Wednesday, 19 August 2026
The way Europeans book holidays has changed faster than the legal categories traditionally used by the travel industry. Flights, accommodation, transfers and activities can now be combined within a single online journey, even when several different businesses ultimately provide the services. EU lawmakers are responding by making the structure of the customer journey increasingly important in determining who carries responsibility when something goes wrong.
The revised Package Travel Directive was formally adopted in 2026 and updates rules originally designed for a market dominated by conventional tour operators and high-street travel agents. Member states must transpose the new requirements by September 2028, with national rules applying from March 2029.
For travel businesses, the significance extends well beyond their legal departments. Under the new framework, the description a company gives itself does not necessarily determine its obligations. Calling a platform an intermediary or presenting individual elements of a trip as separate contracts will not by itself prevent the overall transaction from being treated as a package where the legal conditions are met.
That places increasing importance on what the customer actually sees and is encouraged to do. A traveller may begin by booking a flight and then be offered a hotel, transfer or excursion within the same interface. From the customer’s perspective, the services can appear to form part of one connected journey even though different providers sit behind them.
Where a business encourages the customer to buy another category of travel service for the same trip, bookings made within 24 hours at the same point of sale can fall within the package regime in certain circumstances. If the combination does not otherwise qualify as a package, the trader must clearly tell the customer that the services are being purchased separately and that package-travel protection will not apply. Failure to provide that information can affect the legal classification of the transaction.
This means decisions traditionally treated as marketing or product-development choices can carry regulatory consequences. Product teams determine where accommodation offers appear during the booking process, marketing departments decide whether to cross-sell airport transfers or activities, and designers determine whether additional services look like part of one transaction or entirely separate purchases. Those decisions can influence whether a platform is eventually regarded as the organiser of a package.
For online travel agencies and other booking platforms, this creates a different compliance challenge from simply reviewing contracts. Legal exposure can begin while the customer journey is still being designed.
The same issue is increasingly relevant to hotel operators. Hotels are trying to sell more directly to guests rather than relying entirely on third-party booking platforms. Their websites may combine accommodation with airport transfers, spa treatments, excursions, car hire, event tickets or other services. The more integrated these products become, the more carefully operators need to consider whether they are simply selling accommodation or creating a regulated travel package.
Serviced-apartment operators, resorts and hospitality groups developing their own digital booking ecosystems face similar questions. This does not mean every combination of accommodation and another service automatically becomes a package, as classification depends on how the transaction is structured and presented. It does mean, however, that booking architecture increasingly needs to form part of compliance analysis rather than being treated purely as a commercial tool.
The reform also simplifies an area that had become difficult for companies and consumers. The separate concept of linked travel arrangements is being removed after EU lawmakers concluded that it had added complexity while providing limited additional protection. Instead, the revised rules place greater emphasis on clearer distinctions between packages and stand-alone bookings and on informing travellers when package protection does not apply.
The changes were shaped heavily by the experience of the pandemic. COVID-19 exposed weaknesses in refund systems when millions of journeys were cancelled simultaneously and travel companies themselves experienced severe liquidity pressure. The failure of major operators had already highlighted vulnerabilities around insolvency protection, making financial protection another important part of the regulatory review.
The revised framework therefore strengthens several areas alongside the definition of a package. Refunds following qualifying cancellations generally remain subject to a 14-day deadline. Vouchers can be offered as an alternative, but customers must be able to reject them and receive money instead. The framework also introduces clearer requirements covering voucher validity, transferability, consumer information and insolvency protection.
Complaint handling is becoming more structured as well. Organisers will be required to acknowledge complaints within seven days and provide a reasoned response within 60 days. For consumers, the broader objective is to make it easier to understand who is responsible for a journey and what protections apply when several travel services are purchased together.
For companies, however, the implications are more complicated. A platform designed to make booking effortless can unintentionally make separate products appear to the customer as a single travel product. The commercial objective of reducing friction in the purchasing process can therefore increase regulatory exposure.
This creates a growing tension within digital travel. Businesses want seamless booking journeys because customers are more likely to purchase additional services when the process is simple. But the more seamless that journey becomes, the more difficult it can become to argue that every component was entirely separate from the customer’s perspective.
Package-travel compliance is consequently becoming less of a final legal review and more of a product-governance issue. Companies may need legal and compliance teams involved earlier when new booking functions are developed, particularly where customer data are transferred between providers, users are prompted to add services or several travel products are presented within one transaction flow.
Marketing can also influence the outcome. A platform describing an experience as a complete holiday or presenting several components as one combined offer may create a different regulatory position from a business that clearly separates each booking and explains the protections applying to each service.
The implications extend into the hospitality industry as operators invest more heavily in direct digital relationships with customers. Hotels have spent years attempting to reduce their dependence on large online travel agencies by improving direct-booking platforms, loyalty programmes and ancillary-service sales. Those strategies can generate higher margins and provide better access to customer data, but they can also bring additional responsibilities when the hotel begins to provide something broader than accommodation.
This does not undermine the commercial logic of direct selling. Instead, it changes the regulatory considerations surrounding it. Hotel groups, resorts and serviced-apartment operators may increasingly need to examine their digital distribution strategies not only from the perspective of conversion rates and revenue but also according to how customers perceive the overall product they are purchasing.
The wider lesson extends beyond travel. European regulation is increasingly examining how digital business models function in practice rather than relying exclusively on contractual descriptions of individual participants. User-interface design, data flows, commercial relationships and customer perception can all contribute to determining where responsibility sits.
Travel provides a particularly clear example because the industry has moved rapidly from conventional packaged holidays towards digital ecosystems combining services supplied by multiple businesses. The technology has made those boundaries increasingly invisible to consumers, while regulation is attempting to make responsibility clearer.
For online travel platforms and hospitality operators, the regulatory question is therefore changing. It is no longer enough to determine what a company calls itself in a contract. Businesses increasingly need to consider what customers reasonably understand themselves to be purchasing as they move through the booking process.
That makes the revised EU package-travel framework not simply a change in travel law, but an increasingly important issue for technology, product development, digital distribution and the wider European hospitality industry.
Source: CMS
