Brexit implications for ABTOT Members

With the announcement of the UK-EU Trade and Cooperation Agreement, it has been confirmed that the mutual recognition between the UK and the EU Member States in relation to financial protection will finish from 31 December 2020. A link to the agreement is set out below:

EU-UK_Trade_and_Cooperation_Agreement_24.12.2020.pdf (

In terms of financial protection arrangements under the 2015 Package Travel Directive, this will have the following impact on certain ABTOT Members and other travel organisers:

If a Member or travel organiser actively sells into an EU country, they will need to be compliant with the local regulatory requirements for that individual country.

Remember, selling into is not the same as simply selling.

If a Member or other travel organiser advertises their products online and sells in GBP then they are required to comply with UK Financial Protection Regulations, and for ABTOT Members  this is covered by their ABTOT Membership and bonding with ABTOT.

However, if a Member or other travel organiser advertises in EU languages, produces marketing or packages aimed specifically at EU customers and accepts payment in EUR (as examples) then they will need to take steps to check about their post Brexit compliance.

An ABTOT Member or other travel organiser should ask:

  • Do we accept payment in Euros?
  • Do we target any EU countries?
  • Do we advertise in EU languages?
  • Do we have a large percentage of EU custom overall?

If they answer yes to some or all of these questions, it is likely that they will need a secondary financial protection product as well as their current ABTOT bond or other form of UK financial protection.

Travel & General may be able to provide this:

  1. For sales to the Republic of Ireland, the Travel & General Irish topp policy is accepted by CAR to cover Irish sales.
  2. For other EU countries, Travel & General has a French Regulated arm called Arcus Solutions which can underwrite EU accepted insurance products.

Through their relationship with Travel & General and ABTOT, ABTOT Members and t&g clients have access to these Brexit solutions so please talk with us about what you may need.

For other Brexit related advice on contracts, terms and conditions, employees, taxes or other business issues, ABTOT Members should please contact our expert Associates – see for contact details.