The proposal in the CAA’s draft standard terms, about the information provided to consumers before and after sale on ATOL protection, is one example of going beyond what is in the PTD. Similarly plans to introduce a mandatory schedule of agency terms for EEA traders selling in the UK and plans to require small business holders to report quarterly, rather than annually, are also not required for the implementation of the PTD.
ABTA has launched a consultation with Members in order to get their views and insights to inform its response to the consultations. Members have until Friday 16 March to provide their feedback by completing ABTA’s survey.
ABTA will also be holding a conference call with Members on Tuesday 13 March, which will be an opportunity to hear more about the draft regulations and standard terms, and raise any particular questions.
Simon Bunce, Director of Legal Affairs at ABTA said: “The travel industry would be forgiven for thinking that the content of the draft ATOL Regulations and standard terms are only to support the UK’s implementation of the Package Travel Directive. But, having read all of the documents in detail, that is clearly not the case.
“Some of the proposals go beyond what is required for the successful implementation of PTD. So it is important travel companies are aware of the suggested changes, the impact it could have on their businesses – and that they take the opportunity to provide their feedback through the consultation process.
“We encourage ABTA Members to share their feedback with us as part of our own consultation process. ABTA will also be making the point to the CAA and DfT that any additional changes to regulations or standard terms, which don’t relate to the PTD, shouldn’t be pushed through on the same tight timescale, and that some elements may require further consultation, particularly where the current consultation contains only proposals and no firm drafting that can be properly assessed.”