regulation Atol and package travel reform continues to stall


the new powers are expected to come in. It needs one more piece of legislation.” The DMCC has implications for


the sector in a second way. Golding explained: “The Act revoked and replaces the old Consumer Protection from Unfair Trading Regulations which has a list of banned practices for businesses selling to consumers. It adds a couple of banned practices and gives the government the power to add to the list. “The two new banned practices relate


to fake reviews and drip pricing. Fake reviews are the most notable. The DMCC broadly bans four things: submitting or commissioning fake reviews; publishing consumer reviews or review information in a misleading way; publishing consumer reviews without implementing appropriate procedures; and offering services in connection with any of the banned practices. “Publishing consumer reviews without implementing appropriate procedures is something the industry should be aware of. A business won’t be able to publish a consumer review without taking reasonable and proportionate steps to a) prevent publication of fake reviews or reviews that conceal the fact they have been incentivised, and b) remove any such reviews from publication. “The Act, in effect, requires companies


to implement internal processes to verify reviews before they’re published, and to perform ongoing audits on reviews on their website or wherever they publish reviews. A business will need to show it has a process to comply with the requirements.”


SUSTAINABILITY CLAIMS ‘AN AREA OF FOCUS’ ‘Greenwashing’ and sustainability claims are also a potential area of focus for the CMA once it has the new powers. Golding argued: “We’ve seen a spate


of Advertising Standards Authority (ASA) rulings on sustainable travel claims – including ruling against airlines where the ASA found a claim to be ‘one of the greenest choices in air travel’ to be misleading, and another where a reference


40 Travel Weekly Insight Report 2025


Two new banned practices relate to fake reviews and drip pricing. Publishing consumer reviews without appropriate procedures is something the industry should be aware of


to ‘100% sustainable aviation fuel’ was found to be misleading. There has been a similar focus on claims made by airlines in the EU. I wouldn’t be surprised if this is an area the CMA focuses on.” He noted: “The CMA had a focus on


green claims in the fashion industry in 2024 and wrote to 17 brands about their green claims practices including a reminder of its enhanced enforcement powers.” His colleague Tim Robinson, Deloitte


travel and aviation audit director, pointed out: “The largest travel businesses are now caught by the EU’s Corporate Sustainability Reporting Directive (CSRD), and we’re seeing ‘greenwashing’ caught here too. It’s the omission of information as much as inclusion of information that is an issue – for example, not including negative key performance indicators (KPIs), or moving the goalposts by rebasing KPIs. It’s an area in which we expect to see investigations and enforcement as annual reports are released.” Other pieces of EU regulation could


also have an impact. Those related to sustainability are discussed elsewhere in this report, but the EU AI Act includes provisions which apply from 2025, although most don’t come in until 2026. Golding explained: “The prohibited AI


practices are banned from February and the obligations on providers and deployers of AI to ensure AI literacy for staff also apply from February. If a UK business is supplying AI systems on the EU market or outputs from AI systems are intended for use in the EU, it could apply to them.” He said: “The UK is not as far forward


as the EU in legislation on AI. The government plans to regulate key AI developers and ban things like sexually explicit deepfakes, but its proposals are not as broad and extensive as the EU AI Act.” However, Golding warned: “The usual


rules around the sale of travel apply if a company is using AI to come up with marketing content or itineraries and isn’t checking the output is accurate. There is potential liability under the PTRs and under contract law.”


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