Search
Contact
Symbolbild zur Pauschalreiserichtlinie: zwei Frauen mit Koffern am Flughafen
08.04.2026 | KPMG Law Insights

New Package Travel Directive 2026: Complaint management becomes mandatory

The EU is reforming the Package Travel Directive. The amendments were adopted by the European Parliament and Council in March 2026 and are expected to become law in Germany in 2029.

One of the innovations is a mandatory complaints management system for tour operators. Agents, online platforms and business travel managers are also subject to new obligations.

The development of complaint management should be systematically planned. This is because modern complaint management is essential for the customer relationship and also serves the strategic management of the company in particular.

These are the key points of the new Package Travel Directive

With the reform, the legislator wants to strengthen consumer protection, among other things by obliging tour operators to provide more transparency, clearer processes and binding complaints management. These are the key points of the new Package Travel Directive:

  • In future, brokers must clearly distinguish between package tours and individual services.
  • The associated travel services are no longer available.
  • Tour operators must meet additional information obligations and transparency standards, including on payment methods, visa requirements, accessibility and cancellation policies.
  • Organizers must implement a formal complaints management system.
  • Tour operators must refund the travel price within 14 days of canceling a trip.
  • Vouchers remain a voluntary alternative to repayments.
  • Insolvency insurance is also mandatory for vouchers.
  • As a rule, advance payments by travelers may not exceed 25 percent of the total price.

 

Requirements for complaint management

The draft of the new Package Travel Directive provides for mandatory complaints management for tour operators.

Complaint management will have to meet the following requirements:

  • Transparent, documented processes
  • verifiable compliance with deadlines
  • Systematic classification and processing
  • Reporting to supervisory authorities
  • Interfaces to other compliance processes

Complaint management not only serves to fulfill legal requirements, but also to ensure customer satisfaction and loyalty. Studies show that around 90 percent of dissatisfied customers will leave if complaints remain untreated.

 

Tour operators should pay attention to this when implementing complaint management

Tour operators should consider the following aspects when setting up a complaints management system:

Clear governance and unambiguous responsibilities

It is important that roles and responsibilities are clearly defined, from the receipt of complaints to the assessment and processing through to escalation. Tour operators should appoint a centrally responsible body that acts independently and is clearly visible.

Standardized processes and documented procedures

The directive requires comprehensible processing and response deadlines. To achieve this, organizers need a clearly structured end-to-end process with defined input channels, standardized deadline models, a uniform classification of complaint types and consistent documentation of all steps.

Scalable systems for high volatility

The travel industry is experiencing heavy peak loads. Complaint management that cannot scale technically or organizationally quickly leads to backlogs, escalations and dissatisfied customers. Automated workflows, structured decision paths and flexible capacity models prevent the organization from being overloaded in stressful situations.

Sophisticated interfaces

Complaints often concern different departments: Customer service, operations, legal department, airline partners, hotel chains or insurers. An effective system therefore requires defined interfaces and clear rules for cooperation. Data protection requirements must also be taken into account.

Professional communication and trained employees

Dealing with angry or unsettled travelers requires trained employees. Training in conversation management, de-escalation and standardized documentation is a key success factor.

Reporting and continuous improvement

In future, the Package Travel Directive will require structured reporting to supervisory authorities. At the same time, tour operators should use complaint data for internal improvements and quality assurance by identifying recurring causes and optimizing partner processes. Reporting can help to identify risks and frequent sources of error at an early stage.

 

Conclusion

The reform of the EU Package Travel Directive brings new burdens for the travel industry. In particular, new information obligations and mandatory complaints management can initially take up resources. However, if complaints management is set up strategically, centrally and automatically, it will bring the company more benefits than costs in the long term.

After all, modern complaint management is not just a reaction, but a strategic management tool.

Co-author: Dr. Patrick Schröder, Senior Associate

KPMG Law supports companies in the travel industry with complaints management processes. Further information on our complaint management-as-a-service services can be found here.

 

 

 

 

Explore #more

13.08.2026 | KPMG Law Insights

Federal Ministry of Finance Presents Draft Bill on Mandatory Use of Electronic Cash Registers and Combating Tax Evasion

In July 2026, the Federal Ministry of Finance (BMF) and the Federal Ministry of Justice (BMJV) presented an action plan to combat tax and financial

11.08.2026 | In the media

Guest article in *Versicherungsmonitor* on the topic of cyber claims regulation

Cyberattacks—particularly ransomware campaigns—pose challenges for insurers when it comes to claims settlement. When entire IT infrastructures at insured companies come to a standstill and the…

11.08.2026 | KPMG Law Insights

Transparency Requirements Under Article 50 of the AI Act: Companies Should Address These Questions Now

The transparency requirements of the EU AI Act have been in effect since August 2, 2026. These obligations apply to chatbots, AI assistants, avatars, synthetic…

10.08.2026 | In the media

Op-Ed on the Procurement Acceleration Act and Sustainable Public Procurement

On April 23, 2026, the Bundestag passed the Act on Accelerating the Award of Public Contracts. After the Act was published in the Federal Law…

05.08.2026 | Deal Notifications

KPMG Law and KPMG Advise NMP Germany on the Acquisition of Klöckner Desma Elastomertechnik GmbH

KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) and KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) advised NMP Germany GmbH on the legal, tax, and financial aspects of the transaction…

04.08.2026 | In the media

Portrait of Mathias Oberndörfer in the *Börsen-Zeitung*

Mathias Oberndörfer has been with KPMG for more than 20 years—reason enough for an in-depth profile in the *Börsen-Zeitung*. The Börsen-Zeitung traces his career path…

03.08.2026 | Unkategorisiert

KPMG Law und KPMG beraten NMP Germany beim Erwerb der Klöckner Desma Elastomertechnik GmbH

Die KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) und die KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) haben die NMP Germany GmbH beim Erwerb der Klöckner Desma Elastomertechnik Gruppe…

03.08.2026 | In the media

Statement by KPMG Law experts on the EU Packaging Regulation in the business magazine *impulse*

Starting January 1, 2030, packaging must consist of at least 70 percent recyclable materials. Starting August 1, 2030, so-called “deceptive packaging” will also be banned.…

30.07.2026 | KPMG Law Insights

CRD VI and Third-Country Banks: Preserving Cross-Border Access to the EU Market

From 11 January 2027, third-country banks will need to reassess whether they may continue to provide banking services into the EU on a cross-border basis.…

28.07.2026 | In the media

Op-ed in the FAZ on the topic “Who is liable when algorithms make decisions?”

Artificial intelligence has made its way into the boardroom. Whether it’s investment decisions, risk analysis, or workforce planning—the results of artificial intelligence are increasingly being…

Contact

Hauke Büsing

Senior Manager

Fuhlentwiete 5
20355 Hamburg

Tel.: +49 40 360994-5998
hbuesing@kpmg-law.com

© 2026 KPMG Law Rechtsanwaltsgesellschaft mbH, associated with KPMG AG Wirtschaftsprüfungsgesellschaft, a public limited company under German law and a member of the global KPMG organisation of independent member firms affiliated with KPMG International Limited, a Private English Company Limited by Guarantee. All rights reserved. For more details on the structure of KPMG’s global organisation, please visit https://home.kpmg/governance.

KPMG International does not provide services to clients. No member firm is authorised to bind or contract KPMG International or any other member firm to any third party, just as KPMG International is not authorised to bind or contract any other member firm.

Scroll