Alternative dispute resolution (ADR) for hotels and holiday rentals: what changes with Directive (EU) 2025/2647 (2026)

Updated: 10 November 2026

A guest disputes a charge or a cancellation and, instead of going to court, turns to a consumer mediation or arbitration body. That is alternative dispute resolution (ADR). The EU has reformed it with Directive (EU) 2025/2647. We read the directive, the 2013 directive it amends, the regulation that closed the ODR platform, Spain's Act 7/2017, the Spanish Consumer Affairs ministry's consultation and Portugal's Law 144/2015 (links at the end). Where we could not confirm something we say so. This is not legal advice: check with your adviser.

What Directive (EU) 2025/2647 is

Directive of the European Parliament and of the Council of 16 December 2025, published in the Official Journal on 30 December 2025:

It amends Directive 2013/11/EU on alternative dispute resolution for consumer disputes.
It also adjusts the package travel directive (2015/2302), 2019/2161 and 2020/1828, after the EU ODR platform was closed.
Member States must transpose it by 20 March 2028. It applies from 20 September 2028.
Until then your current national law applies (in Spain, Act 7/2017; in Portugal, Law 144/2015).

Does it affect hotels and holiday rentals?

Yes, like any business selling to consumers:

It covers disputes about contractual obligations, including the pre-contractual stage (what you advertised).
It does not cover disputes between businesses or claims you bring against a guest.
The directive does not name accommodation, but it flags transport and tourism as sectors with low ADR participation (recital 16).
Package travel organisers will have to give information on ADR (art. 2).

From 2028: reply to the ADR body within 20 working days

New art. 5.9 of Directive 2013/11/EU:

If an ADR body invites you to a case, you must say whether you agree to take part within a reasonable period of no more than 20 working days.
In complex or exceptional cases the period can be extended, to no more than 30 working days.
If you do not reply, the body may assume you refuse and close the case. National law will set the consequences.
No reply is needed if participation is mandatory, if you already committed to it by contract, or if the body can decide without you.

What information you will have to give

Arts. 13.2 and 13.3 as amended:

On your website, if you have one, in a clear, prominent, comprehensible and easily accessible way, and in your general terms.
If a guest's direct complaint is not resolved, you will have to give them the ADR information.
Today the duty to inform falls on traders that commit to or are obliged to use an ADR body (art. 13.1 of 2013), including the body's website.
The duty to say whether or not you will use an ADR body is removed (recital 30).

The guest must contact you first

Art. 5.4(a): the guest must have tried to contact you before going to the ADR body.
That contact cannot be subject to disproportionate format or content requirements: keep a simple complaints email or form.
Other changes: non-EU traders targeting a country can take part on a joint request with the guest; where automated means are used, a review by a person can be requested; bodies may group similar cases.

The ODR platform is gone

Regulation (EU) 2024/3228:

No complaints accepted since 20 March 2025.
Regulation 524/2013, which created it, was repealed with effect from 20 July 2025.
If your website or terms still link to the ODR platform, remove the link.

Spain: Act 7/2017 and the reform under way

Act 7/2017 (unofficial copy of the BOE text):

Art. 40: if you have joined an accredited body, say so and identify the body in full.
If a direct complaint is not resolved, tell the guest which bodies are competent, on paper or another durable medium.
Art. 41: failure to comply is a serious consumer-law offence.
The Consumer Affairs ministry held a public consultation (until 7 July 2026) on a draft bill amending this act: it includes the duty to reply to the ADR body, with consequences if you do not. The text does not mention tourism.

Portugal: Law 144/2015

Original 2015 text (copy on the Banco de Portugal site; we did not check later amendments):

Art. 18: inform guests of the available ADR bodies and their websites, on your website and in written or standard-form contracts, clearly and accessibly.
Art. 23: fines of EUR 500 to 5,000 (individuals) and EUR 5,000 to 25,000 (companies).
Enforced by ASAE.
gov.pt confirms the ODR platform was discontinued on 20 July 2025.

Italy and Greece

We did not read in an official source the national law that currently applies the 2013 directive in Italy and Greece, so we give no details. Both countries must transpose Directive (EU) 2025/2647 by 20 March 2028. Ask your adviser.

What to do now

Remove the ODR platform link from your website and terms.
If you have joined a consumer mediation or arbitration body, name it on your website and in your terms.
Offer a simple complaints channel and reply in writing.
Note in your diary: from 20 September 2028, answer every ADR invitation within 20 working days.

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Frequently asked questions

What is Directive (EU) 2025/2647?

The reform of the EU directive on consumer alternative dispute resolution, dated 16 December 2025. It must be transposed by 20 March 2028 and applies from 20 September 2028.

Do I have to accept mediation a guest asks for?

The directive does not oblige you to take part unless your national law does. But from 2028 you will have to tell the body within 20 working days whether you accept.

Do I still need the ODR platform link?

No. The platform was closed and Regulation 524/2013 has been repealed since 20 July 2025.

Sources

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