When a Trip Becomes a Package

The definition

The word “package” sounds like a marketing category. In EU law it is a test, and it is applied to the facts rather than 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. That happens the obvious way, under a single contract. It also happens where the services are bought at a single point of sale, or advertised at one inclusive or total price, or sold through linked online booking processes.

Two flights are not a package: 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, and both of them are about who carries the risk.

The organiser answers for the performance of the whole trip. Not for the parts it performs itself — for all of it, including 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. Member states require organisers established in their territory to hold security for the refund of payments where services are not performed because the organiser has become insolvent, and where the package includes carriage, for the repatriation of travellers. That protection follows the traveller regardless of where they live, where the trip departs from, or where the package was sold.

There is a third, quieter consequence. Prices may only be raised if the contract expressly allows it and the increase results from defined cost changes. Above 8% the traveller may terminate and be refunded within 14 days. And a traveller may terminate 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 is the one about linked booking processes.

Where a traveller books one service and is then passed to another trader — with their name, payment details and email address transmitted — and a second service is booked 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 is worth knowing in the other direction too: waiting a day before booking the second service changes the legal character of the trip, which is an odd fact but a true one.

What separate contracts do instead

The alternative structure is straightforward. The traveller contracts directly with each supplier — the house, the yacht, the driver, the restaurant — and holds a set of separate agreements rather than one.

That is not a lesser arrangement, and it is how much of the top of the market has always worked. It gives the traveller a direct relationship with the person doing the work, terms negotiated with that person, and no intermediary standing between them when something needs deciding at short notice.

What it does not give is a single party liable for everything, or the statutory protection of the money. Each contract stands on its own. If one supplier fails, the others are unaffected, which cuts both ways: nothing collapses, and nothing is automatically made good either.

The choice between the two structures is a real one, and the honest way to make it is to know which you are in. Many travellers do not.

What the 2026 revision changes

The rules have just moved. 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 deletion of linked travel arrangements — the intermediate category between a package and a set of separate bookings, which proved hard to explain and harder to enforce. Services bought under separate contracts with different traders now sit plainly outside the package protections.

Member states have 28 months to transpose the amendments, so national law in Greece and elsewhere still runs on the 2015 rules as they were transposed until that work is done.

What to check before paying

1. Ask whether the trip is being sold as a package. It is a direct question with a direct answer, and the answer determines everything below it.
2. If it is: ask who the organiser is, and what insolvency protection it holds. The name of the scheme or the insurer, not the assurance that there is one.
3. If it is not: ask who you are actually contracting with, service by service. Each name, on each agreement.
4. Read what the contract says about price changes, and whether it permits increases at all.
5. Establish who you telephone at midnight, and whether that person can commit anybody other than themselves.