In 2024, the UK government launched a consultation proposing to eliminate Type B linked travel arrangements from the Package Travel and Linked Travel Arrangements Regulations 2018. Six months later, the EU agreed to delete LTAs entirely but widen its package definition to capture more transactions. Two jurisdictions, two opposite strategies, one operator trying to sell into both.
The problem
Since Brexit, UK travel regulation has diverged from EU law. The UK retained the 2015 Package Travel Directive through the Package Travel and Linked Travel Arrangements Regulations 2018 (SI 2018/634), but it is no longer bound by EU amendments. The UK government's 2024 consultation paper proposed removing Type B arrangements, which are linked travel arrangements facilitated by a trader who does not collect payment. The UK rationale is deregulatory: Type B arrangements created compliance costs without clear consumer benefit, since the facilitating trader collected no money and had limited ability to provide redress.
The EU is taking the opposite approach. Rather than selectively removing one type of linked arrangement, the EU reform removes the entire LTA category and widens the package definition. Transactions that were previously LTAs in the EU will now either be full packages with full organiser liability, or standalone services. For operators selling packages or facilitated arrangements to both UK and EU consumers, this creates two compliance tracks with different classification rules, different liability structures, and different penalty regimes.
UK deregulation: narrowing the scope
The UK consultation proposed removing Type B linked travel arrangements entirely. Type B arrangements occur when a trader facilitates a second travel service booking without collecting payment for both services. Under current UK rules, the facilitating trader must provide insolvency protection for Type B arrangements. The UK government's position is that this obligation is disproportionate given that the trader holds no customer funds. If implemented, traders facilitating Type B arrangements in the UK would have no package travel obligations. Only Type A arrangements (where the trader collects payment) and full packages would remain regulated.
EU tightening: widening the net
The EU reform takes the opposite path. By deleting LTAs and widening the package definition, the EU pulls more transactions into full regulation. The 24-hour linking window and targeted booking process tests from the 2015 Directive are being replaced with broader criteria. The EU's position, supported by the Commission's 2023 impact assessment, is that consumer confusion between LTA and package protections justified removing the intermediate category. The penalty ceiling of 4% of annual turnover adds enforcement weight.
The dual-compliance cost
An operator selling a hotel-plus-transfer combination to a UK consumer may have no linked travel obligations if Type B removal proceeds. The same transaction sold to a German consumer could be classified as a full package under the reformed EU directive, triggering organiser liability, prepayment caps, and information duties. Booking systems, terms and conditions, insolvency protection arrangements, and supplier contracts may all need jurisdiction-specific variations.
What to do now
Map every product you sell into both UK and EU markets. For each, determine the classification under current UK rules, proposed UK rules (post Type B removal), current EU rules, and the reformed EU directive. Build a matrix showing where obligations diverge. Prioritize contract language that addresses the highest-liability jurisdiction first, which in most cases will be the EU. Track both the UK consultation outcome and the EU transposition timeline in each member state where you operate.