Destination and Policy Update

June 2020

We continue to update our Coronavirus resources page regularly with practical information on destinations, overview of travel restrictions, guidelines, research and other resources. Updates are announced in the weekly newsletter.

The Coronavirus Hub gives an overview of ETOA’s current activities and webinars.

This update contains information on risk management, digitalisation, sustainability, TOMS reform consultation as well as information regarding some attractions’ opening plans.

Today, 27th May, we will hold an online Group Tourism working group meeting at 15:30 BST / 16:30 CEST. Members working with group tourism are welcome to participate. Please contact Sofie Jensen if you would like to join this meeting or hear more.


Risk management and guidelines

Risk management has become much more complex. Jargon does not help: ‘Covid-secure’ is a claim of risk control, not that the risk is absent. Operators selling B2C are usually liable for the proper performance of services in a package. Exceptions arise, such as in France where the retailer is liable. In both cases, what constitutes proper performance matters, and this is the subject of much uncertainty. For B2B operators and DMCs, aside from statutory liability and obligations, they may be asked to meet new contractual requirements or provide indemnities, some of which will be hard to satisfy.

Guidelines issued by the WHO are at the foundation of most sector-specific recommendations to manage COVID-19 risk, and many businesses have developed their own in-house practice based on them. Some are subject to external audit and certification. All will entail practical changes to operations. For example, in a hotel the new regime might be: no housekeeping during period of guests’ occupation; more rigorous cleaning of keypads, door handles, remote controls; anti-virus cleaning certification of rooms prior to guest entry; physical barriers and social distance management at reception; take-away and/or room-service-only breakfasts.

Measures that are practical in some premises may not be in others. Europe’s supply chain is very diverse: over 70% of hotels are independent. To cope with this, operators will evolve their own in-house procedures, in part to provide reassurance to their clients that their safety remains paramount, and to anticipate conditions in destination. For those offering cross-border product the need for coordination and convergence is clear, particularly in relation to social distancing. It is confusing for both operator and client if requirements vary over the course of a single itinerary.

There are financial risks: if a group is stranded due to quarantine the operator may be liable for costs. Knock-on effects on hospitality and transport services quickly multiply. Whether these are insurable risks under current circumstances is an open question.

Operators’ care for clients will remain the sector’s focus as we build towards recovery. It is important that each operator devises a risk management process that they can deliver, and suits their circumstances, client profile and product offer. It follows from this that care should be taken not to commit to meeting guidelines or standards unless compliance can be assured. Operators can be held liable for failing to meet in-house standards that exceed statutory requirements.

Travel will always include risk. Visitors will explore independently and confront unfamiliar traffic. Other travellers may pose a risk of infection to others unrelated to COVID-19. Operators’ duty is to mitigate risk, not to eliminate it.

Both recommendations and regulation must recognise that tourism needs to be economically viable to be socially valuable. Limits on private coach load factors must not be stricter than those applicable to public transport. Small hotels with one lift cannot be expected to achieve the same social distancing among clients as larger properties. Group travel providers, whose use of private coaches keeps travellers off mass transport systems, need more information about how services can be delivered otherwise they cannot sell.

As soon as prudent and practical, both public health advice and sectoral guidelines must allow a return to activity which is commercially sustainable for both operators and service providers. ETOA will continue to argue for proportionate and pragmatic proposals that will support this.

Digitalisation and Sustainability

Digitalisation and Sustainability will remain the twin pillars of EU policy as the post-COVID recovery package and the next MFF are debated (Multi-annual Financial Framework, the EU’s budget 2021 onwards). EU regulatory developments already planned for 2020 continue to make progress. The EU’s data strategy consultation closes on 31st May: the intention is an open market for data within the framework of GDPR. Whether data that is currently private should be made available to policy makers and other stakeholders attracts wide interest from consumer rights groups to destination managers, and those who are seeking to adapt quickly to domestic and intra-European demand, but are lacking current consumer preference data. Is there a public interest argument in current crisis that it should be made more widely available to kick-start recovery plans?

On sustainability, further to previous communication, though delayed by the COVID-19 crisis, ETOA will be surveying its members to ensure its policy work in this area aligns with current interests and broader policy priorities.

Tax and Tourism

The European Commission has just opened a public consultation on the future of TOMS VAT (‘the special VAT scheme for travel agents and tour operators’). While agreeing tax reform in the EU is a challenge (any major change requires unanimity among EU27), there is widespread acceptance that rules in force for over 40 years need review to maintain their stated objectives in a market that has completely transformed: one question is whether a special scheme should remain at all.

ETOA’s position is that value-adding in Europe should be encouraged through fiscal frameworks, that exports of packaged product should not be subject to VAT, and that any scheme should be simple to operate without the need for multiple registration. For businesses based outside the EU buying services delivered within the EU, multiple registration is a distinct risk. From the Commission’s roadmap, their purpose is:

… to evaluate the application and implementation of the special scheme in Member States, because origin-based taxation requires a harmonised application of the special scheme in order to prevent distortion of competition. The evaluation will assess fiscal effects and consequences that may have materialised and possibly affected the level playing field within the European Union and vis-à-vis economic operators located in third countries with a view to determine to what extent the special VAT scheme for travel agents is fit for purpose and has delivered the desired impacts at minimum costs. The evaluation will further assess, if there is still a need for granting travel agents and tour operators special VAT rules. In this context, developments in the regulatory framework, like the introduction of the “One Stop Shop” in 2021 (a solution enabling all businesses that deal with final consumers to avoid multiple registrations and declarations) and the shift to destination-based taxation (in the current VAT Directive and in a definitive VAT system) will be important aspects to consider.

For more information and links to the consultation, click here.


This section contains information about how and when some attractions are planning to open. Despite some countries allowing museums to open now or in the near future, it is our understanding that many have not yet opened or are not planning to yet due to difficulties around health & safety regulations as well as challenges around financially viability. You can find an overview from NEMO (Network of European Museum Organisations) of when attractions are allowed to open here.

If you believe we are missing information on a specific topic or destination, or would like to bring something to our attention, please contact


Paris – Eiffel Tower: the Eiffel Tower is not yet open, but our understanding is that they are hoping to open somewhere between 15th June and 15th July. The maximum capacity of the Tower (10,000 before COVID) will be reassessed considering the social distancing. Mask will be compulsory for a visit. Our understanding is that they plan to open in phases (dates of phases TBC):

  • First phase: Stairs only; one to go up and one to go down, and only to 1st and 2nd floor. Tickets will be on sale at the door only.
  • Second phase: The lift to 1st and 2nd floor will open. Sales to professionals will open by then to groups of maximum 10 people.
  • Third phase: Lift to the top floor will open last, as social distancing will be difficult to keep up with.


Florence – Uffizi and Accademia: Operators’ large deposit sums are still being held by Opera Laboratori Fiorentini, who manages the reservations. We have tried to contact them without any luck. Our understanding is that the museums remain closed until further notice. Accademia is undergoing preservation work until 29th May.

Rome – Colosseum: Our understanding is that the Colosseum may reopen for visitors from 3rd June, but it is unlikely that groups will be permitted. The voucher scheme has not yet been extended to bookings beyond 17th May, but we expect that it will, at least until the opening day. We are following the situation closely as group bookings will have been made up until end of June.

Rome – Vatican museum: Vatican museum has announced how the opening of the museum will be managed. Some of the new regulations are:

  • One-meter distance required between visitors
  • Face masks mandatory
  • Temperature checks at door
  • Only online and timed tickets available (no tickets at door) – tickets here
  • Online res. fee is free for now (normally €4)
  • 15-minute intervals for entrance Maximum 10 pax + guide in a group
  • Group bookings only possible through online ticket portal Headsets/whispers for groups are banned, regular audio guides are not


The majority of the country is now into phase 1 of the easing of lock-down restrictions, meaning some attractions may open with up to 30% capacity. Despite this, many attractions have decided not to open. Sagrada Familia will open later in the summer, possibly in September 2020.

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