He took aim at the timing of the CAA’s decision in April 2021 to start reviewing the Atol regulations while the industry was still reeling from the impacts of the first year of the pandemic, describing it as “a bit ridiculous”.
He also criticised the requirement under the current Package Travel Regulations for agents and operators to provide specific details of clients’ Atol arrangements at point of sale. “You and your clients have probably never read the information you’re required to provide. It’s a bit of a nonsense.”
Despite several rounds of consultation, Nunn declined to put a timeframe on delivery of the new Atol regulations, while on the PTRs, he said: “My prediction is 2026 for the new PTRs, and that they will be rolled out gradually. There will definitely be changes, and I think they will be for the better.”
He added: “When the consultations do come, give them an eyeball – you can impact the outcome.”
’Lessons from the pandemic have to be learned’
Besides segregation of client monies and variable APC, Nunn identified another three areas where agents and the wider travel trade can expect regulatory change – the removal of Linked Travel Arrangements (LTAs); right of address against supply chain; and flexible refund requirements.
- Nunn said the CAA’s tone on segregation of client monies had “softened a bit” after its initial proposals suggested segregation could apply on a per agency basis.
- On variable APC, Nunn said there were several ways this could be applied, highlighting how the contribution – currently set at a flat £2.50 per Atol protected seat – could in future be based on the type of holiday, the destination and also the value.















