors:

  • A linked travel arrangement is either sold online or in a travel agency and covers the purchase of individual travel services which are then combined by a seller for the same trip or holiday. It’s the separate selection and purchase of travel services made during a single visitto a shop or a trader’s website, where the traveller selects and pays for, e.g., a hotel and then, without leaving the Agent or the website, he pays separately for a flight.


If the consumer goes online and purchases a travel service from one business and through a targeted link on this website they purchase a second travel service from the linked website, then this also would be an LTA, as long as the second travel service is purchased within 24 hours of the first.

You can access the full policy report on the CTSI website.

Chartered Trading Standards Institute (CTSI)  

The Chartered Trading Standards Institute (CTSI) is a national not for profit established in 1881 which supports the UK’s trading standards profession, and works to protect consumers and safeguard honest businesses.  CTSI's members are engaged in delivering

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