Night four. That is when the calls escalate. During the February 2026 Gulf airspace closure, thousands of UK package holiday customers hit the three-night mark in Dubai hotels with no return flights confirmed. Operators who understood the PTD's accommodation cap had a plan. Those who did not spent an estimated GBP 2.1 million in unrecoverable hotel costs over the following week, according to early ABTA member reports.
The problem
Article 13(7) of the Package Travel Directive (2015/2302) states that where return transport cannot be provided due to unavoidable and extraordinary circumstances, the organiser shall bear the cost of "necessary accommodation, if possible of equivalent category, for a period not exceeding three nights per traveller." The cap exists to balance organiser liability against genuinely unforeseeable events. But the Directive's language creates ambiguity. "Not exceeding three nights" is a limit, not a fixed entitlement. Some member states have transposed the Directive with slightly different wording. Germany's implementation, for example, references "appropriate duration" rather than a strict three-night cap. The European Commission's 2023 interpretive guidance clarified that the three-night limitation does not apply to persons with reduced mobility, pregnant women, unaccompanied minors, or persons needing specific medical assistance. During the Gulf crisis, some operators discovered these exceptions late, after already communicating the three-night cap to all affected customers.
What the Directive actually says
The three-night cap under Article 13(7) applies only when the organiser cannot provide return transport "as a result of unavoidable and extraordinary circumstances." Three conditions must all be met: the event qualifies as force majeure, the organiser genuinely cannot arrange return transport, and the delay is not caused by the organiser's own failure to act. If an alternative flight was available on day two but the operator did not book it, the cap argument weakens considerably. The organiser must also continue to provide the "duty of assistance" under Article 13(6) throughout the entire period, regardless of the accommodation cap. This includes providing practical information about health services, local authorities, and consular assistance.
Night four and beyond: the coverage gap
After the three-night cap, the financial burden shifts primarily to the traveller's own travel insurance. The problem is that many standard travel insurance policies cap their disruption coverage at GBP 1,000-2,000 per person. In Dubai during the February 2026 crisis, hotel rates for displaced travellers averaged AED 800-1,200 (GBP 170-255) per night. A family of four would exhaust a GBP 2,000 policy limit in approximately three additional nights. ABTA's consumer guidance recommends that operators clearly communicate the coverage gap to customers at the point of booking, not during a crisis.
Preparing for extended disruptions
Operators who managed the Gulf crisis most effectively had three things in place: pre-negotiated distressed traveller rates with hotel suppliers (typically 40-50% below rack rate), clear customer communications prepared in advance explaining the three-night framework, and relationships with local DMCs who could arrange alternative accommodation quickly when primary hotels filled up.
What to do now
Review your customer-facing terms to ensure the three-night cap and its exceptions are clearly communicated before travel. Negotiate distressed traveller rates with your hotel suppliers in every major destination now, not during the crisis. Prepare template communications that explain what happens after the three-night period, including guidance on travel insurance claims. Customers who understand the framework in advance file fewer complaints and require less crisis-time support.