Tripdash Team
July 6, 2026
Who refunds a cancelled trip, agency or supplier? Refund flows by booking type, commission recalls, EU, UK and state rules, a worked example and a policy template.

A travel agency refund policy says what a traveler gets back, from whom and how fast when a trip is cancelled. The refund usually comes from whoever charged the card, the merchant of record. Supplier terms set how much comes back. Your policy should match those terms, say whether your own fee is refundable, and be accepted before the traveler pays.
The supplier sets the penalty. You set the promise. Here is how refunds flow by booking type, what happens to your fee and commission, what EU, UK and state law add, and a workflow, worked example and template to adapt.
It is the part of your client terms that covers cancellations and money back. It answers three questions: what is refundable, who pays it, and when.
It matters for disputes. Under Visa's rules, cancellation terms must be disclosed before purchase to be relied upon. A policy the traveler never saw doesn't protect you. See travel agency chargebacks for the full dispute process.
This is general information, not legal advice.
Whoever is the merchant of record, the business that charged the traveler's card. For air, US Department of Transportation (DOT) rules define it as the business processing the payment, as shown on the consumer's card statement. Visa says a travel agency is often the merchant of record.
Two common setups:
For more on who charges the card, see how travel agencies collect payments.
Watch the gap between the two. Carnival's ticket contract says any refund made by Carnival to an agent on behalf of Guest shall be deemed payment to Guest, whether or not the agent passes it on. Once a supplier pays you, the traveler's refund is your job.
Each supplier type follows different rules. These examples come from the suppliers' own published terms, as checked in October 2026.
| Booking type | Who usually refunds | What sets the amount | Example from published terms |
|---|---|---|---|
| Air | The merchant of record | DOT refund rule, then fare rules | Full refund for a cancelled or significantly changed flight if the traveler declines the alternative |
| Hotel | The hotel, or you if you charged the card | The rate's cancellation rules | Hilton Advance Purchase: no refunds or credits for changes, cancellation or no-show |
| Cruise | The cruise line, via the agent | Days before sailing | Carnival 6+ day cruises: deposit lost from 90 to 56 days, 100% inside 14 days |
| Tour | The tour operator | Days before departure | Intrepid: 30% from 31 to 55 days, 60% from 15 to 30, 100% at 14 or fewer |
| Package | Each supplier for its part, unless you sold one price | Each component's terms | Your policy decides how you pass them through |
A traveler is owed a full refund when a flight is cancelled or significantly changed and they decline the alternative. A significant change includes leaving 3 or more hours earlier, or arriving 3 or more hours later, on a domestic trip (6 hours internationally), a different airport, more connections, or a downgrade.
If you are the merchant of record, the refund is yours to make. A ticket agent must refund within 7 business days of hearing from the airline for credit card purchases. For cash, check, debit card and other payments, the limit is 20 calendar days from when the refund becomes due. It goes back in the original form of payment. The airline must tell you without delay whether the traveler qualifies, and transfer the funds if it holds them.
You can offer a travel credit instead, but you must first inform consumers that they are entitled to a refund. That credit must stay valid for at least 5 years. More on air in how to sell flights without an IATA code.
A prepaid rate is usually final. Accor grants no refund on a prepaid reservation. A flexible rate is free to cancel until the hotel's cutoff. After that, a no-show on a cancellable Accor booking costs the first night, including tax. See free cancellation and auto-cancel for deadlines.
Penalties grow as departure nears, usually from the final payment date. Carnival refunds prepaid government taxes and fees after deducting any cancellation charges. Globus charges 50% of the total price from the final payment date to 30 days out, 80% from 29 to 1 days, and 100% on the day of departure. Its deposits are always non-refundable. Full schedules are in deposit and final payment schedules.
When the supplier cancels, the remedy varies. If Globus cancels for reasons other than force majeure and you decline its rebooking offer, it refunds the amounts paid by you for the reservation. After a force majeure cancellation it may offer a future travel credit instead. Carnival's clause covers voyages it cancels or shortens at embarkation or during the cruise. For any reason other than a mechanical failure, the traveler gets a Future Cruise Credit or an Onboard Credit, not cash. Read the clause before you promise cash.
When you sell several components at one price, each supplier still refunds under its own terms. What this means for agencies: your policy should say the traveler gets back what the suppliers refund, minus any fee you disclosed. Don't promise a full refund the suppliers won't fund.
If you sell packages to travelers in the EU or UK, the law adds refund rights on top of your terms. The EU Package Travel Directive puts these duties on the organiser, the trader that combines and sells or offers for sale packages. A retailer only sells packages an organiser put together.
The UK's Package Travel and Linked Travel Arrangements Regulations 2018 copy these rules in regulations 12, 13 and 14, including the 14-day deadline.
What this means for agencies: "we refund what suppliers refund to us" doesn't work when you organise an EU or UK package. The 14-day clock runs from termination, not from the day a supplier pays you.
For air, DOT decides. A ticket agent may keep its service fee only to the extent that service is for more than processing payment for a flight that the consumer found. The fee must be per passenger, and its existence, amount, and the non-refundable nature if that is the case must be clearly and prominently disclosed when the traveler buys the ticket.
For lodging, the Federal Trade Commission (FTC) bars misrepresenting the nature, purpose, amount, or refundability of any fee. Outside those two, your written terms decide. Set fees up in travel agent service fees.
Usually, on the part that gets refunded. Each supplier's agent terms decide the details.
Air. Delta says that per industry standard, when a travel agency ticket is refunded, the related commission amount is recalled. On a partial refund it recalculates the commission and collects the refunded share by debit memo. It doesn't recall commission after an involuntary reroute to another carrier or ground transport, or after a cancellation for maintenance.
Hotels. Hilton calculates commission based on the hotels' daily checkout records, so a cancelled stay earns none. Its settlement files include non-commissionable records, no-shows and cancellations. Reconcile them against your booking files.
Cruises and tours. Lines set their own rules. Riviera River Cruises changed its policy in September 2024. Travel Market Report quoted it saying advisors will no longer lose their commission when a client cancels in the days before their cruise starts. Clients cancelling within 15 days still lost 100% of the booking cost. Check each line's terms before you count on commission from a cancellation penalty.
What this means for agencies: hold advisor splits until travel is complete, or say in your advisor agreement how you recover a split on a recalled commission. More in commission split models and unpaid commission recovery.
California and Washington set their own refund deadlines. This is a summary, not legal advice.
| State | Refund deadline | When your cancellation terms count | Source |
|---|---|---|---|
| California | The earlier of 30 days from departure, the refund request or your cancellation, or 3 days from when you first can't provide the travel | A refund under cancellation terms the traveler saw and agreed to counts as compliance | Bus. & Prof. Code § 17550.14 |
| Washington | 30 days after the vendor refunds you, or 14 days if you never sent the money to the vendor | You don't owe back vendor penalties you disclosed in the required written statement | RCW 19.138.050 |
California. Before you take payment, you must give the traveler, in writing, all terms and conditions of the travel, including cancellation conditions (§ 17550.13(a)(1)(D)). You must also state that if they're not at fault, sums paid for services not provided will be promptly paid to the passenger. Any day the traveler's money isn't in the required trust account counts as a day you are unable to provide the travel, which starts the 3-day clock.
Washington. When you charged the traveler's card and paid a vendor, card refunds must be applied for within ten days from the date of cancellation. Your written statement at payment must include a penalty advisory: either the amounts, or Cancellation and change penalties apply to these arrangements. Details will be provided upon request.
Trust account rules decide where refund money sits until then: see travel agency trust accounts.
Two clocks run: yours and the bank's.
| Step | Typical timing | Source |
|---|---|---|
| Airline refund, credit card, agency is merchant of record | 7 business days after the airline's notice | 14 CFR 399.80(l) |
| Airline refund, cash, check, debit or other | 20 calendar days | 14 CFR 399.80(l) |
| Card refund you agree to give, any booking type | You send the credit to the card issuer within 7 business days; the issuer posts it within 3 business days | Reg Z, 12 CFR 1026.12(e) |
| Card refund reaching the traveler on Stripe | About 5–10 business days | Stripe |
Reg Z only starts its clock once you accept a return or forgive a debt for services. It does not require refunds for returns in the first place: your terms and the supplier's decide that.
A refund is not free. On Stripe, a refund might incur a fee, and the original processing fees aren't returned. Cancelling an uncaptured payment costs nothing. That is the case for holding before you charge: see authorization holds.
Then the bank decides, not your policy. Under Regulation Z, a billing error includes services not delivered "as agreed", and the cardholder must notify the card issuer within 60 days of the first statement showing it.
Slow refunds push travelers to call their bank. Once a chargeback is filed, don't refund separately. ARC warns it could credit the traveler twice.
Practical guidance, built on the rules above.
Illustrative numbers. The penalty tier is Intrepid's published one; the price and fee are made up.
A traveler books an Intrepid tour through you for $4,000. They also pay your planning fee of $200, disclosed as non-refundable. Total paid: $4,200. They cancel 40 days before departure, when Intrepid charges 30% from 31 to 55 days.
| Line | Amount |
|---|---|
| Tour price paid | $4,000 |
| Intrepid cancellation charge (30%) | −$1,200 |
| Refund on the tour | $2,800 |
| Planning fee (non-refundable, disclosed) | $0 back |
| Refund to the traveler | $2,800 |
Two costs land on you. If you charged the card, the original processing fees aren't returned when you refund. And commission tied to the refunded $2,800 may be recalled, as under Delta's rule above. Whether the operator pays commission on the $1,200 it keeps depends on its agent terms.
Had the traveler cancelled 10 days out, the charge would be 100% and the tour refund $0. If Intrepid charged the card itself, it refunds the $2,800 directly, and you keep the $200 you charged separately.
Template: adapt with counsel. This sample is original Tripdash text, not a legal form. Edit the brackets, match your supplier contracts and state rules, and have a lawyer review it.
Tripdash Pay supports authorization holds, ACH, SEPA instant, SWIFT and local-account netting. Payment tracing follows each payment to the exact supplier that received the funds, so you know where a refund has to come from. See how Tripdash Pay works.

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