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ATOL travel trust and escrow accounts

ATOL Full Trust

The CAA view their standard full trust account as being the most robust form of ATOL trust account financial protection. Implementation of that trust structure is therefore likely to attract the best available reward package from the CAA. It works where the balance held in the trust account exactly mirrors the funds taken from consumers for flight inclusive travel arrangements. Funds are generally held in the account until travel has been completed but, in some circumstances, money paid to flight suppliers can be released prior to that.

Serenity has unrivalled knowledge and experience in the set-up, implementation, and administration of the CAA’s ATOL full trust account structure.

With additional support from our ATOL specialist consultants, we can provide you with an efficient and painless route to ATOL compliance.

The CAA’s standard stand-alone full ATOL trust envisages the following structure: –

  • All consumer payments made for licenced sales must settle directly into the trust account within two days of them being paid. Alternatively, they may be transferred to the trust account from an ‘interim’ bank account which houses a mix of money paid for licenced and non-licenced travel arrangements;
  • If an interim account is being used, funds should reach the trust account no later than two days following their receipt into the interim account.
  • Payments made via agents should reach the trust account 15 days or less after they are received by agents. If agents haven’t passed on pipeline money by then, the account holder must pay an equivalent sum from its own funds into the trust account within 5 days;
  • Trustees are authorised by the trust deed to release payments based on a ‘payment request’ system in the following situations: 
  1. Performance – the customer’s return from travel.
  2. Component Performance – a component part of the package that has been completed by a non-ATOL holding supplier on whose behalf the account holder acts as agent.
  3. Component Reimbursement – reimbursement of a payment made to the non-ATOL holding supplier of any component part of a package (excluding flights). This may only apply where the account holder acts as agent for that supplier, the account holder has Scheduled Airline Failure Insurance in place and the CAA have approved the agency status.
  4. Flight Carrier Reimbursement – reimbursement of a payment made to a flight carrier in return for a confirmed ticket with guaranteed travel. This may only apply where the account holder has Scheduled Airline Failure Insurance in place and the CAA have approved the insurance.
  5. BSP Payment Performance – reimbursement of a payment made for airline tickets through IATA BSP. This may only apply where the account holder has Scheduled Airline Failure Insurance in place and the CAA have approved the insurance.
  6. ATOL Holder Package Reimbursement – reimbursement of a payment made for a package to an ATOL holding principal.  This may only apply where the account holder has Supplier Failure Insurance in place and the CAA have approved the insurance.
  7. Refund already made – this covers the reimbursement of sums refunded to consumers.
  8. Cancellation – this covers cancellation charges due back to the account holder under the package travel contract.
  9. Limitation Expiry – Sums that have been in the trust account for more than 6 years.
  1. Closing Date Expiry – Sums that settled into the trust account after the trust has closed.
  2. Scheduled Airline Insurance Refund – reimbursement of payments made a) to a consumer or b) in relation to a repatriation or c) for alternative travel arrangements following the failure of an airline and an account holder’s claim on a Scheduled Airline Failure Insurance policy.
  3. Supplier Failure Insurance Refund – reimbursement of payments made a) to a consumer or b) in relation to a repatriation or c) for alternative travel arrangements following the failure of a non-flight supplier and an account holder’s claim on a Supplier Failure Insurance policy
  4. Insurance Premium Refund – reimbursement of payments made for insurance premiums where the insurance has been issued.
  5. APC Payment Reimbursement – reimbursement of payments made to the ATT in respect of APC.
  6. Corporate Credit Card Flight Purchase Reimbursement – reimbursement of payments made using a corporate credit card to a flight carrier in return for a confirmed ticket with guaranteed travel.

This structure can represent a significant barrier to travel businesses that have been used to operating in a fundamentally different way. Having appropriate trust support and guidance from trustees that understand the CAA full trust structure is crucial to ease travel companies through this difficult transition. Contact us for further information.

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Serenity Trusts is a trading name of Travel Trust Services Ltd, a limited company, registered in England and Wales, First Floor, Dale House, 64 Fink Hill, Horsforth, Leeds LS18 4DH (registered number 8717843).

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