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Package Travel Regulations Checker: Is This a Package?
Work out whether a trip you are selling is a package, a linked travel arrangement or neither under the UK Package Travel and Linked Travel Arrangements Regulations 2018. Answer the questions, then see the regulation that decides it and what it means for you as organiser, including insolvency protection, ATOL and information duties.
Outcome · reg. 2(5)(a)
Package
The Regulations apply in full. The organiser is responsible for the whole trip.
How we got there
- Contract concluded before 6 April 2027: the 2018 Regulations apply as originally made, including linked travel arrangements.
- 2 different types of travel service count towards a package.
- One trader combined them before a single contract for everything: this meets the definition of a package in reg. 2(5)(a).
What it means for you
| Responsibility for the whole packageregs. 15 and 16 | The organiser is liable to the traveller for the performance of every travel service in the package, whoever provides it, and must remedy problems, offer alternatives or price reductions and pay compensation where due. |
|---|---|
| Information before the contractreg. 5 and Schedules 1 to 4 | Give the Schedule 1 information and the standard information form (Schedule 2 where hyperlinks can be used, Schedule 3 otherwise, including by phone). |
| The contractreg. 7 and Schedule 5 | Plain, intelligible terms setting out the full package, including the Schedule 1 and Schedule 5 information, with a copy or confirmation on a durable medium. |
| Insolvency protection: ATOLreg. 19(6)(b); ATOL Regulations 2012 | A package that includes a flight is protected through ATOL, administered by the Civil Aviation Authority, rather than the PTR bonding, insurance or trust options. Check the ATOL Regulations 2012 and the CAA’s guidance. |
- A statement that you act only as an agent, or that a package is not a package, does not remove the organiser’s duties (reg. 30).
How the checker works
- Which rules. Contracts concluded before 6 April 2027 follow the 2018 Regulations as made. From that date the 2026 amendments apply: linked travel arrangements end, and separately paid services booked on one visit to a single trader become a package.
- Same trip. Services for different trips never combine into a package.
- Types of travel service. You need at least two of: transport, accommodation, vehicle hire and other tourist services. Several tourist services count as one type. Where there is only one of transport, accommodation or vehicle hire, a tourist service counts only if it is a significant part of the value (a 25% rule of thumb) or an essential feature, and was not bought after the trip started (regulation 2(6)).
- Exclusions. Trips under 24 hours with no overnight stay, occasional not-for-profit trips for a limited group, and business travel under a general agreement are outside the Regulations (regulation 3(2)).
- How it was sold. The checker tests the ways of forming a package in regulation 2(5) in order, then the linked travel arrangement tests in regulation 2(3).
- What follows. It lists the main duties for the outcome: responsibility for performance, pre-contract information and the contract, and insolvency protection, including the ATOL pointer for flights.
What the checker doesn’t do
- It doesn’t decide borderline facts for you, such as whether a tourist service is an “essential feature” or whether several contacts were a “single visit”. The government guidance has case studies for both.
- It doesn’t cover the detail of ATOL, which has its own rules for flight sales administered by the Civil Aviation Authority.
- It covers UK law only. EU member states apply their own versions of the Package Travel Directive.
Questions & answers
What makes a trip a package under the Package Travel Regulations?
At least two different types of travel service (transport, accommodation, vehicle hire and other tourist services) for the same trip, put together in one of the ways listed in regulation 2(5): combined by one trader before a single contract, bought from one point of sale before paying, sold at an inclusive or total price, advertised as a “package”, chosen from a gift-box-style selection, or booked through linked online booking processes where the traveller’s details are passed on within 24 hours.
Does a hotel with an excursion or spa treatment count as a package?
Only if the excursion or treatment is a significant proportion of the value or is advertised as, or otherwise is, an essential feature of the trip (regulation 2(6)). Government guidance gives 25% or more of the value as a rule of thumb, but it is not a fixed threshold. It is not a package if the extra service is chosen and bought after the stay has started.
What changes on 6 April 2027?
The Package Travel and Linked Travel Arrangements (Amendment) Regulations 2026 abolish linked travel arrangements for contracts concluded on or after 6 April 2027. Where one trader lets the traveller select and pay for each service separately on a single visit or contact, that becomes a package (new regulation 2(5)(c)). Targeted links to another trader without passing on the traveller’s data drop out of the Regulations. Contracts concluded before that date keep the old rules, so it is the booking date that matters, not the travel date.
Do the Regulations apply to business travel?
Yes, unless the trip is bought under a general agreement: a framework contract between a business and a travel provider for booking that business’s travel (regulation 3(2)(c)). Business travellers who book through ordinary consumer channels are protected like anyone else.
Do I need ATOL or a bond for a package?
Every UK organiser of packages needs insolvency protection. A package that includes a flight is normally protected through ATOL, run by the Civil Aviation Authority. Packages without flights need a bond through an approved body, insurance or a trust account (regulations 19 to 24). Where services are added to an ATOL-protected flight in a single visit after 6 April 2027, the added services need non-flight protection as well.
Can I avoid being an organiser by saying I am only an agent?
No. Regulation 30 says a declaration that you act only as an intermediary, or that a package is not a package, does not remove the organiser’s obligations. What counts is how the services were put together and sold.
Sources & data
Every figure this tool uses by default is listed here with where it came from and when we last checked it. Spotted something out of date? Tell us.
- The four types of travel serviceRegulation 2(1), definition of “travel service”, paragraphs (a) to (d). DBT guidance: a sleeper berth whose purpose is getting from A to B is part of the carriage, and residential accommodation (including long-term language courses) is not a travel service. Examples of other tourist services: concerts, sports events, excursions, guided tours, ski passes, equipment hire, spa treatments.
- Definition of a package (two or more types of travel service for the same trip)Regulation 2(5). Limb (b) applies “irrespective of whether the traveller concludes separate contracts”. Limb (c) is inserted by SI 2026/455, regulation 2(2)(c), in force 6 April 2027; DBT guidance calls it “Package Category 7”. Under limb (b)(v) the organiser is the trader who transmits the traveller’s data (regulation 2(1), “organiser”).
- When an “other tourist service” counts towards a packageRegulation 2(6) applies where no more than one of carriage, accommodation and vehicle hire is combined with other tourist services. Regulation 2(4) applies the same significance test to linked travel arrangements (contracts before 6 April 2027 only), without the “after performance has started” limb.
- “Significant proportion” rule of thumb for other tourist servicesNot in the Regulations. DBT guidance: “A ‘rule of thumb’ is that if the ‘other tourist service’ accounts for 25% or more of the value of the package then this should be indicative of it forming a significant proportion.” “Value” is not defined and will often, but not always, be the purchase price. A service under 25% can still count if it is advertised as, or otherwise is, an essential feature. The user answers this question themselves in the tool.
- Definition of a linked travel arrangement (contracts concluded before 6 April 2027)Regulation 2(3) and (4): at least two types of travel service for the same trip, not a package, under separate contracts with the providers. SI 2026/455 omits regulation 2(3) and (4) from 6 April 2027: type (a) becomes a package under new regulation 2(5)(c) and type (b) leaves the Regulations. Arrangements entered into before that date keep the old rules (SI 2026/455, regulation 1(4)).
- Arrangements the Regulations do not apply toRegulation 3(2) and (3). DBT guidance: “occasionally” means no more than a few times a year, and the not-for-profit exclusion covers the not-for-profit body itself, not a commercial company organising trips for it. The general agreement exclusion covers framework contracts with business travel agencies; business travellers who book through consumer channels without one stay protected.
- Commencement of the 2026 amendments (linked travel arrangements abolished)SI 2026/455, regulation 1(1): made 22 April 2026, in force 6 April 2027. Regulation 1(4): the amendments have no effect on a package travel contract or a linked travel arrangement entered into before that date, so the date the contract is concluded decides which rules apply, not the travel date.
- Main duties of a package organiserRegulation 19(5): the security must be bonding (regulations 20 and 21), insurance (regulation 22) or a trust account (regulations 23 and 24). Failing to provide information or insolvency security is a criminal offence (regulations 5(5) and 19(9)). A declaration that the organiser is acting only as an intermediary, or that a package is not a package, does not remove these obligations (regulation 30(1)).
- Flight packages are protected through ATOLRegulations 19(6)(b) and 26(6)(b): the PTR security options do not apply to the extent a package or linked travel arrangement needs an ATOL licence under the Civil Aviation (Air Travel Organisers’ Licensing) Regulations 2012 or is covered by ATOL arrangements. DBT guidance (paragraphs 49 to 51): flight packages need ATOL protection, administered by the CAA; where services are added to an ATOL-protected booking to form a “Package Category 7”, ATOL does not cover the added services, which need non-flight insolvency protection.
- Duties of a trader facilitating a linked travel arrangement (before 6 April 2027)Regulation 26 is omitted by SI 2026/455 from 6 April 2027, with Schedules 6 to 10. Breach is a criminal offence (regulation 26(10)).
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