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ARTICLE · 15 SEPTEMBER 2026

Digital Platforms Are Redefining Package Travel Liability

CMS Wistrand
CMS Wistrand
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CMS Wistrand

CMS Wistrand

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Travel platforms face evolving regulatory scrutiny as package travel rules expand beyond traditional tour operators. Product design, marketing strategies, and booking flow decisions now carry significant...

SwedenConsumer Protection

For many years, package travel rules were seen as something that concerned traditional tour operators. Liability in the travel industry was determined by contracts. Businesses invested significant effort in defining their role within the transaction. A company was either a travel organiser, a retailer or merely an intermediary and legal risk followed those labels.

When the original package travel rules were introduced in 1990, travel services were usually sold in a fairly straightforward way. Consumers bought holiday packages from travel agents, and responsibility for the trip was generally easy to identify.

When the customer journey becomes a product

That is no longer always the case. A traveller can now book flights, hotels, transfers and activities through a single online journey, even though each service may be provided by a different business. While those distinctions may matter from a contractual perspective, they are often invisible to the traveller. The law is

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