Take-aways: The changes seek to address the issues which arose in relation to refunds for travel cancelled or disrupted by COVID-19 and the collapse of Thomas Cook and the increasing use of OTAs by consumers in the EU. Notwithstanding the greater clarity in these changes, several issues remain unclear and will require either further clarification by the Commission or EU courts. This includes the relationship with other EU directives on passenger compensation and assistance and the extent to which non-EU suppliers will be subject to and bound by the Directive’s deadlines for them to refund travel organisers when the services of the non-EU suppliers are cancelled or are not fully or properly performed. Another key issue is the speed with which Member States will implement the changes and the extent to which these changes are implemented uniformly and consistently across the EU.

Singapore

In our Q1 update, we reported on the SAF levy which was to apply to tickets for flights departing Singapore from 1 April 2026. Given the current surge in jet fuel costs, implementation has been delayed to 1 October 2026.

Thailand

The Electronic Transactions Committee has proposed to require social media platforms to verify the identity of users and advertisers. Based on the current draft of the proposal, the identity verification requirements for advertisers appear more stringent and demanding than those for users. These requirements would specifically include:

the extent to which the advertiser complied with the platforms T&Cs;
the level and nature of previous complaints against the advertiser;
advertising which targets specific groups, such as the young and the elderly; and
advertising which deals with financial products, potential cybercrimes and sensitive personal data.

Next steps: Public consultation on this proposal closed on 2 February and the Committee is currently considering the submissions before deciding whether to proceed with a notification to give effect to this proposal.

Türkiye

In January, the Turkish Association of Travel Agencies commenced proceedings in the Turkish courts which seek to ban the following OTAs and travel platforms from Türkiye:

Agoda;
Airbnb;
Expedia;
GetYourGuide;
Hotels.com;
Isango;
Musement;
ToursByLocals;
Trip.com; and
Viator.