How does a trust account impact your cash?

Trust accounts are increasingly seen as the preferred form of security for our industry. They have been used throughout the travel supply chain to cover a multitude of potential risks since the failure of Thomas Cook and a devastating global pandemic sent insurers and their capacity running for the hills.

There are many things to consider when deciding whether a trust account is right for you. Above all, you must understand the impact on your cash flow. Client funds will be held in a segregated account and your ability to move the money will be restricted. A detailed cash flow model is essential, and frankly, getting it wrong could be disastrous.

So, here’s what you need to consider.

Timing your cash inflow

Depending on the purpose of your trust account, it may hold all customer funds or just a subset (e.g. only ATOL bookings).  Some operators collect all customer funds into one central account and then split out protected funds into the trust. Or you can arrange for your card processor to send funds directly into the trust. You may also need to separate different foreign currencies into different trust accounts.

Whichever approach you choose, the timing difference between your customer handing over money and you receiving it could be critical.

Any delay in receiving cash may mean you would have to front up the money in advance from your own cash flow. For example, if you’re on ‘deferred settlement’ terms with your card processor (i.e. you wait more than 3 days to collect), or if you sell via a travel agent, and they hold onto funds for longer than two weeks before passing it over to you.

The gross amount paid by your customer should be protected and go into the trust – no offsetting card processor charges and no leaving out the commission paid to the travel agent. For some, this might mean changing previous payment and commission arrangements and your IT systems or card processing set-up will need to be able to identify and separate out which monies require protection.

When funds are released

The default position under Package Travel Regulations is that funds can only be released once the booking has been performed. In other words: no money until the customer comes home.

Now, there are some caveats. Money can sometimes be released earlier, but only in very specific circumstances. For example, an ATOL trust might allow funds to be released for certain authorised booking components, as long as they’re covered by Supplier Failure Insurance or Chargeback via a corporate credit card. Similarly, a non-flight package trust may permit early release where the money is protected by a gap insurance policy.

It’s also worth highlighting that robbing Peter to pay Paul is strictly forbidden. Any customer refund can only be paid out from the amount held in trust.  So if supplier payments have already been released, you’ll need to get them refunded before the customer can be repaid.

Funds are usually claimed out of the trust using a Payment Request mechanism. You must provide evidence that the holiday has been delivered, cancelled or refunded, or in some cases that a supplier has been paid from your own cash flow first before funds can be released from the trust.

Before trust, comes knowledge

To understand whether a trust account could work for your business, you need a robust financial model that illustrates the impact on your cash flow.

If you need any help, feel free to get in touch.

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Road to recovery – key milestones on the journey back to travelling

Throughout the pandemic, there have been endless amendments, extensions and general tinkering to support schemes, regulatory rules and compliance obligations. To help keep track of these changes, we’ve updated our previous infographic of the critical dates that travel businesses need to be aware of over the coming months.

Map of travel dates

*Discount scheme:
• 100% off your business rates bills for the first 3 months of the 2021 to 2022 tax year (1 April 2021 to 30 June 2021)
• 66% off your business rates bills for the rest of the 2021 to 2022 tax year – up to a total value of £2 million
Find out if you’re eligible here.

If you would like a copy of the roadmap or need help determining what any of the dates mean for your business, please get in touch.

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The COVID-19 crisis is rapidly evolving and the Government's response and the details of support on offer are continuously changing. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn. If you have any questions in the meantime, please get in touch. 

Four characteristics of a travel trust account

Up until 2019, trust accounts were relatively rare in the travel sector. Insurance and bonding were the dominant forms of security though that changed in late 2019 when Thomas Cook Group failed. The insurance industry suffered substantial losses leading many insurers to exit the market. 

Throughout 2020, as the pandemic accelerated the exodus of insurance capacity, trust accounts have stepped in to fill the void in the consumer protection infrastructure. We are seeing regulators, insurers, merchant acquirers and other stakeholders increasingly turn to trust accounts. Even customers are becoming more trust aware, thanks to several high profile travel businesses pushing their virtues heavily in their marketing material.  

In reality though, the term “trust account” is currently being used to describe a whole spectrum of substantially different arrangements. 

So if you’re considering setting up a trust account for your travel business, or you’re being asked to accept a trust account as a means of security, there are four basic key characteristics you should understand.

1. Who is the beneficiary?

Trust accounts can be used to protect a range of different stakeholders. They are one of the accepted methods for organisers to protect consumers’ money under the Package Travel Regulations (PTRs). However, nervous insurers, merchant acquirers, lenders and other stakeholders are increasingly asking operators to provide them with security by holding monies in a trust fund. 

Any trust arrangement must make clear who is the ultimate beneficiary, to avoid any confusion in the event of a failure.  

2. Where and how is the money held?

Understanding how and where the money is physically held is critical to understanding how robust the trust arrangements are. In practice, we see a wide range of structures. At one end of the spectrum, monies are held in an independently controlled bank account that cannot be accessed by the trust account holder. At the other end of the spectrum, the account being described as a trust is little more than a different current account with no separation or controls. 

There are many other nuances to consider. 

– Do 100% of customer funds go into a trust or only one class of bookings (eg ATOL bookings).
– Do funds go straight into the trust account or sit somewhere else first (sometimes referred to as an interim account).
– Who has access to the bank account and therefore control over the inflow and outflow of monies?

3. Who are the trustees? 

The trustee plays a pivotal role in the operation of a trust account. They are responsible for managing and controlling funds to ensure the trust account operates in the best interests of the beneficiaries  

There are no formal qualifications for acting as a travel trustee. The PTRs are vague on the qualifications or attributes a trustee must demonstrate, though they do state they must be independent of the organiser. 

When it comes to ATOL trusts, the CAA is more strict. They only permit a narrow range of approved trustees that can demonstrate travel sector knowledge and competence, together with an appropriate level Professional Indemnity (PI) insurance.

Outside of these regulatory frameworks, there is no oversight of the trustee role. We see a wide range of individuals or organisations acting as trustees. Usually, it falls to an accountant or lawyer, but we have seen cases where a company’s own directors or relatives take on the role. 

4 – How are the trust rules documented?

Finally, the rules of the trust account should be codified in a formal Trust Deed. The Trust Deed is a vital document for creating a legal water-tight trust structure and requires careful legal drafting to ensure that the beneficiary and their funds are 100% protected.

The terms of the Trust Deed can be complex (the CAA’s standard ATOL trust deed runs to more than 60 pages). As a minimum they should set out:

– What monies should be paid into trust, and when
– When funds can be released, including cancellations, refunds and other common amendments
– Who are the beneficiaries
– What are the triggers for releasing trust funds to the beneficiaries

Setting up a trust account for your travel business can be complicated and you may need to consider a range of commercial, regulatory, legal, accounting, financial and tax issues. We’d be delighted to help you understand, model and implement a trust account for your travel business. Please get in touch for more information.

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IATA has made some changes

In all the mayhem of the past few months, it may have escaped your notice that IATA has introduced a number of changes to its approach for assessing UK ticketing agents.

These changes could have material and wide-reaching consequences for your business, and you should review their impact carefully.

Here we have summarised our view of the most significant changes and identified some areas for you to consider. We hope you find it useful, but please remember, this is not meant to be an exhaustive list of all impacts. As always, there is no substitute for advice which is specifically tailored to your business!

We’ve covered:

-Changes to Local Financial Criteria
-New method of calculating Risk Holding Capacity
-New rules on the horizon for large agents

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If you have any questions, please get in touch.

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Preparing for March ATOL renewals

If you are due to renew your ATOL licence this March, there are a few areas that we wanted to make you aware of as you prepare to go through the process. TTC Director, Simon looks at changes to the financial criteria, additional information you may need to provide, Refund Credit Notes,  the impact of Brexit on EU sales, and security.

If you need any help processing your renewal, please get in touch. 

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The COVID-19 crisis is rapidly evolving and the Government's response and the details of support on offer are continuously changing. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn.  If you have any questions in the meantime, please get in touch. 

Brexit: focus areas for travel businesses

Now that the end of the Brexit transition period is less than a month away, it is more important than ever that travel companies understand how this might impact them. From 1 January 2021, there will be new rules in place, many of which will affect the travel industry. Below are 11 key areas that you should consider when getting your business ready for these changes.

We have also created a Brexit risk matrix to help you capture and document the key risks and considerations for your business. Download your free template here.

Recently, we discussed the above areas during a webinar hosted by our partner The Travel Vault. The recording is available here.

If you need any help understanding how these changes might impact you, please get in touch. 

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Guidance on Brexit is continually being updated as we progress through the transition period. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn. If you have any questions in the meantime, please get in touch. 

The growth of integrated travel companies

The challenges faced by airlines and tour operators during this pandemic are well publicised. 

Business activity has fallen off a cliff, and cash has flown out of the door as new bookings have dried up and old bookings have been refunded. 

But spare a thought for those that are both an airline and a tour operator. 

Whether you think of them as tour operators with their own airline (TUI, Jet2) or airlines dabbling in tour operating on the side (easyJet, BA, Virgin), integrated groups now represent five of the top 20 ATOL holders in the UK. You can see how the size of their ATOLs, which cover their flight inclusive package holidays has grown over the last eight years in our interactive chart here

When times are good, there are plenty of solid reasons why a vertically integrated, asset-heavy model is a no-brainer for a travel company. The ability to control the delivery of your product, manage your supply chain, and guarantee access to flying capacity are all invaluable when you’re selling holidays at scale.  

Of course, the trade-off is a massive reduction in flexibility. Operating an airline is incredibly capital intensive, especially when most of the aircraft are stuck on the ground. Easyjet and BA are still burning through £8million (easyJet) and £20million (BA) a day, despite flying less than 30% of their capacity and carrying out major cost-reduction programmes. 

On the face of it, asset-light companies should be able to weather the current storm better than the integrated groups. Take the third-largest ATOL holder, On the Beach, for example. Despite the pandemic, they are still trading at break-even thanks to their more variable cost base

On the other side of this crisis, though, integrated groups have a unique opportunity to reassert themselves. 

Right now, customers simply aren’t booking holidays. Interestingly, anecdotal evidence suggests that they fear the prospect of further quarantine more than catching COVID.

Travel corridors change weekly and destination access can be restricted within hours of a government announcement. Nervous customers are either avoiding commitment or deferring decisions until the last possible minute and booking much closer to departure. 

In order to stimulate demand in that kind of environment, tour operators and integrated groups have two moves: drop their price, or offer as much flexibility as possible, with options to change or cancel trips at minimal cost. 

Whilst larger tour operators are generally able to negotiate favourable terms with most of their suppliers to enable them to offer such flexibility, their airline suppliers have so far been unwilling to play ball.  

Integrated groups, on the other hand, have a unique advantage, and are offering innovative terms to their holiday customers that aren’t available to other tour operators. In recent weeks we’ve seen a few examples emerge: 

– TUI is offering customers the flexibility to change their holiday with no fee, up to 21 days before departure.  

– Easyjet Holidays launched a ‘Protection Promise’ offering fee-free changes or cancellations to holidays up to 28 days before departure.

– Virgin Atlantic Holidays announced a new ‘Escape Pass’. Customers choose their dates and hotel rating and will be guaranteed a holiday in the Caribbean where they won’t be subject to quarantine rules and restrictions. The customer will only find out two weeks before departure which destination they’re going to.

– BA Holidays are offering customers the ability to change destinations, dates or cancel altogether with three weeks notice. 

Owning their own airlines has given these integrated groups the ability to create flexible, unique, and highly defensible product offerings. 

All they need now is the recovery to take off. 

 

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The rapid rise of online travel agents

Yesterday, we shared an interactive graph showing the movement of the top 20 ATOL holders from 2013-2020. We also gave some initial insights extracted from our deep dive into the data. 

Over the next couple of weeks, we will be drilling down into these insights. 

Firstly, we’re exploring the rise of online travel agents.

Over the past eight years, we have seen the rapid rise of online travel agents (OTAs). 

They are built on slick, scaleable technology, selling primarily ‘fly and flop’ holidays and allowing customers to dynamically package a wide range of low-cost carrier flights and accommodation offers. 

By October 2020, six of the top 20 ATOL holders could be classed as OTAs, where online distribution is their dominant channel as well as their key characteristic. Given the business model barely existed a decade ago, their growth rate has been phenomenal. For example, the largest UK OTA, On the Beach increased its ATOL from 639,000 passengers in 2013 to 1.65 million by 2019, a compound annual growth rate (“CAGR”) of 17%. 

Loveholidays, a prominent PE-backed OTA grew from just 167,000 pax in 2015 to 1.37 million in 2019, a staggering CAGR of 69%! 

Faced with the onset of the pandemic, both businesses reduced their licence projections by around a fifth as the UK went into the first lockdown in March 2020. However, this was far less than the market as a whole which is down 33%

Will online travel agents continue to grow? To answer this question, we have to look at how consumer spending habits have changed as a result of the pandemic. 

How has COVID-19 changed consumer spending? 

UK consumers continued to spend money in spite of the pandemic. However, the closure of shops and restrictions on mobility drove an unprecedented shift to online channels over the past eight months. 

Data from the Office of National Statistics (ONS)* shows that over the past decade, consumers have been shifting online at a rate of around 1% per year. This leapt 9% in the 12 months to September 2020.  

Sadly, travel spending was a negligible proportion in the last eight months, but it is clear that consumers are far more comfortable transacting online than they were pre-pandemic.

In addition, a recent study from McKinsey indicated that the shift online transcends demographics, with older and historically more-technophobic generations turning to online purchases to ease the boredom of lockdown.  

So the prospects look great for OTAs post-pandemic? 

Not so fast! COVID-19 has been indiscriminate in its devastation of the outbound travel sector and OTAs have had as tough a time as any. Their technology has been unable to cope with huge numbers of cancellations, forcing them into laborious manual refunding processes. On top of this, the OTAs have been disproportionately affected by the delayed refunds from the low-cost airlines, resulting in customers receiving only part of their money back. 

Without a strong human relationship to fall back on, they have been roundly condemned in the consumer media. For example, On the Beach, loveholidays, lastminute.com and Travel Republic, all score poorly in this Money Saving Expert ‘70 best and worst firms for travel refunds‘ list.

Incidentally, the report named Trailfinders and Travel Counsellors as the top two. Both are businesses where human interaction powers the vast majority of distribution. 

It’s all to play for.

Going forward, we think travel will remain complicated for the foreseeable future. We expect travel restrictions to remain inconsistent, corridors to remain dynamic and testing and quarantine requirements to differ country by country. 

In this environment, it’s easy to imagine customers returning to service-led, knowledgeable, human travel professionals. This Advantage Travel Partnership study in October 2020 appeared to support this theory. 44% of 25-34-year-old respondents said they are likely to consider using a travel agent in future. 

At the same time, we know consumers have notoriously short memories. Customers at the value end of the market can always be enticed by bargain prices, leaving plenty of room for OTAs to recover when the great refund crisis fades from memory. 

However, we think the biggest opportunity is change itself. That same Mckinsey study reported unprecedented levels of customer habit changes over the past eight months, with over 63% of UK respondents reporting switching to a new brand, new service or new retail outlet for the first time. 

In that kind of environment, it’s all to play for.

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*ONS data, the proportion of total non-food sales online increased 9ppts from 14.7% in September 2019 to 23.7% in September 2020. The change from September 2018 to September 2019 was 0.3ppts. The average annual increase over the last five years to September 2019 was 1.1ppts per year. 

Deep dive into ATOL renewal data: 2013-2020

TUI and Jet2holidays are currently the top two ATOL holders, but how does this compare to the last eight years? What was the impact of the collapse of Thomas Cook, Monarch and others on the top 20?

We’ve spent some time digging into the ATOL renewal data between 2013 and 2020 and have pulled out some interesting trends. We have also charted the movement in the top 20 on the graph below. 

You can use the cursor to pause the graph or move to a specific year.

Here are a few trends we uncovered:

Consolidation in the market – the top three ATOL holders now hold the licenses for almost half (48%) of licensed passengers. The top 10 now hold the licences for more than two-thirds (68%). Will customers be increasingly drawn to the mega brands, especially if we start to see further smaller operators failing, or will they look to more niche operators?

–  Shift to online sales with the rise of On the Beach, loveholidays, and others, online travel agents have become a more popular way for customers to book holidays. Will this shift online continue to increase or will the complexities surrounding travel such as testing, quarantines and restrictions in destinations mean that customers will seek reassurance from speaking to an agent? We explore this question here. 

Increase in airline holiday companies the rapid rise of Jet2holidays, the steady growth of BA Holidays and the relaunch of easyJet Holidays means that three of the top six ATOL holders are now airline holiday companies. Will we see Wizz Air and Ryanair follow suit? Take a look at our further analysis of this trend here. 

The number of small ATOL holders has remained flat although not shown on the graph above, it was encouraging to see that there hasn’t been a decline in the number of Small Business ATOL holders (500 licensed passengers) between 2019 and 2020 and that there were also around 90 ‘new’ ATOL holders in the 2020 renewals. Will we see any innovative new package travel companies emerging from the crisis?

Over the next few weeks, we’ll be delving deeper into these trends and sharing plenty more insights. Keep an eye out here or follow us on LinkedIn.

If you would like more information on how we’ve analysed the data, please get in touch.

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Source data is from the ATOL website downloaded at various intervals over the eight years. The data for each year is based on the company's forecasts submitted in that year's March or September renewal.

Seven observations from the September 2020 ATOL renewals

The September ATOL renewal round presented many Covid-19 related challenges for those travel companies seeking to renew their ATOL licences. We helped 71 businesses of varying sizes go through the renewals process.

In preparation for the March renewals, below are a few things we noticed, including the CAA’s approach, the impact of Government loans on licences, and the restrictions placed on some businesses.

If you would like more information or a copy of the slides, please feel free to get in touch. 

We have also done a deep dive into the past eight years’ of ATOL renewal data and unearthed some interesting trends. Read more here. 

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Trust accounts in the travel sector: TTC comment in The Telegraph

TTC director Martin Alcock spoke to The Telegraph about trust accounts in the travel sector and rumours that the government plan to implement new rules to speed up refunds.

Here is the full article:

Screen grab of an article from The Telegraph on refunding customers in the travel industry

The original article can be found here – https://www.telegraph.co.uk/business/2020/09/19/travel-giants-ringfence-customer-deposits-speed-refunds/.

For information on the advantages and disadvantages of trust accounts, please see here.

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The COVID-19 crisis is rapidly evolving and the Government's response and the details of support on offer are continuously changing. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn.  If you have any questions in the meantime, please get in touch. 

Tips for renewing your ATOL licence

The deadline for submitting your ATOL renewal is fast approaching. If you are due to renew your licence this September and haven’t yet started the application process, we recommend you do this now. We are currently working on our client’s renewals and have some insight into what information the Civil Aviation Authority (CAA) require. Here are our top four tips for renewing your licence.

If you need any help applying for an ATOL licence, or have any questions about the process, please get in touch. 

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The COVID-19 crisis is rapidly evolving and the Government's response and the details of support on offer are continuously changing. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn.  If you have any questions in the meantime, please get in touch. 

Financial tests for ATOL licences

The Civil Aviation Authority’s (CAA) approach to financial assessments largely depends on the size of the ATOL licence required. As the licence size increases, so does the potential exposure to the Air Travel Trust Fund. Therefore, the CAA requires larger businesses to provide more financial information than smaller ones. This diagram demonstrates the commonly requested information needed by the CAA for September 2020 renewals. It takes into account the additional information required due to Covid-19.

If you need any help applying for an ATOL licence, or have any questions about the process, please get in touch. 

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The COVID-19 crisis is rapidly evolving and the Government's response and the details of support on offer are continuously changing. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn.  If you have any questions in the meantime, please get in touch. 

Brexit: six areas of your travel business that are likely to be impacted

Update: We have recently updated our Brexit guidance as further details have been announced. You can read our new blog post here.

It may have been pushed to the back of our minds by a worldwide pandemic, but sadly, Brexit and its many related challenges have not gone away.

The UK officially left the European Union (EU) on 31 January 2020, entering a transition period which is scheduled to last until 31 December 2020. Both sides are currently in the process of negotiating a new trading relationship.

Whatever the outcome of the next few months’ negotiations, there will be challenges for the travel industry, and your business may have to adapt. Here are six key areas that are likely to be impacted: 

1 – Employees

Worker’s rights will feature heavily in any trade deal, and if you employ EU nationals in the UK, or you post UK workers to EU countries, new rules are likely to affect you. 

We understand many EU member states have put processes in place to allow UK citizens to continue to work if no trade deal is agreed. However, there may be restrictions on the length of time workers would be allowed to stay in an EU country. 

Furthermore, any new agreements for workers’ rights are only likely to apply to those living and working in the country before Brexit, which may present issues for seasonal workers. 

Similarly, the recent UK Immigration Bill introduces a series of restrictions on companies rights to employ non-UK workers. In particular, the salary threshold of £25,600 is likely to capture a higher proportion of roles in the travel sector compared to many others and could lead to a shortage of suitable candidates. 

2 – VAT

The Tour Operator Margin Scheme (TOMS) is an EU-wide simplification measure that means EU tour operators don’t have to register for VAT in every member state in which they operate. 

We understand that any trade deal would likely preserve the current system. However, in the event of a no-deal Brexit, HMRC has proposed to change the rules, making travel services to all destinations outside the UK (including the EU) zero-rated. The good news is that only the margin on UK travel services will be subject to VAT, which could result in significant savings for many outbound tour operators. 

However, EU member states will likely require UK operators to separately register for VAT in each territory in which they operate, which would present a significant administrative burden for many travel companies.

 3 – Key information 

Under the Package Travel Regulations, package organisers must provide accurate information to customers on various matters including passports, visa requirements, healthcare support. 

Passengers travelling after 1 January 2021 are likely to need at least six months remaining on their passport.

We understand UK travellers will still be allowed to visit EU countries for up to 90 days without a visa, but only if the UK continues to grant reciprocal rights to EU citizens visiting the UK. 

Though unrelated to Brexit, from 2022 all visitors to the EU will need to complete an application through the EU Travel Information and Authorisation System (ETIAS) and pay a fee before entering the Schengen Area. This will even include citizens of countries with a visa-free travel agreement in place. 

It is still unclear what arrangements will be in place for UK nationals should they need access to health care when in an EU country. If the EHIC card is no longer valid when we leave the EU, you will need to make sure you direct your customers to the correct advice.  

You must ensure that you have systems in place to monitor any changes to these information requirements, and to inform your customers where necessary. 

4 – Flights 

In a post-Brexit world, airlines may need to ask for permission to fly into EU air space, and airlines based in the EU will have to do the same when flying into the UK. This could present challenges if permission isn’t granted on time. 

The current transition arrangements allow flights between the UK and the EU to continue as they were. What happens beyond 31 December 2020 is still being negotiated. 

5 – Regulation and licensing

Under the current European regulatory framework for selling package holidays, companies who are established and compliant with the rules of one EU member state can sell holidays in every other EU member state.  

Non-EU companies must comply with the rules in each and every member state in which they sell holidays. 

Once the UK falls outside of these rules, many companies are likely to require a change to their current licensing arrangements following the end of the transition period. For example: 

    • EU established firms wishing to sell flight-inclusive holidays in the UK from 1 January 2021 are likely to need to hold their own ATOL.
    • UK established firms wishing to sell holidays in the EU will need to either create a new subsidiary place of establishment in an EU member state or register with the financial protection scheme of each member state in which they operate.   

 

In addition, if you use insurance bonds to meet your financial protection obligations, then you should also check with your insurer or insurance broker that they can continue to issue valid bonds following the end of the transition period. 

6 – Foreign currency

The Pound Sterling has been on a volatile rollercoaster ride ever since the UK voted to leave the EU in 2016. Its value has fluctuated dramatically with each twist and turn of the withdrawal process, and it remains impossible to predict.

As the trade negotiations proceed, we expect this pattern to continue. Travel companies must have a robust strategy in place for managing their foreign currency risk. 

There are still many unanswerable questions at this stage. Through the continuing negotiations, we’ll be providing updates, analysis and insight on our website and through our social media channels. If you need support in the meantime, please get in touch.

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Guidance on Brexit is continually being updated as we progress through the transition period. We'll be updating our posts regularly to ensure our analysis and advice remains as accurate and useful as possible. To receive the very latest information as we release it follow us on LinkedIn. If you have any questions in the meantime, please get in touch.