REGULATION


avoiding creating them or are they being created but there is not the recognition?” His colleague Danielle Rawson,


Deloitte CFO Advisory director, added: “How do you capture whether a booking is an LTA or not? If a consumer clicks to another website within a short space of time [after booking a flight], who is capturing that data and who is responsible for reporting it? It isn’t clear and it’s almost impossible to capture completely and accurately.” Golding acknowledged there is a


potential risk in removing LTAs that some businesses could find ways around selling a package. But he argued: “LTAs are defined so narrowly, I’m not sure how likely it is package organisers would start selling these types of arrangements to avoid selling a package. Of the two types of LTA, type A involves a single visit to a trader with separate selection [of services] and separate payment. Would organisers start splitting up sales entirely, sell a flight, then accommodation etc? That would have a detrimental impact on the customer experience. How many organisers would see that as preferential to PTR compliance? “Type B involves separate bookings


sold in a targeted manner. If an organiser said, ‘I’m no longer going to sell packages, I’m going to sell a flight then send a targeted advertisement for accommodation’, it’s a leap of faith that the customer will make that second booking. Given how complex LTAs are, it would be sensible to remove them.” He described a proposal to allow


package organisers to combine not only trust accounts and insurance to provide insolvency protection but also trust accounts and bonds as “sensible” and noted: “The government also sought views on the interaction of the PTRs with card-related consumer protection and the chargeback mechanism. It will be interesting to see how bold they are on that, whether they take an approach that when a customer pays with a credit


overseas holiday was Atol-protected % of respondents reporting last


Don’t know/ not applicable


it wasn’t Certain


7% 7%


it wasn’t ‘Think’ it was


‘Think’ 19%


% point change YoY


Source: CAA Consumer Survey, October 2022 Base: 3,500 UK adults 46% important Quite 21% 62% -1 6% 21%


Certain it was


important Not 6%


FIGURE 49: ATOL-PROTECTION OF HOLIDAYS Importance of Atol protection


Don’t know/ not applicable


11% important Very


One of the themes of the consultation is to strike the right balance between consumer protection and business freedoms but also deliver clarity for consumers


card, the organiser need not provide 100% financial protection because there is a mechanism for the customer to recover their money via the card provider.” But Golding said: “One of the


themes of the consultation is to strike the right balance between consumer protection and business freedoms but also deliver clarity for consumers. I’m not sure how much clarity that would deliver for consumers. It would certainly be welcomed by the industry.” The Call for Evidence asked whether


A MAJORITY of UK


holidaymakers viewed Atol protection as ‘important’, according to a CAA survey,


but a smaller proportion were certain their last holiday was Atol-protected (Figure 49)


domestic packages should be retained or removed from the PTRs, or removed unless they include transport. Golding suggested: “There is a good argument that consumers don’t need the same level of protection for domestic holidays. [But] I’m more persuaded to remove domestic packages when there is no transport. You can envisage a scenario where a customer books a coach package around the UK, the organiser goes into insolvency with customers in northern-most Scotland and they need help getting home.” There is also a proposal to remove


lower-priced holidays, which has attracted criticism. Golding noted: “The consultation states the aim would not be to disadvantage less-well-off consumers.


Travel Weekly Insight Report 2024 39


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48  |  Page 49  |  Page 50  |  Page 51  |  Page 52  |  Page 53  |  Page 54  |  Page 55  |  Page 56  |  Page 57  |  Page 58  |  Page 59  |  Page 60