ABTA believes implementation of the Package Travel Directive 2015 must be the overriding, immediate, priority for both regulators and the travel industry, especially given the lack of available time for businesses to adjust to regulatory changes before implementation deadline of 1 July. Member States were required to have put in place the required implementing laws for the 2015 PTD by 1 January 2018. Any broader changes to the basic operation of the ATOL scheme, which are not necessary for the implementation of PTD, should be subject to a thorough consultation process with the industry and appropriate implementation lead times.
There are several implementation issues where ABTA believes practical improvements could be made to drafting of regulations. However, we recognise that the Government has left itself very little time to consider alternative proposals. We would urge further consideration of these matters, where the opportunity exists.
It is extremely difficult for consultees to fully address these issues as the new BEIS Package Travel and Linked Travel Arrangements Regulations, implementing the 2015 Directive, have also not been implemented by 1 January 2015 or to date. Furthermore, they have not been consulted on and have not been provided in draft form. We have also raised our drafting comments with BEIS. Coordination between BEIS and DfT in relation to these matters is essential.