Key findings from the September 2025 ATOL authorisation data

Movement in the top 20 ATOL holders over the past 12 years (click on a year to interact with the graph)

When travel businesses renew their Air Travel Organisers’ Licence (ATOL), they forecast the number of passengers they plan to carry over the next 12 months. The resulting authorised passenger total is a good way to understand the state of the sector.

Following the September 2025 renewal, we’ve conducted an in-depth review of this latest data. It delivers a vivid snapshot of operator strategy, revealing stability in headline numbers, but notable shifts within the top players point to ongoing consolidation and long-term uncertainty across the travel sector.

Here are four essential insights we think you’ll find valuable. 

1 – The number of ATOL holders is flat, but capacity has risen 

Compared to last year, the number of ATOL holders is largely unchanged. In 2024, there were 1,582, and this year there are 1,588, underscoring a plateau after recent years of turbulence.

However, interestingly, the total number of authorised passengers has increased, now just under 34.8m, marking a 4.3% increase overall. While this is encouraging, it masks a mixed picture beneath the surface. Major players, such as Booking.com and Travel Republic, both reduced their authorisations (down by 157,197 and 93,696, respectively), with Travel Republic dropping out of the Top 20 altogether.

2 – easyJet holidays and Trip.com are the big movers 

The standout increase in this renewal cycle is easyJet Holidays, which added 400,298 passengers, a 13% year-on-year increase from March 2025. This surge has strengthened its position among the top five, as it now accounts for 10% of the overall package holiday market. 

Trip.com makes its debut in the Top 20, surpassing 100,000 licensed passengers for the first time, while Hurtigruten and Royal Caribbean have more than doubled their passenger numbers too. Other notable contributors to growth include TUI (up 91k passengers,+2%) and Expedia Group (up 82k passengers,+24%).

While the top three operators have been more cautious with their projections amid shorter lead times, those targeting growth will look to capture resilient consumer demand.

3 – A seasonality shift – is customer booking behaviour changing?

While overall capacity is growing, the underlying trends suggest a seasonality shift in  booking behaviour.

The largest 20 ATOL holders are predicting the quarter ending December 2025 will be completely flat and only modest growth of 2% for the peak summer quarter ending September 2026. Instead, their growth is focused on the comparatively quiet March 2026 quarter, as key operators look to use winter sun to entice more passengers. 

Those outside the top 20 have a different outlook. The quarters, ending December 2025 and March 2026, are back in growth, implying confidence in trading in the near term. Smaller operators appear less confident for next summer, with both June 2026 and September 2026 in decline once again.

This pattern reflects a cautious sentiment among operators and consumers. Given the later booking window, the uncertain economic and geopolitical backdrop and fluctuating consumer confidence, operators appear reluctant to overcommit to higher capacity so early.

4 – Consolidation continues: top 20 tighten their grip

The top 20 ATOL holders now account for 86% of all authorisations, an increase that underscores continuing market concentration.

The top three, Jet2, TUI, and Love Holidays, now command 51.8% of the total market.

For smaller operators, the story remains challenging. This marks the fifth consecutive renewal where authorisations outside the Top 20 have declined.

However, this year’s decline is marginal (-0.7%), suggesting a possible stabilisation.

While overall ATOL passenger growth remains modest, the underlying shifts tell a story of market consolidation, strategic growth among online leaders, and a generally cautious outlook.

In the coming days, the key watchpoint will be how late renewals influence overall authorisation totals, and as the year progresses, variations for the summer months will indicate whether the mid-tier market believes it can regain momentum after several years of attrition.

We covered these trends on our latest TTC Insights Travelcast – you can rewatch the recording now. Skip to 29:00 for these insights.

If you would like to discuss any of the insights above, please get in touch.

*ATOL holders are defined as total ATOL holders after stripping out nil licences and transport company licences.

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