The association published its full response on Friday (31 March), reinforcing comments made by director of membership and financial protection Rachel Jordan to TTG earlier this month.

Writing for TTG’s latest Big Question on whether it was time to reform the Atol scheme, Jordan said there should be a range of solutions to suit all Atol holders, adding Abta was opposed to mandatory segregation of customer monies.

Abta said it had consulted extensively with members during the six-week call for evidence, as well as the financial services industry – including banks, insurers, merchant acquirers, bond providers and trust providers.

"One of the points Abta has made repeatedly, including in its formal response, is the lack of clarity on the rationale for reform," said Abta on Friday. "Abta says the Covid-19 pandemic demonstrates resilience in the sector is strong and the Atol scheme stood up well during this time, so questions what the reforms are trying to achieve."

Another key criticism from Abta was the CAA’s failure, so far, to evidence any alignment between the various government departments involved in Atol reform, and any alignment with separate reform of the UK’s package travel rules.

Abta’s comments follow feedback earlier this week on the reforms from the Association of Atol Companies, which said in their current form, the CAA’s proposals would increase costs and complexity for every Atol holder.

Here are Abta’s six main points of contention with the CAA’s proposed reforms, detailed in its response to the call for evidence.