Selling rooms with an excursion, transfer or car? When your hotel organises a "package" (2026)

Updated: 9 November 2026

Many hotels sell a stay with an excursion, a transfer or car hire. Combine them the wrong way and the law may treat you as the organiser of a package, with travel-agency duties: an information form, liability for the whole trip and insolvency protection. This is what the EU Directive and the laws of Spain, Portugal and Italy say (sources at the end). This is not legal advice.

What a package is

Directive (EU) 2015/2302 sets four types of travel service: passenger transport, accommodation, car or motorbike rental and "other tourist services". A package exists when at least two different types are combined for the same trip and, for example, are bought together, chosen at one point of sale before paying, sold at an inclusive price or advertised as a "package".

The 25% rule for excursions and tickets

Accommodation + an "other tourist service" (excursion, guided tour, concert or sports tickets, theme park, sports equipment hire) is not a package if that service is worth less than 25% of the total and is not advertised as the essential feature.
Spain already writes the 25% into its law (art. 151.1(b) of the consumer law); Portugal's law says "significant proportion".
Nor is it a package if the guest books it after their stay has started, for example at reception after arrival.
Example: 3 nights at EUR 300 + a EUR 60 excursion = 17% of the total, and the offer is the stay: not a package. A "wine break: 2 nights + winery visit" sold as the main attraction may be one.

What never counts

Meals, drinks and cleaning that are part of the accommodation, and access to an included pool, sauna, spa or gym, are not a separate service (recital 17). Full board or breakfast with spa does not turn a stay into a package.

Transfers or cars: take care

A transfer (transport) and car rental are a different type of travel service, not an "other tourist service": the 25% rule does not apply. If you sell stay + transfer or stay + car together, at one price or in one purchase, you may be creating a package even if the transfer is cheap. The safe route is for guests to book it separately with the operator, or to take advice first.

If you are the organiser

Pre-contract information using the Directive's standard form (Annex I).
You are liable for the whole trip being delivered, even when another company provides a service.
Insolvency protection that refunds all travellers' payments.
National laws add their own requirements, such as registering as a travel agency: check with your association or regional authority.

What changes with Directive (EU) 2026/1024

The reform of 29 April 2026 moves the 25% into the article itself, abolishes "linked travel arrangements" (connected online bookings within 24 hours become packages) and confirms that access to hotel facilities does not create a package. Countries have until 29 September 2028 to transpose it and it applies from 29 March 2029; until then current laws apply. According to the Commission, insolvency refunds within 6 months and complaint replies within 60 days.

10-minute check

List what you sell together with the stay.
For excursions and tickets, check whether they exceed 25% of the total and how you advertise them.
For transfers and cars, let guests book them separately or take advice.
If you are an organiser, check the form, liability and insolvency cover.

How iQuota helps

iQuota publishes your property with its price and conditions; it does not sell packages. If you offer extras, describe them clearly with a separate price so travellers and AI understand what the stay includes.

Want an official booking page AI can read and a connector with your real prices, commission-free? The first 30 hotels join free until 30 June 2027.

See the Founding Hotels programme

Frequently asked questions

Do included breakfast and spa make a stay a package?

No. Meals and access to hotel facilities are part of the accommodation (recital 17 of the Directive).

What if I sell a stay plus a cheap excursion?

If it is worth less than 25% of the total and is not the essential feature, it is not a package.

When does the new Directive 2026/1024 apply?

From 29 March 2029; until then current national laws apply.

Sources

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