An ABTA spokesperson said:
“ABTA supports the need to reform the ATOL regime in order to ensure that it is an effective, sustainable, and proportionate scheme. Future changes will be important to provide adequate and robust consumer protection. However, given that significant reform of Package Travel Directive is already taking place at the European level and the Department for Transport is already carrying out a fundamental review of ATOL and its financing, ABTA is calling on the CAA to place on hold its own reform of the ATOL system until those processes conclude next year.
“There are, for example, over 900 businesses that would be impacted by the proposed removal of the Small Business ATOL scheme – nearly half of all ATOL holders – meaning the changes proposed are not matters of routine management of the ATOL scheme – they are fundamental and go to the heart of the issues under consideration by the DfT. A revised Package Travel Directive is expected in spring or summer of 2015 and we believe that given the potential for significant subsequent changes, the correct thing for the CAA to do is to review the implementation of ATOL after the current DfT review processes are complete.
"More broadly we also strongly believe that change should take shape in a way that does not act as a barrier to micro businesses and SMEs but provides a fair and proportionate approach that is suitable for all business models. The current proposals represent a very significant increase in barriers to entry.
"ABTA calls on the CAA to pause its consultation process and to align it to the timeline of the DfT, to follow the conclusion of BIS/European process in the first half of 2015. Meanwhile, ABTA will continue to engage with the CAA, DfT and BIS, and with our Members, on ATOL reform and the future of Package Travel regulation."
A copy of ABTA’s full consultation response can be viewed here.