Refunds in 7 days and airlines in crisis: what changes for those who sell flights

The new flight rules enter into force on 22 October. In the same weeks, two European airlines went into restructuring.

Regulation (EU) 2026/2202, published in the Official Journal on 2 October, enters into force on 22 October and applies from 23 October 2027. It is the first substantial reform of air passenger rights since 2004: the Commission proposed it in 2013 and the text went all the way to the conciliation committee between Parliament and Council.

In the same weeks airBaltic started a Chapter 11 procedure before the bankruptcy court in New York and Volotea filed for pre-insolvency protection at the commercial court in Barcelona. Ryanair is cutting around two million winter passengers and expects that rivals with less fuel hedging may not survive the season.

Put together, these stories tell anyone who sells travel something precise: the flight sold on its own is becoming the most regulated and riskiest item in the catalogue. And the package is going back to being what the law has always said it is: a protection.

What changes for passengers from 23 October 2027

Compensation stays as clients know it: 250, 400 or 600 euros depending on distance, when they reach their destination more than three hours late. Claims must be made within nine months of departure. The rest changes a great deal.

Automatic refund within seven days. In case of cancellation or long delay, if the passenger chooses a refund, the airline must pay it within seven calendar days by bank transfer, and the refund covers "the full price of the tickets and the intermediation fees, where applied".

Do-it-yourself rerouting, up to 400%. If the passenger wants to continue and the airline does not offer an alternative flight under comparable conditions within three hours, they can make their own arrangements. The airline reimburses necessary and reasonable costs up to 400% of the ticket price, within 14 days of the request.

A personal item always free. A bag of up to 40x30x15 centimetres, or one that fits under the seat in front, travels in the cabin at no cost.

No cancelled return for skipping the outbound. The airline can no longer deny boarding on the return, or charge money, to a passenger who did not take the outbound flight of the same contract.

Name corrections free of charge. A spelling mistake in the name is corrected free of charge at least once, if the request arrives at least 48 hours before departure. And the agency that made the booking can also submit the request.

What it asks of those who sell tickets

The regulation does not speak only to airlines. It expressly addresses "intermediaries", meaning anyone who sells tickets on behalf of an airline or a passenger: travel agencies all fall within it. And it asks them for some precise things, from 23 October 2027.

An information notice on the website or app setting out passenger rights and the complaints procedure. The summary the Commission will publish in all EU languages can be used.

Before purchase, say what kind of ticket is being sold. In particular, whether the trip is covered by a single contract of carriage or by several separate contracts. Anyone selling separate tickets, the classic itinerary built with two different airlines, must state clearly and on a durable medium that, if a connection is missed, the rights to refund, rerouting and assistance do not apply between one contract and the other.

A complaints mechanism. Passengers can also complain to the intermediary, within 12 months. The recipient acknowledges receipt within seven working days and gives a reasoned reply within one month, two at most in justified cases.

The burden of proof lies with the intermediary. If a client claims they were not informed, it is up to the agency to prove otherwise. Anyone who today communicates by phone and WhatsApp without leaving a trace will have to change their habits.

Coming next: the commission to refund

There is a second text, more delicate for agencies: the regulation on the enforcement of passenger rights. Council and Parliament reached a provisional agreement at the end of June and Parliament's transport committee approved it on 2 September; according to Parliament's Legislative Train the final votes in plenary and Council are still to come. The final text may change, but the agreement says this:

Passengers who bought through an intermediary are entitled to a full refund in case of cancellation, including the intermediation fee. The refund must be paid within seven days, extended to 14 when the intermediary paid the airline from its own account. Micro-enterprises are exempt from refunding the fee, but only if they tell the client clearly at the start of the booking. At the time of booking, the intermediary must also explain how the refund will work. Airlines will have to declare whether they cooperate with intermediaries to handle refunds, and screen scraping, booking without disclosing yourself to the airline, will be banned.

ECTAA, the European association of travel agents and tour operators, called it "fundamentally unfair" to ask intermediaries to give back their remuneration for a service already provided, while they handle for free a cancellation they did not cause. It also pointed out that the exemption does not cover the thousands of agencies with more than ten employees. The objections are well founded, but it is wise to prepare for the text as it stands.

The autumn of fragile airlines

Fuel is the thread that links all the news of these weeks. At the Airlines for Europe meeting on 8 October, Michael O'Leary said jet fuel costs around 50% more than before the war, that it will stay at those levels for another 12 to 18 months and that 2027 will be a "full-blown crisis" for those who have hedged little of their needs. He also spoke of fares up to 20% higher next summer.

The first consequences are already visible. airBaltic has obtained 350 million euros of financing within the US procedure and expects to complete it by mid-2027; flights continue. Volotea estimates a fuel cost overrun of 150 million, has negative equity of 77.5 million, is cutting its fleet from 44 to 30-35 aircraft and aims for an agreement with creditors by December. Here too the chief executive says the airline continues to fly normally.

Neither has stopped flying, and both may well come through. But on 29 September the chairman of the travel agencies section of the Austrian Economic Chamber, Gregor Kadanka, recalled two figures every agency should know: between 2000 and 2024 more than 1,200 airlines closed worldwide, around fifty a year, and between 2011 and 2019 about 5.6 million European passengers were caught up in an airline failure. His conclusion: anyone who buys a ticket directly from the airline has no legal protection against insolvency.

Agencies already live this. According to the Aidit Federturismo survey of 230 Italian agencies, this summer 52% handled flight cancellations and rerouting, 19% had to deal with price increases that arrived after the trip was confirmed, and around seven agencies in ten consider the cost of flights one of their main concerns for 2027.

The package as protection, rules in hand

This is where the opportunity lies. Everything that makes a flight sold on its own risky is already solved, by law, inside a package.

One party responsible. Directive (EU) 2015/2302 makes the organiser responsible for all the services in the package, even when someone else performs them (Article 13). If the flight falls through, the organiser must offer an alternative at no extra cost or reduce the price. The new regulation confirms the approach: for a flight included in a package, the right to a refund comes from the directive, and the organiser keeps the right to claim back from the airline. The client has a single point of contact and does not have to chase an airline in restructuring.

Insolvency protection. The organiser must have security that refunds payments and, if the package includes transport, brings the traveller home (Article 17). For a flight bought on its own there is no equivalent European protection: if the airline fails, the client is left as a creditor of an insolvent airline. Some countries extend the agency's protection to certain services sold on their own, such as France, Portugal, the United Kingdom with ATOL and Ireland for transport abroad, but these remain national exceptions.

A price without surprises. In a package the price can only go up if the contract expressly provides for it, only for fuel, taxes or exchange rates, and with notice at least 20 days before departure; above 8% the client can withdraw (Article 10). With fuel expected to stay high throughout 2027, that clause needs explaining before signing. The 19% of agencies that handled increases after confirmation show exactly what happens when the client discovers it afterwards.

What to do between now and 2027

Decide how to handle your commission on flights. If you are a micro-enterprise, get ready to say so at the start of every booking, not at the bottom of the terms. If you are not, take into account that in case of cancellation the commission may have to go back to the client, and price your flights accordingly.

Put it in writing when you sell separate tickets. Itineraries with several contracts of carriage are often the cheapest, but the client must know in writing that between one flight and the next the connection rights do not protect them. Where possible, prefer a single contract or a package.

Organise complaints. A dedicated address, acknowledgement within seven working days, a reply within one month. And keep a record of every piece of information given to the client before purchase: from 2027 the burden of proof is yours.

Watch the health of the airlines you sell. Following industry news, spreading volumes, weighing ticketing and payment timing when an airline shows signs of difficulty: it is supplier risk management, as with any other supplier.

Offer the package, and explain it. When a client buys a flight and a hotel, offering them as a package is not bureaucracy: it is telling them, rules in hand, that if the airline fails someone answers for them. In an autumn when two European airlines are in restructuring and a third predicts casualties among its rivals, it is a sales argument that explains itself.

The agency's value, written into the rules

For years the flight has been the product on which agencies lost most ground: comparable to the cent, bought in a minute on the airline's app. The new rules do not change that, but they change the sums. The flight sold on its own brings information duties, complaints, the burden of proof and perhaps a commission to refund, and leaves the client exposed if the airline fails.

The package, on the contrary, gives the client exactly what an autumn like this makes them want: one party responsible, a guarantee and a price that does not change by surprise. Agencies that can explain it in plain words will have, from 2027, the most solid advantage European law has ever given them.