This round of 30 September renewals features 14 of the current top 20 Atol holders, including the top two of Tui UK and Jet2holidays, so there will be plenty of focus on their licensed numbers – especially for summer 2022 when travel will be hoping to bounce back strongly.

Alan Bowen, legal advisor to the Association of Atol Companies (AAC), said: “They are being far more realistic and nobody is looking for the licence numbers they had in 2019. If business goes up, they can apply for a revision upwards and put more passengers on the licence.”

One clear trend is that the CAA is already looking to push larger Atol holders down the trust account model of consumer protection.

Yasin Khandwalla, audit director at Elman Wall, said: “The CAA is encouraging larger Atol holders [£20 million in licensable turnover pre-Covid] to go down the trust account or escrow approach.

“The CAA has to consider companies are going to be making a loss and there’s an obvious focus on the liquidity position.”

Martin Alcock, director of the Travel Trade Consultancy, said: “Over the past year, we’ve seen more and more Atol holders forced into these arrangements [the use of trust and escrow accounts]. We expect to see more of these demands as the renewal unfolds.”

Alcock added that the CAA was asking for “lots more information from applicants, as they did in March, which makes the renewal process more painful”.

March’s renewals saw a significant proportion of Atol holders leaving it to the last minute to submit renewal paperwork.

“They were waiting in hope that things were going to get better,” added Bowen. “There were 10% who submitted seven to 10 days before the deadline and that caused all sorts of issues.”

Will we see a repeat of this late-filing trend in the run-up to the 30 September? We have only another few weeks to wait.

These are the UK’s top Atol holders due to renew by 30 September, showing their current 2020/21 licence numbers.

• Tui UK – 3.7 million passengers
• Jet2holidays – 3.5 million
• British Airways Holidays – 599,000
• easyJet Holidays – 547,000
• BravoNext (lastminute.com) – 433,000
• easyJet Airline Company – 342,000
• Expedia Group – 317,000
• Southall Travel – 291,500
• Trailfinders – 174,000
• Travel Republic – 165,000