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New rules have very practical implications for trade, says Travel Marketing Systems’ Steve Rushton
You probably had the same initial reaction as me to the changes required by the Digital Markets, Competition and Consumers Act. Something along the lines of, ‘This is the last thing I need!’
As the founder of a travel marketing platform, I’m responsible for ensuring the assets we provide to tour operators and agents are compliant, so I’ve had to give these changes a great deal of thought.
The travel industry has understandably spent a lot of time focusing on the Competition and Markets Authority guidance regarding pricing transparency. Pricing is the part that has created the biggest immediate challenge, particularly where local taxes, mandatory charges and ‘from’ prices are concerned.
But there is another aspect of the new rules that, in my view, deserves far more attention than it has received so far: the requirement to make clear who the customer is actually buying from. Historically, travel marketing has often followed the same broad pattern: lead with the destination, hotel, price and the call to action. Capture the customer’s interest first, then deal with the finer detail later.
In that context, it has been quite normal for the identity of the principal – the supplier legally responsible for providing the holiday – to remain in the background until the quote or booking stage. That is where the position now appears to have changed.
The new rules are not just about price. They are also about material information – the information a consumer needs in order to make an informed decision. In travel, that means not just the holiday details, but also who is providing it and how that business can be contacted. If a piece of marketing amounts to an invitation to purchase, then principal disclosure looks much harder to leave until later in the sales process.
That has some very practical implications for the trade. It affects not only websites and landing pages, but also social posts, emails, printed promotions and traditional shop window displays. From what I can see, this is still an area where there is a good deal of uncertainty.
As a result, a lot of businesses do not appear to have fully adapted their marketing yet. If you walk past many travel agency windows today, you will still see offer cards showing a destination, hotel, departure date and price, but nothing clearly identifying the principal behind the offer.
Because the new requirements have not historically been how travel marketing has worked, I have also noticed some resistance to the changes. But rather than fear them, I think the trade can confidently embrace them to their advantage, because they can make marketing feel more credible.
Customers are increasingly aware of who they are booking with, which protections apply and what sits behind an offer. Being upfront about the principal can support confidence rather than weaken it.
After all, travel agents do not add value by pretending to be the operator. They add value through service, trust, advice and the ability to match the right holiday to the right customer.
Being clearer about who the principal is does not reduce that value. It shows the agent is acting transparently while still doing what good agents do best: guiding the customer through the booking process with expertise and reassurance.
Of course, the practical challenge is making sure this information is built into marketing in a compliant way that still looks good and works commercially. That will mean rethinking some long-standing templates and habits.
The key point is that this is not a minor side issue to the pricing changes – it is part of a wider move towards greater transparency across all marketing. The silver lining is that it can even be a marketing advantage.
Your message will be clearer, more trustworthy and more in step with what consumers now expect. So, embrace the change, build the trust and then reap the benefits!