Holiday Disputes

How to Get a Refund on a Package Holiday UK

·12 min read
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Over 20 million package holidays are sold in the UK every year. The Package Travel and Linked Travel Arrangements Regulations 2018 are the most powerful consumer protection most of those holidaymakers have never heard of.

A package holiday is not just an all-inclusive resort booking. Any combination of flight and hotel — or transport and accommodation — sold through one trader qualifies, even when the elements are listed separately on the booking platform. TUI, Jet2 Holidays, easyJet Holidays, On the Beach: all packages. A custom combination you built through one website: also a package.

The company that sold you your holiday has a legal obligation to refund you. Not a goodwill gesture — a legal obligation.

This guide covers exactly what qualifies as a package, your seven core rights under the Regulations, what “unavoidable and extraordinary circumstances” actually means (and what it does not cover), the full six-step escalation process, and what your refund demand letter must contain.


What counts as a package holiday

The Package Travel and Linked Travel Arrangements Regulations 2018 (SI 2018/634) — which implement the EU Package Travel Directive 2015/2302 in UK law — define a package as a combination of at least two of the following, sold by one trader for the same trip:

  • Transport (flights, coaches, trains, ferries)
  • Accommodation (hotel, villa, apartment, cruise cabin)
  • Vehicle rental
  • Other tourist services — tours, sports events, excursions — where they account for a significant proportion of the package

The combination must be for the same trip, last at least 24 hours or include overnight accommodation, and be sold by one trader — whether presented as a single offer or selected separately on the same booking platform.

What qualifies

TUI, Jet2 Holidays, easyJet Holidays, On the Beach, and loveholidays packages. A flight plus hotel selected separately on one booking website where one trader completes the transaction. A cruise (which combines transport and accommodation by nature).

What does not qualify

Booking flights directly with an airline and a hotel separately through a different platform with no intermediary. Each element is a standalone contract — different regulations apply to each.

Linked Travel Arrangements (LTAs)

Where a trader facilitates the separate booking of at least two travel services for the same trip (for example, clicking through from a flight booking to a hotel booking on a partner site), this may be a Linked Travel Arrangement rather than a full package. LTAs receive less protection than packages — but they are still covered by the Regulations and the organiser must provide insolvency protection.

If you are not certain whether your booking qualifies, apply the two-element test: did one trader sell you at least two of flight, hotel, car hire, or tourist service for the same trip? If yes, you almost certainly have a package.


Your seven rights under the Package Travel Regulations 2018

The Regulations give package holiday consumers a specific set of rights that sit on top of general consumer law. These are the ones that matter most.

1

Right to cancel for a significant change

Regulation 11

If the organiser notifies you of a significant change before departure — including a change of destination, departure point, major reduction in accommodation quality, or accommodation type change — you are entitled to cancel the booking and receive a full refund. You must be given a reasonable deadline to accept the change or cancel. Accepting a substitute package with comparable or higher value is also available if you prefer.

2

Right to full refund on organiser cancellation

Regulation 13

If the organiser cancels the package — for any reason, including 'unavoidable and extraordinary circumstances' such as natural disasters or serious public health risks — you are entitled to a full refund within 14 days. This is a statutory deadline, not a target. Many companies breached this during the COVID-19 pandemic and were successfully pursued through ABTA ADR and the courts.

3

ATOL protection for flight-inclusive packages

Civil Aviation Act 1982 / ATOL Regulations 2012

Any package holiday that includes a flight and is sold by a UK ATOL holder must be financially protected under the Air Travel Organiser's Licence scheme. Every ATOL-protected booking must be accompanied by an ATOL certificate — if you did not receive one, that is itself a breach. If the company fails before or during your travel, the Civil Aviation Authority (CAA) will either refund you or arrange for you to complete your holiday.

4

Insolvency protection for non-flight packages

Regulation 18

For packages that do not include a flight, the organiser must hold insolvency protection — typically an ABTA bond. ABTA members are bound by the ABTA Code of Conduct and are covered up to the bond amount in the event of insolvency. Check whether your organiser is an ABTA member at abta.com before booking, or at the point you need to make a claim.

5

Right to transfer your booking

Regulation 9

You may transfer your booking to another person — at least 7 days before departure — with reasonable notice to the organiser. The organiser may charge only the actual additional costs arising from the transfer (for example, airline name-change fees). They cannot impose arbitrary transfer charges beyond actual cost.

6

Surcharge limits

Regulation 10

Post-booking price increases are only permitted to pass on genuine cost increases in fuel, taxes, or exchange rates. If the organiser increases the package price by more than 8% of the total price, you have the right to cancel with a full refund. No surcharges may be applied within 20 days of departure, regardless of cost increases.

7

Price reduction for unused services

Regulation 15

If your holiday is cut short — whether due to circumstances affecting you personally or due to problems at the destination — you are entitled to a price reduction proportional to the services not provided. This applies whether you leave early voluntarily (where the circumstances warranted it) or where the organiser failed to deliver contracted services.


ATOL certificate — check it before you need it

Every UK package holiday that includes a flight must be sold by an ATOL holder and must provide an ATOL certificate at or before the point of booking. Check yours now: the ATOL number, the organiser's name, and your travel dates should all appear. If you did not receive a certificate, the organiser may have breached their obligations under the ATOL Regulations 2012.

If the company fails, the 14-day refund window under Reg 13 still applies — and your ATOL number is required for a CAA claim.


What “unavoidable and extraordinary circumstances” actually means

Regulation 13(3) of the PTR 2018 permits organisers to cancel without paying compensation (above the refund itself) where cancellation is caused by unavoidable and extraordinary circumstances. The Regulation gives examples: natural disasters, war, acts of terrorism, serious public health risks.

COVID-19 litigation confirmed that widespread pandemic cancellations did qualify as unavoidable and extraordinary circumstances for the purpose of Reg 13(3) — meaning organisers were not liable to pay additional compensation. However, the statutory 14-day refund requirement was not affected. Many companies delayed refunds significantly beyond the 14-day window during 2020–2021 and were successfully pursued through ABTA ADR and the courts for breach of the refund deadline.

One important limit: financial difficulty or insolvency on the part of the organiser is not an unavoidable and extraordinary circumstance. A company that cannot afford to refund you is not exempted from the obligation to do so — ATOL protection and ABTA bonding exist precisely to ensure the refund is paid even where the organiser cannot pay it themselves.


The six-step escalation process

Each step builds the legal record that makes the next one more powerful. Most disputes resolve at steps one to three — but knowing steps four to six changes how you write the first letter.

1

Submit a written refund request

Write to the organiser — by email or recorded post — citing either Regulation 13 (organiser cancellation) or Regulation 11 (significant change) of the Package Travel and Linked Travel Arrangements Regulations 2018. State clearly that you are entitled to a full refund within 14 days under the Regulations. Include your ATOL certificate number if the package included a flight. Keep a copy of everything you send.

2

Raise a formal complaint

If the organiser does not respond within 14 days or disputes your entitlement, escalate to a formal complaint in writing. If the organiser is an ABTA member, cite the ABTA Code of Conduct — ABTA members are bound by its standards and by ABTA ADR. Set a further 14-day deadline and state that you will refer to ABTA ADR if not resolved.

3

ABTA Alternative Dispute Resolution (ADR)

ABTA's ADR scheme is free for consumers and its decisions are binding on ABTA members. It covers both ATOL and non-ATOL packages where the organiser is an ABTA member. You can submit a claim at abta.com/complaints. Typical resolution time is 28 days. This is a powerful step — a binding ADR decision does not require court proceedings.

4

CAA ATOL claim — if the company has failed

If the company has become insolvent and held ATOL protection, submit your claim directly to the Civil Aviation Authority at caa.co.uk/atol-protection/consumers/make-a-claim. Act promptly — the CAA processes claims in order of receipt. No formal time limit is stated, but early submission is strongly advisable.

5

Section 75 or chargeback through your bank

This is a parallel route and can be pursued alongside other steps. If you paid by credit card and the purchase was between £100 and £30,000, Section 75 of the Consumer Credit Act 1974 makes your credit card provider jointly liable. If you paid by debit card, a chargeback request under Visa or Mastercard scheme rules is available. Contact your card issuer directly. Act within 120 days for chargeback, though the Section 75 limitation period is 6 years.

6

Small claims court

For claims under £10,000 in England and Wales, the small claims track via Money Claim Online (MCOL) is the final route. Before filing, issue a formal Letter Before Claim compliant with the CPR Pre-Action Protocol. The claim is grounded in Regulations 11 or 13 of the PTR 2018. Scotland: small claims via the sheriff court. Northern Ireland: via the magistrates' court.


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What your refund demand letter must include — a 7-point checklist

A letter that triggers the 14-day statutory clock and signals you will escalate is specific, legally referenced, and evidence-backed. These seven elements are the difference between a letter that gets actioned and one that gets filed.

1

Booking reference and confirmation date

2

ATOL certificate number (if the package included a flight)

3

Name of the regulation you are relying on — PTR 2018 Regulation 11 (significant change) or Regulation 13 (organiser cancellation)

4

Exact amount claimed with a breakdown by component (flights, accommodation, transfers)

5

Evidence of the cancellation or significant change notification from the organiser

6

Demand for a full cash refund within 14 days — the statutory window under PTR 2018 Reg 13

7

Statement of intended next step if not refunded within 14 days: ABTA ADR, Section 75 claim, or small claims court

Send by email (keep a copy with sent timestamp) or by recorded post. Both create the paper trail required for ABTA ADR, Section 75, and court proceedings.


Key deadlines — act before these windows close

ATOL claim:Submit as soon as possible after company failure — the CAA processes claims in order of receipt. No formal time limit, but do not delay.
Section 75 (credit card):6 years under the Limitation Act 1980 — but your card issuer's informal window is often 120 days from a failed chargeback. Submit promptly.
Chargeback (debit card):120 days from the transaction or the expected travel date — Visa and Mastercard scheme rules. This window is strict.
ABTA ADR:18 months from the event (cancellation, significant change, or failure to refund).
Small claims court:6 years from breach of the Regulations (Limitation Act 1980 s.5).

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Jurisdiction note: The Package Travel and Linked Travel Arrangements Regulations 2018 apply across the United Kingdom. Small claims procedures differ by nation: England and Wales — County Court / Money Claim Online (MCOL), claims under £10,000; Scotland — sheriff court simple procedure, not county court; Northern Ireland — magistrates' court. ATOL and ABTA protection applies UK-wide regardless of which nation you reside in.

Frequently asked questions

Can I get a refund if I cancel the holiday myself?

No automatic right. If you cancel, the organiser's cancellation charges apply unless a significant change was made to the package. Travel insurance is the protection where you need to cancel for personal reasons. The PTR 2018 right to a full refund arises only when the organiser cancels or makes a significant change.

What if the holiday company goes bust?

ATOL covers flight-inclusive packages — the CAA will reimburse you or arrange alternative travel. Non-flight packages are covered by the organiser's ABTA bond under PTR 2018 Reg 18. Section 75 (credit card) or chargeback (debit card) is a parallel route in either case, especially where insolvency delays the primary protection.

The company offered vouchers instead of a refund — do I have to accept?

No. PTR 2018 Regulation 13 requires a full cash refund within 14 days of cancellation. Vouchers are voluntary. You are not obliged to accept them and doing so does not waive your statutory right to cash — though it is prudent to state clearly in writing that you do not accept the vouchers in substitution for your legal entitlement.

My holiday was 'significantly changed' — what counts?

Regulation 11 covers: change of destination or departure airport; departure time change exceeding 12 hours; accommodation downgraded to a materially lower standard or different type; or a reduction in the package price exceeding 8%. Minor flight time changes or room category adjustments within the same property do not qualify.

Does this apply to flights-only or hotel-only bookings?

No. PTR 2018 applies only to packages — at least two of transport, accommodation, vehicle rental, or other tourist services, combined and sold by one trader. A flight alone is covered by UK Regulation EC 261/2004 for cancellation and long-delay rights. A hotel alone falls under the Consumer Rights Act 2015.


Fight My Corner provides dispute letter generation tools and guidance — not legal advice. For complex disputes involving large sums, tour operator insolvency, or potential court proceedings, consider seeking independent legal advice from a solicitor or your local Citizens Advice bureau.