ATOL Standard Term 1.3 changes are coming: Is your affiliate program ready?

Brands that sell ATOL-protected products in the holiday and travel industry are about to experience a range of new rules when it comes to marketing these products online to UK consumers. In particular, brands will need to pay close attention to the way affiliates and influencers promote ATOL-protected products, as the consequences could have far-reaching effects on their businesses.

The Civil Aviation Authority (CAA) is introducing significant changes to ATOL advertising, which are specifically targeted at digital marketing. The new advertising rules, which come into effect on 1st April 2026, focus on the marketing of ATOL-protected holidays and flights on websites, apps, social media platforms, and other digital influencer channels. 

Amendments to ATOL Standard Term 1.3, detail how ATOL protection is to be referenced in any digital advertising. These updates aim to bring digital marketing in line with traditional broadcast advertising such as TV, Radio, and print media. 

What changes will likely affect brands?

Coming into effect on the 1st April 2026, the changes to ATOL Standard Term 1.3 will need to be implemented across major digital platforms where ATOL advertising is taking place.

These changes will affect brands, affiliates, influencers, and other digital marketers. The most significant are as follows:

• The ATOL logo, the ATOL number, and the phrase "ATOL protected" should be prominently displayed within the ad itself.
   
• Significant Terms can no longer be hidden behind a link; they need to be clear and visible ‘in the moment’ so that the viewer of the advert can see them.
   
• As part of the Advertising Standards Authority (ASA) guidance on digital advertising for affiliates and influencers. Both brand and affiliate will share responsibility for ensuring adverts are identifiable on digital platforms.

The full scope of changes to ATOL Standard Term 1.3 has considered feedback from a variety of stakeholders. They aren’t just about making adverts more compliant; they are also designed to make adverts more visible, without taking away from the user experience.

The CAA website provides guidance for brands on ATOL advertising

The cost to brands for non-compliance

By the 1st April, 2026 The Civil Aviation Authority (CAA) expects brands and their affiliate partners to have implemented changes to their content so that it meets the standards laid out in Term 1.3. Failure to do so may result in a number of enforcement actions the CAA may choose to take. These include:

• Licensing restrictions: Removing, suspending, or limiting a brand/affiliate to participate in any ATOL advertising. There may be a ‘fit and competent’ review of any businesses that regularly breaches advertising rules.
   
• Criminal Prosecution: In severe cases, the CAA can pursue criminal proceedings against brands and or affiliates that continually break the terms of advertising standards laid out in Standard Term 1.3
   
• Financial Penalties: The CAA may refuse claims should they feel that the advertising party has deliberately misled consumers. This will then pass responsibility of any compensation over to the advertiser.
   
• Rulings by Advertising Standards Authority (ASA): If breaches of the advertising standards occur then the ASA may use its powers to restrict or withhold advertising space for the brand or affiliate.

Deadline fast approaching

With a deadline in place for the 1st April 2026, brands in the travel industry have their work cut out ensuring that affiliates, influencers, and other digital marketing partners have got their digital content updated to be compliant with ATOL Standard Term 1.3. 

For many brands this presents a daunting task of manually checking hundreds of thousands of web pages, social media posts, and other digital content to make sure information is correct. It’s a similar task to that experienced in other industries, such as finance and gambling, where wholesale regulatory changes introduced new daily tasks of checking and auditing third party marketing material.

Potential solutions for checking and managing content

There are a variety of approaches brands in the holiday and travel industry can take in cleaning up their digital footprint regarding ATOL-protected products and preventing potential threats in the future.

Manual checking: The slowest and most resource-intensive option, which generally requires setting up a dedicated team to examine content that contains mentions of brand + ATOL. This method usually requires the use of search engines to track down content and can be hampered by ‘human error’. Manual checking requires organisation and leadership to deliver successful results. 

Manual checking + free tools: There are some tools in the market that can help track data. One fairly obvious one is Google Alerts, which can be used for identifying content that has certain characteristics. This is not a full proof method, but can be more effective than manual checking if set up in the right way.

Specialist scanning software: A much more efficient way of identifying content that may not meet the new terms would be using specialist software, which is designed to track down instances of Brand + ATOL together. Depending on the software, it may also be able to predict the threat level or suggest courses of action. 

AI tools: The use of AI tools can be a method for discovering and resolving non-compliant content. It can be prone to error, so it needs to be handled carefully. Brands should not outsource decisions of significant importance to AI, but the technology can be trained to assist in tasks that require a lot of repetition or manual checking. One of the drawbacks of using AI is exposing company sensitive data to the technology, which is not always in the businesses interests.

Whatever decisions brands take for dealing with the changes to ATOL Standard Term 1.3, the time to act is now. There are only two months until the deadline for getting your ‘house in order’ and ensuring the content on your marketing partners' websites is compliant with new ATOL advertising rules.