The first question with an agent or booking platform is not "who has the app?" but what legal role the business played: organiser, retailer/agent, ticket agent, accommodation platform or payment intermediary.
Start with the transaction and the disruption that actually occurred. Travel disputes often involve several businesses, but their responsibilities are not interchangeable.
Key points
- A travel agent can sell another supplier's service without becoming the airline or hotel, but may still have contractual duties of its own.
- A package organiser has stronger statutory responsibility than a pure agent selling a single travel service.
- For refunds, trace who took the money, who issued the ticket/booking and whether funds have actually moved back through the chain.
- Do not let businesses bounce you indefinitely between supplier and agent without each explaining its own role and position.
Diagnosis
First: what exactly happened?
Identify the problem before choosing the remedy or escalation route.
| What happened? | What to check first |
|---|---|
| The platform says "we are only an agent" | Check the confirmation, terms and whose name appears as principal/supplier. |
| The airline says it refunded the agent | Ask for the refund date/reference and ask the agent to confirm receipt. |
| The agent cancelled or changed the booking itself | Separate the agent's own service failure from the underlying airline/hotel issue. |
| The booking looked like a package | Check whether the business was actually the package organiser and issued the required package/ATOL information. |
| The listing/price was misleading | Preserve screenshots and identify which business made the representation. |
Agent, organiser and supplier are different roles
A pure agent arranges a contract with another supplier. A package organiser combines/sells a package and assumes statutory responsibilities for its performance. Some online businesses perform different roles for different bookings.
Do not rely on the brand name alone: read the confirmation and terms for the specific transaction.
Who took the money?
Card statements can show the merchant of record, while ticket/booking documents identify the supplier. These details matter for refunds, chargeback and Section 75.
If the supplier says it refunded the agent, obtain a transaction reference or written confirmation; if the agent denies receiving it, put the contradiction to both parties.
Flight bookings through agents
CAA guidance recognises third-party flight bookings and says practical refunds can take longer. Passenger-rights obligations against the operating airline remain important, while the agent can have separate obligations to pass on refunds or administer the booking properly.
Accommodation platforms
A booking platform may provide search, payment and communications while the accommodation contract is with the property. The platform can nevertheless be responsible for its own misleading information, payment handling or contractual promises.
Check any platform guarantee or rebooking promise separately from statutory rights.
When the booking is a package
If the same trader combines qualifying travel services into a package, the package organiser cannot simply re-label itself as an agent to avoid organiser obligations.
Look for the package information form, ATOL certificate where flights are included and the named organiser.
Booking errors and changes
If the consumer entered the wrong date/name, amendment charges may be contractually due. If the agent made the error, the analysis changes.
Preserve the original data you submitted, confirmation screen and any recorded call/chat.
Misleading ranking, scarcity or price
CMA accommodation-platform guidance emphasises transparent rankings, genuine discounts, clear total pricing and truthful availability/pressure claims.
Screenshots can be decisive because listings and prices change quickly after booking.
Payment protection and intermediaries
Intermediaries can affect Section 75 debtor-creditor-supplier analysis, while chargeback uses different card-scheme rules.
Do not assume "paid by credit card" automatically resolves a complex agent/platform payment chain; use the dedicated guides.
Who is responsible?
Responsibility follows role. An organiser is responsible for the package; an agent can be responsible for booking/payment administration and its own representations; the airline/hotel remains responsible for its own service where the agent only arranged it. A platform may also make independent guarantees. Map the chain rather than assuming one company owns every issue.
What can you realistically ask for?
Ask an agent to correct its booking error, pass on a received refund, provide records of the principal/supplier, or honour a specific platform promise. Ask the supplier for the service/refund it owes. If the dispute is about a package, use organiser remedies. If it is about misleading platform presentation, identify the representation that caused the booking decision.
What to say when you are bounced between companies
Send a short role-and-money schedule, who sold the booking, who supplied it, who charged the card, who received the refund, and what each party says. Then ask each respondent to answer only its own part. 'We are just an agent' should be followed with: 'Please identify the principal, your contractual role, and whether you have received or control any funds due to me.'
Escalation
Travel companies that are ABTA members can have an ABTA route. Airline statutory claims escalate through aviation ADR. Card claims go through the bank/FOS route. Misleading practices can also be reported through consumer enforcement channels, but that does not replace seeking your individual remedy.
Important exceptions and edge cases
An agent may be disclosed or undisclosed, may act for the consumer or supplier, and may become principal for some services while remaining agent for others. Package status can arise even where separate supplier names appear. Payment intermediaries can complicate Section 75 but do not automatically defeat it. Where a UK platform markets an overseas trader, consumer enforcement and court jurisdiction may still be complex. Preserve the exact terms shown at checkout because platform terms can change after the dispute starts.
Evidence worth keeping
Travel disputes are usually won or lost on the booking chain, timings and contemporaneous evidence. Preserve the original record rather than relying on screenshots taken weeks later where possible.
Common responses - and what they do not necessarily prove
| The business says | ConsumerWise view |
|---|---|
| "We are only the agent, so we have no responsibility." | Agency can limit responsibility for the supplier's performance, but the agent still needs to account for its own promises, payment handling and service. |
| "The airline has not refunded us." | Ask the airline for its written payment status and transaction reference rather than accepting circular blame. |
| "The supplier controls the listing." | The platform's own consumer-law duties around presentation and its own representations can still matter. |
| "It was a package in marketing only." | The statutory definition depends on how services were combined/sold, not merely whether the trader likes the legal consequences. |
What to do
A practical next-step plan
- Identify principal, agent, organiser and merchant of record from the documents.
- Ask each business to state its legal/contractual role in writing.
- Trace refund/payment movements with dates and references.
- Use screenshots and call records for booking errors or misleading representations.
- Choose the correct escalation route for the responsible entity rather than complaining to everyone indiscriminately.
Official sources
Check the current source material.
- CMA: Online accommodation booking principles
- CAA: Flight cancellations
- GOV.UK: Package holidays - complying with the regulations
Travel rights can depend on route, airline, booking structure, country, provider membership and the date of the event. Check the live official source before relying on a formal deadline, compensation amount or scheme rule.