On February 14, 2026, airspace closures across the Gulf region grounded flights from Dubai, Abu Dhabi, Doha, and Bahrain. Within 48 hours, operators were managing two entirely different crises. Group A: 4,200 UK package holiday customers stranded in Dubai hotels with no return flights. Group B: 2,800 customers whose outbound flights were rerouted through Istanbul or Mumbai, arriving 18 hours late with missed connections.
The problem
The Package Travel Directive (2015/2302) treats these two scenarios under different articles, with different obligations and cost allocations. Most operators applied the same crisis playbook to both groups, creating liability exposure in one direction or the other. Article 13(7) governs the duty of assistance for stranded travellers, including the three-night accommodation cap. Article 11 governs significant alterations before departure, giving travellers the right to accept the change, take an alternative package, or cancel for a full refund. The European Commission's 2023 guidance on force majeure and the PTD noted that operators frequently conflate these two frameworks during crises, leading to either over-compensation (absorbing costs they are not legally required to bear) or under-compensation (failing to offer the choices the Directive requires). During the 2026 Gulf crisis, the UK Civil Aviation Authority received over 1,400 complaints in the first week, with the majority relating to confusion about traveller rights under each scenario.
Scenario A: stranded travellers and duty of assistance
For customers already at the destination when the crisis hit, Article 13(7) of the PTD applies. The organiser must provide "appropriate accommodation" for stranded travellers, but the Directive caps this obligation at three nights (with exceptions for persons with reduced mobility, pregnant women, and unaccompanied minors). After the three-night cap, the cost question becomes more complex. The traveller's own travel insurance is expected to cover extended stays, but gaps in coverage are common. During the Gulf crisis, Dubai hotels raised rates by 30-40% within 72 hours of the airspace closure, according to STR Global occupancy data. Operators who had pre-negotiated crisis rates with hotel suppliers paid significantly less than those booking at rack rates.
Scenario B: rerouted travellers and significant alteration
For customers whose travel was altered before departure (rerouted flights, changed itineraries), Article 11 applies. The organiser must notify the traveller of the alteration and offer three choices: accept the change (potentially with a price reduction), accept a substitute package, or cancel for a full refund. The rerouting costs themselves (additional fuel, landing fees, ground handling at alternative airports) fall to the airline under EU261, not the package organiser. But if the rerouting causes downstream itinerary changes (missed hotel nights, cancelled excursions), the organiser bears the cost of making the package whole.
Where contracts fail
Most operator-supplier contracts do not address the cost allocation for crisis rerouting. When a flight reroutes through Istanbul instead of flying direct to Dubai, who pays for the additional transfer night? The hotel supplier in Dubai did not cause the problem. The airline may invoke force majeure. The operator is left holding costs that no contract anticipated.
What to do now
Map every active booking to a PTD scenario before the next crisis hits. For each destination, document which article applies if travellers are stranded versus rerouted. Pre-negotiate crisis accommodation rates with at least two hotel suppliers per major destination. Review your supplier contracts for force majeure cost allocation clauses. The time to discover your contracts have gaps is now, not during the next airspace closure.