The following has been added to the Guidance to the Code of Conduct in section 3 on significant changes between booking and travel.
 
The Code of Conduct Committee is likely to regard a holiday having been significantly changed for the purposes of Clause 3E of the Code of Conduct if it's changed in such a way that the revised arrangements, although not amounting to a cancellation, involve the client receiving travel arrangements that can't reasonably be considered the same as those initially booked, including, for package holidays, situations where the Foreign, Commonwealth & Development Office (FCDO) advises against all travel, or against all but essential travel to the destination and this is current at the due date of departure. 

In such cases the Committee would expect the client to be offered a full refund.
If a Member refuses to offer a full refund in such circumstances, the Committee will consider whether there is any reason why a refund should not be payable.

If the Committee receives complaints from clients who say that they believed that would receive a refund in these circumstances, it is likely that they will find that a refund is due. If a Member wishes to assert that a refund is not due the Committee will require clear evidence that the client understood that they were entering into a booking on the basis that there would not be a right to a refund in the particular circumstances and the consequences of that.

In such cases, the Committee will consider how clearly and prominently the refund policy was set out in the contract. The Committee will consider how clearly it was brought to the client’s attention before they booked and whether the client did expressly and specifically agree to the policy.  

Members are warned that the above guidance does not bind the courts or any other regulator. For package holidays, clients will always have the right to a refund if Regulation 12(7) of The Package Travel and Linked Travel Arrangements Regulations 2018 applies.

Any contract terms you use to agree with your client that you won’t pay a full refund in the event of FCDO advice against travel affecting their package holiday may be void as unfair under the Consumer Rights Act 2015 and could potentially breach the requirements of professional diligence under the Consumer Protection from Unfair Trading Regulations 2008.