It is essential for organisers to understand the scope and limits of their obligations under the Package Travel and Linked Travel Arrangements Regulations 2018 (“the Regulations”). Below is a practical reminder of what the law requires and where your responsibilities end.
Three nights’ accommodation support under Regulation 15
Where travellers are unable to return home as scheduled due to unavoidable and extraordinary circumstances, organisers must provide necessary accommodation for up to three nights per traveller.
Regulation 15(14) states:
“Where the organiser is unable to ensure the traveller’s return as agreed in the package travel contract because of unavoidable and extraordinary circumstances, the organiser must bear the cost of necessary accommodation, if possible of equivalent category - (a) for a period not exceeding 3 nights per traveller.”
There is no three‑night limit where the affected traveller is:
- Pregnant, or
- Of reduced mobility,
and they notified the organiser of this at least 48 hours before travel.
After the three nights: your duty to assist under Regulation 18
Once the obligation to fund accommodation has been met, the organiser’s responsibilities become more limited.
Under Regulation 18, organisers must signpost appropriate assistance, which includes:
- Providing information on local health services, authorities and consular support
- Helping travellers make communications
- Assisting in finding alternative travel arrangements
- Importantly, the Regulations allow organisers to charge a reasonable fee for this assistance - provided that the difficulty was caused intentionally or through negligence by the traveller, and any fee does not exceed your actual costs.
Travel insurance must take over after day three
Your contractual terms should clearly state that travellers must have adequate travel insurance.
After the three‑night accommodation obligation ends, insurers are expected to step in. Ensuring your booking conditions and customer communications reinforce this requirement can prevent disputes and manage expectations during large‑scale travel disruptions.
A practical tip for managing change requests
Where travellers ask to amend their plans during a major incident, it is good practice to record their reasons for doing so. This information can become highly relevant if insurers later pursue subrogated recovery actions. Clear records now can prevent unnecessary complications later.
For those customers wanting to cancel package holiday plans ahead of travel given the recent issues they are of course fully entitled to do so before departure and if their reason for cancellation is the military action in the UAE or FDCO advice against all but essential travel to their planned destination. Travellers will then be entitled to a full refund of their holiday cost pursuant to regulation 12(7), to be paid within 14 days.
Your usual cancellation fees will in these circumstances not be enforceable. Similarly if you as a tour operator wish to cancel a package trip due to issues in destination prior to departure, you can of course do so, and a full refund should be provided back to the customer within 14 days in accordance with Regulation 13.
