ATOL for Umrah Travel Agents: Which Route Fits Your Agency

It is a Friday in February. After the prayer, a man you have known for years puts an envelope in your hand: £600, the deposits for him and his wife on your Ramadan group from Manchester. You write him a receipt from the pad you keep in the car.

Under UK rules, that sale has already gone wrong. When a package includes a flight, the pilgrim must be given an ATOL Certificate immediately the first payment is taken, and you may not accept the payment at all until you are able to issue one.

The short answer: to sell an Umrah package that includes a flight to consumers in the UK, your business must be the airline, an ATOL holder, or exempt. For an agency that leaves three positions: hold your own ATOL, trade under the licence of an Accredited Body as one of its members, or sell as the agent of an ATOL holder under a written agency agreement. In all three, the pilgrim receives an ATOL Certificate with the first payment.

This guide follows the UK Civil Aviation Authority's own pages, linked at the end. It is written for agencies that sell to pilgrims in the UK, wherever the agency itself is based.

What ATOL is

ATOL stands for Air Travel Organisers' Licensing. The scheme is run by the UK Civil Aviation Authority (CAA). The CAA describes the ATOL Regulations as legal requirements that protect consumers if their travel organiser ceases to trade as an ATOL holder: consumers are brought home, or refunded the money they paid for ATOL protected holidays and flights.

A pilgrim does not have to take your word for it. Anyone can look a business up on the CAA's Check an ATOL page before handing over a deposit.

Does an Umrah package need an ATOL?

The ATOL Regulations set out who may advertise and sell air travel to consumers in the UK:

• the operator of the aircraft — an airline selling its own services;
• an ATOL holder;
• a person who is exempt.

A business that sells a flight-inclusive package, or a flight on its own, has to be one of the three. Flights, hotels and ground transport sold together at one price is what an Umrah package usually is, so this is the rule that applies to most agencies.

The CAA adds three points that matter here:

• Where you are based does not change it. The regulations apply equally to businesses established outside the UK if they advertise and sell to consumers in the UK.
• Where the flight departs does not change it. Packages that include flights and are advertised and sold to UK consumers are covered irrespective of the departure point of the flight.
• There is no fourth category. In the CAA's words: "If you are not an airline or you are not acting in an exempt capacity, you must hold your own ATOL."

Who is exempt

The full list is in ATOL Regulation 10. The CAA names these among them:

• an agent for an ATOL holder;
• a member of an accredited body;
• an airline ticket agent;
• a person acting under a general business travel agreement;
• a person making travel available occasionally, on a not-for-profit basis, to a limited group of consumers.

The first two are the exemptions agencies use, and both are explained below. The last one is narrower than it sounds: all three conditions — occasionally, not for profit, a limited group — are part of it. A mosque committee or a charity that plans a trip should read the CAA's guidance for charities and fundraisers before it relies on it.

If you cannot tell which side of the line your sales fall on, the CAA's advice is to seek independent professional advice. A package without any flight is a separate question that this guide does not cover.

The routes compared

Route	What it is	Limits	Bond	CAA application charge
Agent of an ATOL holder	You sell the ATOL holder's packages under a written agency agreement	The terms of the agency agreement	None to the CAA	None — you do not apply for a licence
Member of an Accredited Body	You trade under the Accredited Body's licence	The Body's conditions of membership	No ATOL bond	None — you apply to the Body, not to the CAA
Franchise ATOL	Your own ATOL, granted because you belong to an approved franchise scheme	The charge rises above 1,000 passengers	No ATOL bond; the franchise gives its guarantee to the CAA	£981 for under 1,001 passengers
Small Business ATOL	Your own ATOL, with a cap	500 passengers and £1,000,000 licensable revenue a year, for at least three years	At least £50,000	£1,538
Standard ATOL	Your own ATOL, no trading restrictions	None	15% of licensable revenue, at least £50,000	£2,606 plus 16.35p per passenger

There is also a Trade ATOL, with a £10,000 bond. Its sales are restricted to other ATOL holders, so it is not a way to sell to pilgrims.

These are the CAA's published charges and conditions. They change; read the CAA's Types of ATOL page and its Scheme of Charges before you budget.

Agent of an ATOL holder

This route needs no licence application of your own, which is why it suits a first season. It only protects anyone if the paperwork is right. The CAA requires an ATOL holder that sells through agents to have a written agency agreement with each agent. That agreement must include the Schedule of Terms published by the CAA, name the ATOL holder and the agent, and be dated. Without the correct agreement in place, both the ATOL holder and the agent are in breach of the ATOL Regulations.

As the agent, three duties are yours:

1. Issue the ATOL Certificate to the pilgrim immediately upon payment, whether the booking is made in a shop, by phone or online. You and the ATOL holder agree who produces it and how it reaches the pilgrim.
2. Keep your paperwork inside the agreement. Anything else you hand out has to comply with the agency agreement and the ATOL Standard Terms, and your receipts must identify protected and non-protected money.
3. Keep the agreement itself. If the ATOL holder fails, the CAA asks agents for a copy of a compliant agency agreement in order to process consumer claims.

The CAA spells out the cost of getting this wrong: non-compliant documentation may be treated as a breach of the regulations, which can result in a consumer's claim being refused and referred back to the agent for a refund.

Member of an Accredited Body

Accredited Bodies are ATOL holders that allow other businesses to trade under their licence. Members need no ATOL bond and take no financial criteria test with the CAA, but they must meet the Body's own conditions of membership. Members can issue ATOL Certificates, and once the Body has notified the CAA your firm's name appears in the ATOL search.

You apply to the Body, not to the CAA. The CAA lists six: Barrhead Travel Service Ltd, Broadway Travel Services (Wimbledon) Ltd, Global Travel Group Ltd, Hays Travel Ltd, The Midcounties Co-operative Ltd and Travel Counsellors Ltd. A business cannot be an ATOL holder and a member of an Accredited Body at the same time.

Franchise ATOL

Here the licence is yours, but the CAA grants it on the basis of your membership of a franchise. You apply to the franchise first and, once accepted, make a second application to the CAA for the Franchise ATOL.

You give no bond to the CAA, because the franchise provides guarantees instead. The CAA notes that franchises will typically insist that their members provide protection through another mechanism, so ask each of them what they require and what it costs. You must still meet the CAA's fitness and competence criteria, and, depending on the size of your licence, you may be required to meet its financial criteria.

The CAA lists four organisations that offer Franchise ATOLs: ABTOT Limited, Advantage Travel Centres Ltd, Protected Trust Services and the Travel Trust Association. It aims to decide within eight weeks on average of receiving the required information.

Small Business ATOL

The Small Business ATOL is your own licence with a ceiling: 500 passengers and £1,000,000 of licensable revenue a year, for a minimum of three years. Five hundred passengers is about eleven groups of 45.

What the CAA asks for:

• a bond of at least £50,000;
• the personal fitness and competence test, and the Small Business ATOL financial criteria;
• paid-up share capital of at least £30,000, for a limited company;
• an application fee of £1,538;
• an advance payment of £1,250 towards the ATOL Protection Contribution.

Standard ATOL

No trading restrictions. The bond is 15% of licensable revenue with a minimum of £50,000, the application fee is £2,606 plus 16.35p per passenger, and the same £30,000 of paid-up share capital applies to limited companies. An agency that outgrows the Small Business limits ends up here.

The ATOL Certificate: what your booking process has to do

The Certificate is the pilgrim's proof that the purchase is protected. It states what and who is covered, the issuer's business name and its ATOL number. The CAA sets the format, and each certificate must follow it exactly.

Situation	What the CAA requires
The pilgrim pays in person	The Certificate is handed over at the time payment is made
The pilgrim is not present	It is sent by email, or an equivalent electronic means, immediately after the payment is taken
The pilgrim books by telephone	It is emailed, or posted immediately
A cheque is accepted, or card details are taken	That already counts as taking payment, whether or not the payment has been processed
Details on the Certificate change more than 72 hours before departure	The Certificate is issued again
You cannot yet issue a Certificate	You, or your agent, may not accept any payment

The issuer named on the Certificate is the business that deals with the consumer, regardless of who generates the document.

For an Umrah agency this turns the usual habit around. Deposits collected at an information evening, in a WhatsApp chat or after Friday prayer are first payments. The Certificate has to be ready before you take them.

The ATOL Protection Contribution

Every booking an ATOL covers carries a contribution to the fund that pays for refunds and repatriation. The ATOL Protection Contribution (APC) is £2.50 per passenger, and a passenger is anyone aged two or over on any date of travel. A group of 45 adults is £112.50.

The licence holder pays the APC to the Air Travel Trust. The pilgrim does not: the CAA says it should not appear as an additional passenger charge or "tax" in brochures, on websites or on ATOL Certificates. It is a cost in your package price, like the visa.

Licence holders are required to provide reports of their ATOL sales, monthly to quarterly depending on the licensable revenue the licence authorises. That report is built from numbers you need anyway: how many passengers booked, on which departure, and what they paid.

Applying for your own ATOL

For a Small Business or Standard ATOL, the CAA describes six steps:

1. Create a portal account on ATOL Online.
2. Submit the online application with the fee and the supporting documents. Application fees are non-refundable.
3. Provide financial information. A start-up sends a certified opening balance sheet in the CAA's format; a trading business sends its latest accounts. Both send financial projections covering at least 12 months.
4. Initial assessment. One of the directors or partners is invited to complete the ATOL Accountable Persons online course. The application does not move until it is done.
5. Formal meeting. Normally required. The CAA goes through the finances against its published criteria, including any cash it needs injected, and the fitness and competence points.
6. Offer letter. It lists what must be in place before the licence is granted and allows up to two months to meet it. The ATOL number comes once the licence is granted.

The CAA says an application takes around 12 weeks on average and that it cannot give an individual estimate. An application that is not actively pursued — for example by leaving the CAA's written requests unanswered, or by going out of contact for two months or more — is generally treated as withdrawn, without a refund.

Count backwards from your first sale, not from your first departure. A Ramadan group that you want to open for deposits in October needs an application sent in the summer.

If you sell without it

The CAA's enforcement covers the advertising and sale of flights and holidays under the ATOL Regulations. In its own description, it takes an advisory approach in most cases, but where shortcomings in compliance are found it is likely to take a more formal approach, "which may lead to a person or business being prosecuted."

Choosing a route

The rules above are the CAA's. What follows is our reasoning about them, not regulation.

• You want to sell this season and have no trading history. Selling as the agent of an ATOL holder, or joining an Accredited Body, avoids a licence application of your own. The price is independence: the package, the terms and the protection belong to someone else, and your paperwork has to match theirs.
• You want your own packages under your own name, at small volume. Compare a Franchise ATOL with a Small Business ATOL. The first has no bond to the CAA but adds a franchise with its own requirements and fees; the second needs a bond of at least £50,000 and £30,000 of share capital.
• You expect more than 500 passengers a year. Plan for the Standard ATOL from the start; the Small Business ATOL stops at 500.

Whichever you choose, put it in writing where pilgrims can see it: whose ATOL protects the booking, and its number.

How Ziyara fits

Ziyara is software for running your groups. It is not a licence, a bond or a trust account, it is not connected to the CAA, and it does not produce ATOL Certificates. Your ATOL holder, your Accredited Body or your own CAA account does that.

What it gives you is the record the rules assume you have:

• Every payment, dated. Each deposit and instalment is recorded against the pilgrim with its amount, date and method, and a receipt can be printed as a PDF — see the guide to instalments and payments.
• One list per departure. Each group holds its travellers, their flights and what they pay, so the passenger numbers and income of a departure come from the same place as its rooming list.
• Cancellations on record. A cancelled registration leaves the group lists, but the pilgrim and their payments stay on file — which is what you need when a Certificate has to be issued again.

The licence is one line in the budget of a new agency; the rest is in how to start an Umrah travel agency and what one group really earns.

Frequently asked questions

Do I need an ATOL to sell Umrah packages in the UK?

If the package includes a flight and you sell it to consumers in the UK, you must be an ATOL holder or exempt — for example as the agent of an ATOL holder under a written agency agreement, or as a member of an Accredited Body. The CAA states that a business that is not an airline and is not acting in an exempt capacity must hold its own ATOL.

Can I sell Umrah packages under another company's ATOL?

Yes, in two ways. As an agent, you sell an ATOL holder's packages under a written agency agreement that includes the CAA's Schedule of Terms. As a member of an Accredited Body, you trade under the Body's licence. In both cases an ATOL Certificate is issued to the pilgrim immediately the first payment is taken.

How much does a Small Business ATOL cost?

The CAA's application fee is £1,538, with an advance payment of £1,250 towards the ATOL Protection Contribution. The licence also requires a bond of at least £50,000 and, for a limited company, at least £30,000 of paid-up share capital. It is limited to 500 passengers and £1,000,000 of licensable revenue a year.

How long does an ATOL application take?

The CAA says a licence application takes around 12 weeks on average. For a Franchise ATOL it aims to decide within eight weeks on average of receiving the required information, after you have been accepted by the franchise.

Does ATOL apply if my agency is outside the UK or the flight leaves from another country?

Yes. The CAA states that the ATOL Regulations apply equally to businesses established outside the UK if they advertise and sell to consumers in the UK, and that flight-inclusive packages sold to UK consumers are covered irrespective of the departure point of the flight.

When must the ATOL Certificate be issued?

Immediately, when the consumer makes the first payment. Accepting a cheque or taking card details counts as taking payment. You may not accept any payment until you, or your agent, are able to issue the Certificate.

Sources

• UK Civil Aviation Authority — Do I need an ATOL
• UK Civil Aviation Authority — Types of ATOL
• UK Civil Aviation Authority — Small business ATOL
• UK Civil Aviation Authority — Franchise ATOL
• UK Civil Aviation Authority — Accredited bodies
• UK Civil Aviation Authority — Travel trade selling through agents
• UK Civil Aviation Authority — ATOL Certificates
• UK Civil Aviation Authority — ATOL Protection Contribution
• UK Civil Aviation Authority — ATOL enforcement
• UK Civil Aviation Authority — Check an ATOL