GLOSSARY
Products
THE SHORT VERSION
Unlike a ready-made brochure package, a dynamic package is put together at the time of booking, usually from live availability and prices. Agents and tour operators can combine scheduled and low-cost flights, bed bank hotels and directly contracted rates, with mark-up rules applied by the booking engine.
The regulatory side
There is no legal definition of dynamic packaging, but a dynamically packaged trip is usually a package under the Package Travel Regulations 2018, because the parts are combined by one business, chosen in one booking process or sold at a total price. The business doing the packaging is normally the organiser, responsible for every part of the trip and for protecting the customer’s money.
If the package includes a flight, ATOL applies. Selling as an agent for an ATOL holder only covers a package if the agent simply selects, or lets the customer select, from a closed group of services the ATOL holder makes available and the ATOL holder acts as the organiser. A business that builds its own flight-inclusive packages normally needs its own ATOL or membership of an ATOL Accredited Body. For VAT, a business reselling travel in its own name accounts for VAT on its margin under the Tour Operators’ Margin Scheme.
Common confusion
Dynamic packaging is not the same as dynamic pricing, where prices move with demand.
Until 6 April 2027, services chosen and paid for separately in a single visit can be a linked travel arrangement rather than a package. From that date they count as a package too.
Sources
The official pages behind this explanation. This is general information, not legal advice, and rules change, so check the latest version.
Package holidays: complying with regulations, guidance for businesses (GOV.UK)
The Package Travel and Linked Travel Arrangements (Amendment) Regulations 2026 (legislation.gov.uk)
The Civil Aviation (Air Travel Organisers’ Licensing) Regulations 2012, regulation 15 (legislation.gov.uk)
Accredited bodies (Civil Aviation Authority)
Tour Operators’ Margin Scheme, VAT Notice 709/5 (HMRC)