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.
