Comment: Computer says ‘go’

Following the swift introduction of the Package Travel Regulations six months ago, a review is scheduled for the New Year. Traveltek product manager Chris Brown assesses the importance of a robust software/ system so agents don’t fall foul of the law.

"A robust travel technology system that’s equipped to deal with changes and requirements is vital so agents can be alerted when a booking may be subject to the new rules under the Package Travel Regulations (PTRs).

The PTRs were introduced six months ago in response to technological innovation within the travel sector, with more businesses using dynamic packaging (DP) to personalise holidays by combining travel services from multiple suppliers.  

Before the revised PTRs came into effect, there was much ambiguity about who was responsible if a service supplier failed, and concern that not all holidays offered consumers the same level of protection. Under new PTRs, more holidays have become ‘packages’ and more people who book holidays online through travel sites enjoy the same rights as those who book with a traditional travel agent.

Providers are now required to give better information to travellers, making it clear what their rights to refund are. In addition, the regulations make online sites that enable consumers to put travel packages together responsible for the entire holiday, even if services are performed by third parties.

The updated rules do pose challenges to travel companies who use DP booking tools to create what’s now seen as a ‘package’ and, unless the booker is acting as the retailer on behalf of another supplier, their company will be considered the package provider. This means customers can claim directly with the booker for a refund or an alternative option if something isn’t provided or isn’t as expected.

This new directive mainly affects those companies who previously sold packages under the ‘Flight Plus’ model. Now that companies who provide such services will be seen as the ‘package organiser’, they may be required to take on additional responsibilities, such as holding their own ATOL. New ATOL certificates have been introduced to reflect the new bonding types which include ATOL single contract packages, ATOL multi contract packages, Flight Only and Flight Inclusive Day Trips.

The new legislation has a much more detailed list of documentation that must be provided to a customer before and after a sale is concluded. Moreover, there is now more flexibility relating to what the traveller can amend to their booking and there’s widened scope for termination of a package.  

It’s important that all front-line agents are able to be notified when a booking may be subject to the new regulations and IT systems can offer practical solutions, such as simplifying documentation stipulations requirement by giving the system admin the option to build in specific wording and templates.

For example, all the information listed in Schedule 1 of the legislation can be programmed to automatically pull from the selling system into any quote an agent sends to a client before the conclusion of the sale. Helpfully, these quotes can also be generated when required for a client using a B2C website.   

When it comes to amendments and refunds, a particularly useful feature is an audit trail function that tracks any movement within the portfolio. This allows a system user to generate a document to show all amendments, cancellations and refunds, which is time- and date-stamped and can’t be edited.

The new regulations state that, when termination occurs and a refund is due, this refund must take place no later than 14 days after termination. One way to comply is to make refunds directly from the back-office system, provided that the platform has an integrated payment gateway.

Another helpful feature gives users the ability to generate and auto-populate receipts for the client via the system, saving them a lot of time and effort compared to manual processes.

Finally, selling systems can be configured in such a way that they recognise the new package types and notify the user when a booking may be subject to the new regulations. This can be done within financial controls and system administration rules.

We made significant changes prior to the implementation of the PTRs to ensure these  features were already part and parcel of the Traveltek platform.

The number of DP bookings made through our platform has actually been very stable since the introduction of PTR, but we have noticed a change in the way smaller agents are handling DP bookings and where agents are buying their DP products from. Many smaller agents had no desire to take on the additional costs and risks, both financially and operationally and are now choosing to put their DP business through larger tour operators that are willing to take on the risks of being package organisers, but who can still offer them DP booking portals to meet the requirements of their customers.

As a result of the extremely short implementation period, there have been some areas of the legislation that have led to confusion amongst the travel community, such as the exemption of business travel; the ambiguity surrounding ‘point of sale’ and civil enforcement.  

A review is scheduled for January 2019, but I expect that another review will be necessary later in the year to provide a full picture of how the new regulations are impacting both consumers and travel businesses."