If you’re a travel business selling flights, you already know how vital your ATOL (Air Travel Organiser’s Licence) is. It’s not just a legal requirement – it’s a safety net for your customers. But renewing your ATOL isn’t a simple “tick the box” exercise.
Whether you’re approaching your renewal date or trying to stay ahead of the process, here are five common pitfalls to watch out for and tips on how to avoid them.
1 – Underestimating the renewal process
You’d think renewing would be easier than applying for your first ATOL, but it can be just as demanding. You’ll need to submit your latest accounts, forecasts and a range of other documentation depending on the size of the licence. And any gaps or inconsistencies could lead to delays – or worse, a lapse in your licence.
Anyone authorised or applying for a licence covering more than £5millon in licensable revenue needs to be prepared to provide audited accounts as part of your renewal. In addition, you’ll need to submit up-to-date management accounts and a budget or forecast extending to the next financial year-end.
Many renewals go down to the wire, and some even end up on the CAA’s list of companies that didn’t renew in time. This is publicly issued, and being on that list can damage your brand’s reputation, so it’s something you want to avoid.

2 – Delaying conversations with your ATOL Reporting Accountant
ATOL Reporting Accountants (ARAs) conduct thorough checks before approving Annual Accountants’ Reports (AARs), and this process can take time. If you delay reaching out to your ARA, it could result in significant delays to your licence renewal.
Additionally, if retrospective changes are needed to your APC returns before your ARA can sign off on AAR Part 1, you will need to allow time for the CAA to process these changes and reissue the AAR, which could further hold up your renewal.

3 – Neglecting financial performance
During the renewal process, your financial health comes under close scrutiny. It’s essential to understand which CAA financial tests apply to your business and, where possible, assess your compliance with these tests before you submit your application.
For businesses applying for a licence under £20million, the CAA offers a self-assessment tool to help you prepare. However, for licences exceeding £20million, the requirements are often more bespoke and demand a deeper review of your financial management.
Failing to meet these financial criteria can jeopardise your renewal, so preparation is key.

4 – Overlooking changes made by the CAA
The travel industry is constantly evolving, and so are ATOL compliance requirements. Missing even a small change can cause issues with your renewal. The CAA sometimes make tweaks to their reporting requirements, which may seem small but can be significant. For example, 31 January 2025 marks the phased introduction of some new rules for completing your APC returns.

5 – Misjudging your licence requirements
Deciding on the right licence size is no small task – it requires predicting your future sales and operations accurately. If you apply for a licence covering more than £20million in ATOL sales, your application will be handled by a specialist team within the ATOL department. This means moving away from standard financial ratios to a more tailored review process, which involves providing significantly more detailed information.
Based on discussions we’ve had with the CAA, you’ll need to demonstrate how you manage client funds, demonstrate that you have sufficient liquidity within your business, and explain the safeguards you’ve put in place to protect customer money.

Final thoughts
Renewing your ATOL doesn’t have to be a headache. With preparation, attention to detail and the right support, you can navigate the process confidently.
Whether you need advice on financial forecasting, compliance updates, or simply want a second opinion, don’t hesitate to get in touch. Sometimes, a helping hand is all it takes to ensure your renewal goes smoothly – so you can focus on building your travel business.
If you like this, we think you’ll love:
- March 2025 ATOL renewal: changes you need to know
- 5 key findings from the 2024 ATOL authorisation data
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