OTA is a trade label, not a legal category. In UK law, an OTA’s position depends on what it actually sells: it may be the organiser of packages, a retailer of another company’s packages or simply an intermediary selling single travel services. Until 6 April 2027 it may also facilitate a linked travel arrangement, for example when a customer books a flight and then books car hire separately on the same visit.

Two business models

• Agency model. The traveller pays the supplier, often the hotel on arrival, and the OTA earns commission.

• Merchant model. The OTA takes the traveller’s payment at booking and pays the supplier, keeping commission or a margin.

These are commercial labels. They do not settle an OTA’s VAT position or its role under the Package Travel Regulations.

The rules follow the booking

• An OTA that lets a customer choose a flight and a hotel in one booking process, or sells them at a total price, is the organiser of a package and needs ATOL cover for it.

• Passing a customer’s name, payment details and email address to another trader also creates a package, with the OTA as organiser, if the customer books with that trader within 24 hours of the first booking being confirmed.

• From 6 April 2027, two or more different types of travel service for the same trip that a customer chooses and pays for separately in one visit to the site will also form a package.

• Since 6 April 2025 the law has expressly required mandatory fees to be included in the headline price wherever they can reasonably be calculated.

Worth knowing

• Metasearch and price comparison sites are not OTAs. They send the customer to a seller.

• In 2019, six hotel booking sites gave the CMA commitments on pressure selling, misleading discount claims, hidden charges and telling customers when commission affects how hotels are ranked.