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Package travel: complaints and records in the business

Package travel in business operations: record complaints correctly, document remedies and distinguish travel services, price reduction and damages.

BRANDAUER Rechtsanwälte
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Mag. Bernhard Brandauer, Austrian attorney-at-law

BRANDAUER Rechtsanwälte

Mag. Bernhard Brandauer assists with the legal assessment of tourism contracts, operating issues, levies and liability matters.

16 August 2026 · Mag. Bernhard Brandauer, Austrian attorney-at-law

A complaint about a package holiday requires a business to distinguish quickly between general dissatisfaction, a specific non-conformity and a possible consequential loss. Under section 11(1) of the Austrian Package Travel Act, the organiser is responsible for the travel services agreed in the package travel contract even where a hotel, transport company or another supplier performs the service. Clear records therefore support not only the response to the traveller, but also internal responsibility, a remedy and the later assessment of a price reduction or damages.

This article is aimed at organisers, travel intermediaries and tourism businesses handling complaints as part of their daily operations. It focuses on receipt, routing, the remedy offered and a comprehensible file. The assessment of an individual claim always depends on the booking documents, the course of the trip and the actual effects of the deviation.

Classify the situation

Where does your business stand with the complaint?

Four answers lead to the key documents and the next practical step.

01 Question 1

When did the complaint arrive?

Classify the timing and the phase of the trip affected.

Result

Your orientation

01

Compare the booking documents and service description.

Preserve the version of the description, the booking confirmation, change messages and the relevant booking data. The key question is what was promised before the contract and what was later confirmed.

02

Record notice, remedy and the on-site response chronologically.

Record when and to whom the notice was given, the deviation, the proposed solution and what actually happened. During an ongoing trip, the responsible person should involve the supplier promptly and preserve the communication.

03

Review the demand, evidence and loss items separately.

Separate a price reduction, necessary expenses and other losses. The response should address the travel service, the chronology and the evidence, not only the total price.

04

Preserve the intermediary’s receipt time and the forwarding record.

Under section 13 PRG, a message, request or complaint may be received by the travel intermediary. Preserve the original message, receipt time, forwarding and internal takeover so that no date is lost.

How a business should classify a complaint

The first question is which service was actually agreed. Package travel combines at least two different types of travel service for the same journey or holiday. For handling purposes, the booking confirmation, service description, pre-contract information, changes and communications with the traveller all matter. A general reference to the hotel or transport company does not replace that review.

The business should also record its role. The organiser remains responsible for the agreed package travel services even where a supplier is asked to provide the practical remedy. A travel intermediary has its own information and forwarding duties. A hotel or transport company may also be liable under its own contract or special rules. These roles must not be mixed in the internal file.

A short intake summary is useful: which trip, which service, what deviation, when and what outcome is requested? This prevents a long message history from hiding the decisive facts. The package travel and organiser topic page provides the broader framework for the contractual roles and the travel service concerned.

What matters in the notice and first response

Section 11(2) PRG requires travellers to notify the organiser without undue delay of a non-conformity noticed while the travel services are being provided, taking the circumstances into account. For the business, this means saving the time and content of the notice. A standard response that simply sends the traveller back to the supplier does not address the legal and operational situation.

The first response does not have to be a final liability decision. It should confirm receipt, repeat the service concerned, name an available contact person and set out the next remedy step. If photographs, receipts or a precise description are missing, the business can request those documents specifically. At the same time, it should assess whether an immediate measure is needed to prevent further loss.

The response should remain factual. Neither a blanket admission nor a blanket rejection replaces the review. Wording such as “We are checking the deviation with the service provider and will confirm the next step” creates a clear expectation without prejudging the legal assessment. A telephone complaint should be recorded with its essential content and the agreed measure.

How to record a remedy or alternative service

Section 11(3) PRG requires the organiser to remedy a non-conformity unless this is impossible or would involve disproportionate cost in light of the extent of the non-conformity and the value of the affected service. The file should therefore not say only “resolved”. It should identify the measure, time, responsible person, traveller’s response and actual implementation.

Depending on the case, a remedy may be a room change, repair, replacement transport or another suitable service. If a significant part of the trip cannot be provided as agreed, appropriate alternative arrangements for continuing the trip may be required. Record the quality, additional cost, consent and any price reduction in a way that can be followed later. An alternative is not sufficient merely because it was easier for the business to arrange.

If the organiser does not remedy the problem within a reasonable period, section 11(4) PRG can allow the traveller to arrange the remedy and claim the necessary expense. No period is required where the organiser refuses to remedy the issue or immediate action is necessary. The file should therefore explain why a measure was possible, impossible or delayed.

Why the intermediary does not reset the receipt time

Section 13 PRG allows travellers to send messages, requests or complaints about the performance of package travel services to the travel intermediary from whom the package was purchased. The intermediary must forward the communication to the organiser without undue delay. For time limits and limitation periods, receipt by the intermediary counts as receipt by the organiser.

The internal rule is simple: preserve the original message with its original receipt time. Forwarding may show when the case entered the next processing stage, but it must not replace the original date. The same applies to platform messages, call centres, hotel reception or a local representative. A ticket with a new internal time must not overwrite the original receipt.

The intermediary and organiser should record who received, forwarded, answered and took over the matter, and when. Where a travel service is affected at short notice, the file should also identify who can make an on-site decision. This reduces duplicate replies, conflicting promises and unclear responsibility.

What belongs in a complete complaint file

The file should first contain the contract, booking confirmation, description and information supplied at booking. Add invoices, payment records, change notices and the service description applicable at the time of booking. For dynamic websites, preserve the relevant version with a date or an unchanged export.

For the trip itself, create a chronology: arrival, first observation of the deviation, notice, response, remedy attempt, alternative service, further complaints and departure. Keep original photographs and videos together with the recording time and a short location note. For statements by staff or suppliers, record the name, function, time and substance.

Record the financial side separately. A price reduction concerns the lost value of a non-conforming travel service. Necessary expenses, such as the cost of an alternative service, should show their purpose, amount and proof of payment. Further loss and serious interference with the holiday must not be merged into the price reduction. The travel defect glossary entry explains the distinction between deviation, remedy and consequences.

How to review and close a claim

For a claim submitted after the trip, assign each item to a travel service and a period. Section 12(1) PRG provides a reasonable price reduction for each period in which the package was affected by a non-conformity. Damages under section 12(2) serve a different function and concern loss caused by the non-conformity. Serious interference with the holiday may also be relevant to compensation for loss of holiday enjoyment.

The response should show which facts are accepted, which documents were reviewed and which points remain open. A rejection or partial settlement needs a specific reason. Internal notes should also record whether the supplier was involved, what remedy was offered and whether a timely notice would have allowed a response. This keeps a later handover to legal advisers comprehensible.

Closing a file is more than sending a letter. Keep the final response, calculation, payment or credit records, communication with the traveller and the retention decision. Repeated defects should be passed to product management so that descriptions, supplier oversight or operating procedures can be improved.

Which errors make complaints harder to resolve

A common error is forwarding the complaint only to the hotel or transport company. This costs time and can produce conflicting answers. The supplier may carry out the practical remedy, while the organiser remains the contractual contact for the traveller. Another weakness is a record without times: “traveller complained” does not show whether a remedy could still have been provided.

Blanket vouchers or price reductions without an identified service are also problematic. They make the factual review harder and leave unclear what was affected. Keeping only the final invoice is not enough. The original description and on-site communications are needed for comparison.

Finally, some complaints are collected and answered only after the traveller returns, although a concrete remedy was possible during the trip. That can make the loss assessment more difficult. A short documented first contact, a clear responsibility and a chronological file are usually more effective than a long standard letter at the end.

Key point: Keep the receipt, travel service, deviation, notice, response and remedy in one chronology. The organiser remains responsible for agreed package travel services. Intermediaries must forward complaints, while the original receipt remains decisive. A price reduction, necessary expenses and further loss must be reviewed separately.

Frequently asked questions

Questions about complaints in a tourism business

Must an organiser answer every complaint itself? +
The organiser is responsible for the agreed package travel services. A hotel or another supplier may provide the practical remedy. The internal responsibility and communication should nevertheless be recorded clearly.
What should a complaint file contain? +
Important items are booking documents, the service description, receipt time, the specific deviation, notice, contact persons, proposed remedy, response, photographs, receipts and a chronological processing note.
Does a complaint to the intermediary also count against the organiser? +
Under section 13 PRG, the intermediary must forward messages, requests or complaints without undue delay. For time limits and limitation periods, receipt by the intermediary counts as receipt by the organiser.
How should an alternative service be recorded? +
Record the reason, time, exact alternative, quality comparison, additional cost, acceptance or refusal and actual implementation. Any later price adjustment should remain comprehensible.
Are a price reduction and damages the same? +
No. A price reduction concerns the reduced value of a non-conforming travel service. Damages concern additional loss caused by the non-conformity. Each item should be described, evidenced and assessed separately.

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