Europe Has a Single Market & Travel Protection Still Has Borders

The Robinson Tours case shows what happens when a borderless booking enters a national enforcement maze

Europe has become exceptionally good at making travel feel borderless. A Hungarian traveller can discover a holiday online, book it from a company registered in another EU Member State, pay within seconds and cross several countries without once having to ask which national legal system sits behind the transaction. The commercial experience is European from beginning to end — right up until something goes wrong. That is when the borders suddenly return.

The organiser may be established in one country, the traveller may live in another, the holiday may take place in a third and the insolvency protection may be administered somewhere else again. Consumer supervision, claims, financial guarantees, civil remedies and possible criminal proceedings can each follow their own national institutional logic. The booking was European. The problem becomes national.

The Robinson Tours case does not prove that this architecture is fundamentally dysfunctional, nor should one company’s collapse be used to characterise an entire country’s consumer-protection system. It does, however, provide an unusually clear case study of what happens when a simple cross-border travel purchase starts moving backwards through the machinery that was supposed to protect it.

Europe made the sale borderless, but it did not make failure borderless

For the traveller, a package holiday is one product. There is one decision, one booking, one payment and one expectation: the holiday that was purchased will take place, or a clearly understandable protection mechanism will step in if it does not.

Behind that simple transaction, however, sits an institutional architecture that most customers never see and should never need to understand. The organiser, travel-service providers, insurers or guarantee mechanisms, consumer authorities, regulators and — when matters escalate — courts or prosecutors may all become part of the same story. The consumer only discovers that architecture when the system stops working normally.

This is precisely what made the Robinson Tours case interesting beyond the immediate fate of the affected travellers. As we documented in our earlier Hungarian-language investigation, “Robinson Tours: mikor fogyott el valójában a pénz?”, the questions quickly moved beyond the cancellation of individual holidays towards the financial and operational circumstances surrounding the company’s collapse. Read the original Hungarian investigation: Robinson Tours – mikor fogyott el valójában a pénz?

Once that happens, travellers can suddenly be expected to understand questions that belong on an institutional flowchart rather than in a holiday booking. Who legally sold the package? Which authority supervised the organiser? Where was the insolvency protection located? Which institution should receive the claim? Which authority coordinates the case when consumers and the organiser are based in different Member States?

A consumer-protection system that requires the consumer to reconstruct the system before being able to use it has already transferred part of its own complexity to the traveller. That is a far more important issue than the administrative inconvenience of filling in one additional form.

Robinson Tours became a stress test for a much larger European question

Robinson Tours was a Bulgarian-registered tour operator serving, among others, Hungarian customers. When its difficulties became public, the immediate questions concerned cancelled holidays, money already paid by travellers and the prospects of compensation. But the further we followed the case, the more it became apparent that several different institutional layers were involved.

Our reporting documented communication with Bulgarian authorities, questions surrounding insurance and financial protection, and the routes available to affected Hungarian passengers. In another Hungarian-language report, “Robinson Tours: így nyújthatják be kárigényüket a magyar utasok”, we followed the practical question that matters most to consumers after a collapse: where and how can they actually make a claim? The responses showed that Bulgarian tourism, consumer-protection, financial and law-enforcement institutions had become involved at different stages of the case. Szálloda

The case subsequently moved another step. On 18 September 2026, the Sofia City Prosecutor’s Office transferred the relevant file to the Sofia District Prosecutor’s Office for substantive assessment. We published the development, together with the underlying prosecutorial document, in “Már a bolgár ügyészi szervek előtt a Robinson Tours ügye.” Read the Hungarian report and the prosecutorial documents

That procedural development requires precision. The transfer does not establish guilt, criminal responsibility or wrongdoing by any person or company. It means that the information submitted entered the formal prosecutorial system and was transferred to the authority considered competent to assess it further. Szálloda

This distinction matters because the purpose of examining the case is not to manufacture a verdict. The more useful question is structural: what does an ordinary European consumer experience when a transaction that was simple, digital and international at the moment of purchase suddenly has to be untangled through several national institutions?

The rights are European - The route to using them can still be very national

The European Union does not lack package-travel legislation. Directive (EU) 2015/2302 modernised the legal framework precisely because the old model of buying a standard holiday package from a local travel agency no longer reflected the way Europeans were booking travel. It broadened the concept of a package, strengthened traveller rights and created a common framework for organiser obligations, liability and insolvency protection.

The EU has now concluded that even this framework needs further repair. Directive (EU) 2026/1024, adopted in April 2026, amends the existing package-travel rules with the explicit objective of making traveller protection more effective while simplifying and clarifying parts of the system. The legislation addresses shortcomings exposed by practical experience, including the pandemic, and introduces clearer rules around matters such as refunds, vouchers, complaints and insolvency protection. EUR-Lex

The direction is important because it demonstrates that Brussels itself recognises the difference between having a legal right and being able to use that right effectively. The European Commission describes the reform as strengthening traveller rights while improving legal certainty for the travel industry; among other changes, it provides for clearer treatment of refunds and insolvency situations. European Commission: stronger rights for package travellers

Yet harmonised rights and harmonised consumer experience are not the same thing. Europe can establish common minimum standards while the institutions responsible for supervision, insolvency protection, enforcement and redress remain national. The legal architecture may therefore be European while the practical journey through it still depends heavily on where the organiser is established. That is where the Single Market becomes less single than it first appears.

The traveller should not become the case manager

There is a useful way to test any consumer-protection system: imagine applying the same logic to another mature cross-border service.

If a European bank card worked seamlessly in every Member State, but after a failed transaction the customer first had to determine which national clearing institution had jurisdiction, we would describe the system as badly designed. If a parcel crossed four borders without difficulty but, once lost, the recipient had to coordinate several national postal regulators personally, we would not praise the sophistication of the regulatory architecture.

Travel should be judged by the same standard.

The organiser may legitimately be supervised in its home Member State. Insolvency protection may legitimately operate under that country’s legal framework. Other authorities may also have clearly defined roles. None of this is inherently problematic.

What becomes problematic is when the consumer has to discover and coordinate those institutional relationships after already losing a holiday and potentially a substantial amount of money.

A sophisticated system does not eliminate complexity. It manages complexity so the customer does not have to. That is the distinction Europe still needs to address.

Five questions the traveller should not have to investigate

A genuinely mature cross-border protection system should make the critical path immediately understandable when a package organiser fails:

1. Who is legally responsible? The consumer should be able to identify the responsible organiser without reconstructing company structures, intermediary relationships or contractual chains.

2. Where is the financial protection? Insolvency protection should be clearly identifiable before purchase and straightforward to access afterwards. It should not become visible only after the holiday has disappeared.

3. Where is the claim filed? A traveller should not have to write to several national authorities simply to discover which institution is competent to receive the claim.

4. Who coordinates the cross-border case? Institutional cooperation should happen between institutions. The traveller should not become the courier carrying information from one national system to another.

5. When can the traveller expect an outcome? Protection without a comprehensible process and a reasonably predictable timetable provides much less reassurance than the word “protection” suggests.

None of these expectations is radical. In fact, they are entirely consistent with the basic logic of the Single Market: complexity may exist behind the system, but the user experience should become simpler rather than more fragmented as integration progresses.

Brussels has recognised the weakness: the real test comes after the directive

The amended Package Travel Directive is therefore more than a technical update. It is also an acknowledgement that some of the mechanisms created for a previous generation of European travel did not always perform as clearly or effectively as consumers and businesses needed them to.

The new framework strengthens several protections and simplifies parts of the regulatory model. According to the European Commission, the updated rules include clearer arrangements for cancellations, refunds and insolvency protection, while Member States have been given a transition period to incorporate them into national law. European Commission

But the success of the reform should not ultimately be measured by the quality of the transposition tables published by twenty-seven Member States. It should be measured on the worst day of someone’s holiday.

Can a traveller immediately see who is responsible? Is the insolvency protection identifiable? Is there one intelligible route into the claims process? Do the institutions involved exchange information efficiently? Does the consumer receive an answer within a reasonable period?

Consumer protection is not the existence of a regulation. It is the experience of being protected.

The Single Market works brilliantly until the customer has to see the machinery

One of Europe’s greatest achievements is that consumers increasingly do not need to think about borders when purchasing ordinary services. Airlines connect cities across the continent, international hotel groups distribute rooms from central platforms, payment systems operate almost invisibly and online travel businesses sell products to customers thousands of kilometres away.

When the Single Market works well, the consumer barely notices that it is working.

Cross-border travel protection should aspire to the same standard. That does not require the creation of a single giant European authority responsible for every failed package holiday. National regulators, courts, insurers, guarantee funds and enforcement bodies will continue to be necessary, and different legal systems will continue to exist.

The question is where that complexity is allowed to sit. If ten institutions are required behind the scenes, ten institutions can work behind the scenes. The traveller should still see a coherent path in front of them. Good systems absorb complexity. Poor systems export it to the customer.

The Robinson case also shows what worked (and also what didn't)

There is another aspect of this story that deserves to be recorded because criticism is only credible when functioning institutions are recognised as well.

During our investigation, the Bulgarian state institutions contacted by szalloda.blog have so far generally responded, explained their competence, forwarded questions where necessary and communicated the procedural steps taken. In our report on the prosecutorial development, we specifically documented this experience and noted that the Sofia City Prosecutor’s Office registered the information, assessed competence, transferred the case and formally informed us of what had happened. Szálloda

That does not answer every question surrounding Robinson Tours, and it does not resolve the losses experienced by affected travellers. It does, however, make an important distinction possible: the structural problem identified here is not an accusation that Bulgarian institutions refused to act.

Quite the opposite. Their responses help reveal just how many competent institutions can become involved once a cross-border travel transaction collapses.

That is exactly why this is a useful European case study.

Robinson Tours is not the problem: it reveals the problem

It would be easy — and intellectually lazy — to turn the Robinson Tours story into an indictment of Bulgaria, a tour operator or an individual manager before the relevant processes have reached their conclusions. That is not what the evidence allows us to do, and it is not the most interesting conclusion anyway. The stronger conclusion lies in the contrast.

The marketing crossed borders effortlessly. The booking crossed borders. The payment crossed borders. The traveller crossed borders. Even the tourism product itself was designed around the assumption that European consumers should be able to purchase internationally without thinking about jurisdiction.

The moment protection became necessary, jurisdiction became one of the central questions.

That is not uniquely Bulgarian. It is a European design problem. And precisely because the European Union has already built an extraordinarily sophisticated market for cross-border travel, the remaining weakness is becoming more conspicuous rather than less.

Europe now has to make protection as modern as the travel market

The next generation of European travel regulation should therefore be judged less by the elegance of its legal architecture and more by the consumer experience that architecture produces.

Travellers do not need to know which directive applies to their holiday. They do not need to understand which ministry supervises which regulator or which national law transposed which article of an EU directive. They certainly should not have to learn those things after losing a holiday and possibly several thousand euros.

What they need is far simpler: a clearly identifiable responsible party, visible financial protection, one understandable route into the claims process, institutions capable of communicating with each other and an outcome within a reasonable period.

Europe has already proved that it can make purchasing travel across borders almost effortless. The harder task is ensuring that those same borders do not suddenly reappear when the purchase fails.

If travel can be sold seamlessly across European borders, protection should not become fragmented precisely when the traveller needs it most.

That is more than a question of package-travel regulation. It is a credibility test for the Single Market itself.

Further reading from szalloda.blog

Our original Hungarian-language investigation examined the financial and operational questions behind the collapse: Robinson Tours: mikor fogyott el valójában a pénz?

We subsequently followed the practical claims process available to Hungarian travellers and the involvement of Bulgarian institutions: Robinson Tours: így nyújthatják be kárigényüket a magyar utasok

Our latest Hungarian report contains the development concerning the Bulgarian prosecution service and the underlying prosecutorial documents: Már a bolgár ügyészi szervek előtt a Robinson Tours ügye

For the European regulatory framework, see the European Commission’s Package Travel information and the official text of Directive (EU) 2026/1024 on EUR-Lex.

Editorial note: The transfer of the Robinson Tours file between Bulgarian prosecutorial authorities is a procedural development and does not establish criminal liability, wrongdoing or guilt. Robinson Tours is examined here as a case study in cross-border consumer protection; it is not used as a basis for assessing the Bulgarian regulatory system as a whole.

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