When a Trip Becomes a Package
A package, in EU law, is a combination of at least two different types of travel service for the same trip, put together by one trader or sold at a single inclusive price. When a trip is a package, that trader is the organiser: liable for the performance of every service in it, whoever performs them, and required to hold insolvency protection covering refunds and getting travellers home. The same trip booked as separate contracts with each supplier is not a package. There is no organiser, and the protection does not apply.
The definition
The word “package” sounds like a marketing category. In EU law it is a test, and the test is applied to the facts, not to the label on the invoice.
A travel service is one of four things: the carriage of passengers, accommodation that is not residential, the rental of a vehicle, and certain other tourist services. A package is a combination of at least two different types of those services, bought for the same trip.
The combination has to come from one trader. The obvious way is a single contract. It also happens where the services are bought at a single point of sale, advertised at one inclusive or total price, or sold through linked online booking processes.
Two flights are not a package, because they are the same type of service twice. A yacht and a villa, or a villa and the transfers, taken together from one seller, generally are.
What being a package changes
Two consequences follow, and both concern who carries the risk.
The organiser answers for the performance of the whole trip. That includes the parts it does not perform itself: the services supplied by hotels, drivers, boats and guides it has contracted on the traveller’s behalf. The traveller has one party to raise a failure with, and that party then deals with the supplier.
The organiser must protect the money. EU countries require organisers established in their territory to hold security for two things. The first is refunds, where services are not performed because the organiser has become insolvent. The second, where the package includes transport, is getting travellers home. That protection applies wherever the traveller lives, wherever the trip departs from, and wherever the package was sold.
A third, less obvious consequence concerns price and cancellation. Prices may be raised only if the contract expressly allows it and the increase results from defined cost changes. Above 8% the traveller may end the contract and be refunded within 14 days. A traveller may also cancel before departure without paying a termination fee where unavoidable and extraordinary circumstances at the destination significantly affect the trip.
The 24-hour rule in online booking
The provision that catches people out is the one about linked booking processes.
A traveller books one service and is then passed to another trader, with their name, payment details and email address sent across. If they book a second service within 24 hours of the first confirmation, the result can be a package, even though it did not feel like buying one.
The rule exists because the alternative was a decade of arguing about what a booking felt like. It also works in the other direction: waiting a day before booking the second service changes the legal character of the trip.
What separate contracts do instead
In the alternative structure, the traveller contracts directly with each supplier (the house, the yacht, the driver, the restaurant) and holds a set of separate agreements.
This is not a lesser arrangement. Much of the top of the market has always worked this way. It gives the traveller a direct relationship with the person doing the work, terms agreed with that person, and no intermediary between them when something needs deciding at short notice.
It does not give a single party liable for everything, or legal protection for the money. Each contract stands on its own. If one supplier fails, the others are unaffected. That cuts both ways: nothing collapses, and nothing is automatically put right either.
The choice between the two structures is a real one, and making it well depends on knowing which one you are in. Many travellers do not know.
What the 2026 revision changes
The rules changed in 2026. Directive (EU) 2026/1024, adopted on 29 April 2026 and in force since 28 May 2026, amends the 2015 Directive.
The most visible change is the removal of linked travel arrangements. This was a middle category between a package and a set of separate bookings, and it proved hard to explain and harder to enforce. Under the amended rules, services bought under separate contracts with different traders sit plainly outside the package protections.
EU countries have 28 months to write the amendments into national law. Until they do, national law in Greece and elsewhere still runs on the 2015 rules as each country adopted them.
What to check before paying
- Ask whether the trip is being sold as a package. It is a direct question with a direct answer, and the answer decides everything below it.
- If it is, ask who the organiser is and what insolvency protection it holds. Ask for the name of the scheme or the insurer, not an assurance that one exists.
- If it is not, ask who you are contracting with, service by service. Get each name, on each agreement.
- Read what the contract says about price changes, and whether it allows increases at all.
- Establish who you telephone at midnight, and whether that person can commit anybody other than themselves.