The revised Package Travel Directive: what you need to know

The Paypers sat down with Benoît Chantoin, Director for Legal and Consumer Affairs at ECTAA, to discuss the recent revisions to the Package Travel Directive (PTD). 

The Package Travel Directive has been a cornerstone of EU consumer protection for years. What made this revision necessary, and how well does the final text address the gaps it set out to fix?

The revision was triggered by a perfect storm of events. The European Commission was already in the process of reviewing the 2015 Directive when two major crises accelerated and shaped the legislative agenda. The collapse of Thomas Cook in 2019 – one of the largest insolvency events in European travel history – brought the adequacy of insolvency protection rules into sharp focus. The COVID-19 pandemic then triggered an unprecedented refund crisis across the sector, revealing serious weaknesses in cancellation and refund rules in the travel value chain and generating enormous pressure for reform.

The final text responds to both crises and delivers several meaningful improvements for the industry, in particular regarding simplicity.

Now that the revised Directive has been adopted, what are the key provisions travel businesses and consumers should be aware of?

The revised Directive introduces a number of significant changes that both industry and consumers will need to understand ahead of transposition.

From a scope perspective, the text goes further than the Commission's original proposal in simplifying the definition of a package – a clear win for the industry. Linked Travel Arrangements (LTAs) have been deleted, the Commission's proposed three-hour threshold for packages has been removed, and the 24-hour definition is now available only on an opt-in basis. However, the industry should note that the click-through provision – covering packages formed via two separate traders – has been broadened. It now extends to any transfer of personal data, not merely the combined transfer of name, email address, and payment details as currently required, meaning a wider range of commercial scenarios will fall within its scope.

On information obligations, the revised Directive introduces new requirements, notably the duty to inform consumers when a combination of travel services does not constitute a package – a provision that will help clarify grey-area situations. There are also enhanced requirements relating to the suitability of trips for persons with disabilities (replacing the narrower PRM concept), which may require organisers to engage more closely with service providers to obtain the necessary information before transposition deadlines.

The revised Directive also strengthens insolvency protection rules significantly. Coverage is extended to all advance payments made by travellers – a direct response to the gaps exposed by the Thomas Cook collapse and the COVID-19 crisis. Clear refund deadlines are introduced: insolvency protection must cover refunds within six months for future travel and nine months for travel already taken place, providing travellers with greater certainty and organisers with a clearer operational framework.

Cancellation rules have been updated to reflect recent European Court of Justice rulings arising from the pandemic, bringing greater legal coherence. A new B2B refund obligation requires service providers to refund organisers within seven days where a service is cancelled. Notably, the final text does not introduce new penalty or binding arbitration mechanisms – an outcome that reflects the sustained and effective advocacy of ECTAA and the wider travel industry throughout the legislative process.

Prepayments were one of the most contested issues throughout the process. How do you view the outcome at EU level, and what should the industry watch for as member states move into transposition?

The outcome on prepayments is a significant win for the industry. Despite intense political pressure at various stages of the legislative process, the final text does not impose any binding EU-level obligation on how prepayments must be structured or limited. This reflects the industry's consistent and ultimately successful argument that rigid, prescriptive prepayment rules would distort commercial flexibility, undermine established business models, and ultimately harm consumers through higher prices or reduced choice.

That said, the industry should not treat this as the end of the debate. The Directive does not prevent member states from introducing national rules in areas not regulated at EU level – and the possibility of prepayment restrictions being introduced domestically during transposition is real. It is worth noting that this was always the case: member states have always had the freedom to act where EU law is silent. What matters now is that the industry stays engaged at national level throughout the transposition process and, if necessary, make the case clearly and consistently against fragmentation that would complicate cross-border trade and undermine the coherence of the single market.

Vouchers now sit alongside refunds under clearer rules, with insolvency backing and consumer consent requirements. What do the new rules change, and what will determine whether they work as intended?

The new voucher framework formalises and strengthens a model that was already outlined in the Commission's COVID-19 Guidelines – giving it proper legal standing and enforceable minimum standards. Under the revised Directive, travellers retain the unconditional right to choose between a cash refund and a voucher – consent cannot be assumed or mandated. 

Where a traveller voluntarily accepts a voucher, it must meet a clear set of minimum criteria:

• Validity: maximum of 12 months, renewable once
• Protection: must be insolvency-protected
• Value: at least equal to the original refund amount
• Transferability: must be transferable at least once
• Refundability: any unused value must be refunded automatically upon expiry

Having this framework codified in law provides real operational clarity for both organisers and consumers. And its relevance is already being felt: vouchers are already introduced to answer to the current Middle East crisis. It is a reminder that disruption does not wait for transposition deadlines – having clear, legally grounded voucher rules in place sooner rather than later is a tangible benefit for the sector.

The PTD introduces a seven-day B2B refund rule, requiring service providers to refund organisers when a service is cancelled or not delivered. What does this change for the sector?

The seven-day B2B refund rule is a genuinely positive development, though its practical impact remains to be tested. For the first time, EU law explicitly establishes that package organisers are entitled to be reimbursed by service providers – airlines, hotels, and others – when a service is not delivered due to unavoidable and extraordinary circumstances. This gives the travel industry a far stronger legal footing than previously existed: rather than relying solely on the right to pursue litigation, there is now a clear, directive-level norm establishing the obligation to refund.

In practical terms, this matters most in crisis situations of the kind experienced during COVID-19, where organisers were caught between their own refund obligations to consumers and the inability to recover costs from upstream suppliers. The rule provides a more robust basis for claims and a clearer basis for dispute resolution. Its enforceability has limits – it applies primarily to EU-based businesses, and extending it to service providers outside EU borders will remain legally and practically challenging. But this is a meaningful step forward: where previously the only recourse was the courts, there is now a statutory rule. The industry should build on this foundation through strong contractual protections in supplier agreements to complement the new legal framework.

The Paypers’ Travel Series includes contributions on topics spanning emerging trends in travel payments, fraud and security challenges, regulatory and tax impacts, risk management and forex, as well as sustainability in the travel industry. For a complete overview of all the contributions featured, click here.  

About the author

Benoît Chantoin is the Director for Legal and Consumer Affairs at ECTAA. With over 18 years of experience in European affairs, Benoît has focused extensively on consumer protection and regulatory policy. He has been a key voice in the development and implementation of the Package Travel Directive (PTD) for the past 14 years. Since January 2024, he has also served as the Secretary General of EGFATT (European Guarantee Fund Association for Travel and Tourism), further broadening his work on financial protection.

 

About ECTAA

 

ECTAA is the European umbrella organisation of travel agents and tour operators across Europe. Its members are the national associations of 26 member states of the EU, as well as Israel, Switzerland, Norway, Ukraine, and the UK. ECTAA’s mission is to drive growth and competitiveness in the European travel industry by working with members to inform and shape the debate in European institutions and industry bodies. ECTAA represents some 80,000 travel agents and tour operators which sell transport, accommodation, leisure, and other tourism services as well as combined products to leisure and business customers.