The update is designed to give greater clarity to firms that do not have direct control over the product that they sell.

Currently, when a travel company advertises an offer it is expected to sell 10% at the displayed "from" price. This is expected to remain the case for those that have direct control of the product e.g. airlines but will change for those that don’t e.g. agents.

The CAP is the sister organisation of the Advertising Standards Authority (ASA).

Responding to a session at the Abta Travel Law Seminar, Daira Moynihan, the ASA’s operations manager – investigations, spoke about what the new proposal might look like.

“What we will look for is evidence of a reasonable degree of availability and we’re not going to prescribe what reasonable means and we’re not going to impose the 10% rule… and it will be addressed on a case by case basis,” he said.

Moynihan added that the new guidelines would aim to “reflect the challenges and issues inherent to the industry”. The CAP is expected to announce the new guidance in the coming weeks.

Speaking beforehand, Sue Barham, partner at law firm Holman Fenwick Willan, said she hoped the new guidelines would be more “nuanced” and would include “a recognition that as an advertiser in the travel industry you aren’t necessarily completely in control of what price changes may be introduced”.