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ATIA Submissions


ATIA sets and maintains Australian travel agent, tour operator, wholesaler and consolidation business standards. We represent the travel industry when addressing policy issues to state and federal governments and stakeholders, which covers aviation, consumer matters, competition, market settings and general visitor economny policy.

 ATIA makes submissions to Government on these major issues which directly and indirectly impact our members, the Australian travel industry and thier customers. Our submissions aim to support the lowering of the barriers and stimulate more Australians to travel domestically and internationally.

Note that prior to 15 August 2023, submission were made under the ATIA's former name of the Australian Federation of Travel Agents (AFTA).

May 2024: Migration Core Skills Occupations List

ATIA’s submission to Jobs and Skills Australia in relation to occupations that will be eligible for skilled migration under the Core Skills Occupations List (CSOL). In our submission, ATIA makes the case that the occupations travel consultant, travel agency manager and tour guide should be on the CSOL.

View the submission

May 2024: Strategic Review of the Australian Apprenticeship/Traineeship Incentive System

ATIA’s submission in relation to the Strategic Review of the Australian Apprenticeship/Traineeship Incentive System. To ensure the travel industry has a pipeline of future workers with the skills the industry requires to support travelling Australians, ATIA’s submission advocates for Government policy settings to support increased enrolments and completions in travel-related VET courses, including through a commitment to long term incentives and support for employers.

View the submission


April 2024: Impact and mitigation of aircraft noise inquiry

ATIA’s submission to the Rural and Regional Affairs and Transfer References Committee in relation to its Inquiry into the impact and mitigation of aircraft noise. The submission highlights the importance of balancing concerns around aircraft noise with the social and economic benefits of Australia’s aviation industry and the flow on impact to industries such as travel and tourism as well as the businesses that support them.

View the Submission

March 2024: Skills Priority List submission

ATIA’s submission to Jobs and Skills Australia in relation to the Skills Priority List for 2024. It includes results from ATIA’s Skills & Workforce survey and makes the case that occupations supporting the travel industry continue to be in high demand. The Skills Priority List is used to inform which occupations Government focuses on in terms of funding support and projects.

View the Submission 

January 2024: Pre-Budget Submission

ATIA’s submission on priorities for the Federal Government’s 2024-25 Budget. It seeks Federal Government action across a number of key areas including business support, measures to ensure an appropriately skilled workforce for the travel industry, and measures to enhance traveller experience and increase consumer confidence and demand for travel.

View the Submission 

December 2023: COVID-19 Response Inquiry

ATIA’s submission to the Independent Inquiry into the Commonwealth Government’s COVID-19 Response for your information. The submission contains 8 recommendations covering border closures, management of the Consumer Travel Support Program and its impacts on travel businesses, as well improving the overall government response if another emergency occurs.  Our submission brings to light the significant challenges the travel industry experienced and suggests ways to enhance future support mechanisms and ensure they are more effective.

View the Submission

December 2023: Aviation Green Paper

ATIA’s submission to the Department of Transport and Infrastructure on the Aviation Green Paper (consultation paper) released by the Government. The submission contains 23 recommendations that will help inform the Government’s development of the Aviation White Paper, which will set the policy direction for the aviation sector out to 2050.

We highlighted the key role the travel distribution system plays, touching on themes such as increasing competition, improving consumer outcomes and disability access, ensuring clarity of responsibility for emissions created through travel, fit-for-purpose agencies and regulations, and ensuring the travel industry has the workforce it needs to support the travelling public.

ATIA's Slot Misuse Report 

View the Submission


December 2023: Virgin Australia and Air NZ’s codeshare request

ATIA’s submission to the ACCC in relation to Virgin Australia and Air NZ’s application for authorisation by the ACCC to codeshade on Trans-Tasman routes.

We know that air is a critical enabler of Australians’ travel plans, and ATIA is reviewing each application on its ability to increase the level of competition and make travel accessible.

View the Submission

December 2023: Fiji, Indonesia and Malaysia Air Services Arrangements

The Department of Transport and Infrastructure is exploring possible discussions with Fijian, Indonesian and Malaysian aeronautical authorities in the first half of 2024 about bilateral air service arrangements and sought ATIA’s input. We have contributed to that process, providing a submission to ensure Australia’s bilateral air services arrangements continue to serve the future needs of these markets and enable the recovery of the supply of air capacity to ensure supply is ahead of demand.

View the Submission

November 2023: Unfair Trading Practices

ATIA’s input to a consultation by Treasury, advocating for a new provision on unfair trading practices. This would likely capture some of the commercial practices that are occurring that are resulting in significant consumer and business harm, but are not captured by the existing provisions of Australia’s consumer laws.

View the Submission

September 2023: Bilateral Air Services Agreements Submission to the Select Committee

ATIA supports the continued policy of negotiating bilateral air service agreements that provide ‘capacity ahead of demand’, as current capacity constraints on routes with strong demand have resulted in higher prices for Australian consumers. The most effective option to increase capacity and allow it to adapt to demand variation over time is the negotiation of adequate capacity limits that offer significant margin for growth.  

A clear framework for the process of air service agreement application/negotiation and an unambiguous written decision outlining the weighting of factors considered is required to ensure that investments can be made to efficiently deliver benefits to the Australian economy and community. 

We make 9 recommendations:

Recommendation 1: The factors pertaining to a consideration of the national interest should be clearly defined. National interest should not be a reason in its own right. The decision and rationale cannot be withheld from the public and the approving authority must justify the reasons why they agree or disagree with the expert advice.

Recommendation 2: The ACCC must review and publicly release its assessment of the consumer benefit of each bilateral application. It is the only government agency which can assess competition settings and ultimate consumer impacts.

Recommendation 3: The travel and tourism industry, airports and airlines and other export sensitive industries as relevant, must be provided equal opportunity to review each bilateral request and make recommendations.

Recommendation 4: Australia should seek to increase the number of open skies arrangements with likeminded Indo-Pacific countries to increase competition to lower prices for Australians and international travellers who wish to visit Australia.

Recommendation 5: Globally, consumer rights have been strengthened following the performance of airlines regarding cancellations and credits during COVID. Reform is needed to simplify refund rights where a flight is cancelled and passengers are not accommodated on the same day.

Recommendation 6: A review of domestic aviation market and contracts between airlines and agents. This review will seek to identify any unfair trading practices which are not prohibited by existing provisions of Australia’s consumer laws but which can nevertheless distort competition.

Recommendation 7: ATIA maintains that authorisations of airline coordination agreements should be conditioned upon robust analysis of the benefits and detriments of the agreements.

Recommendation 8: ATIA supports a competitive market for airport slots that allows entry for increased capacity to put downward pressure on the prices of air tickets. Consideration should be given to increasing threshold for domestic slot use to 90% within 2 years and 95% within 5 years.

Recommendation 9: ATIA maintains that quarterly reporting by the ACCC is of critical importance to tracking the overall health of the domestic aviation sector. Reporting should be immediately re-established and should also include slot usage rate for airlines at all airports operating slot management systems.

View Submission

April 2023: Submission the Inquiry into Australia’s tourism and international education sectors

The Minister for Trade and Tourism, Senator the Hon Don Farrell, requested the Joint Standing Committee on Foreign Affairs, Defence and Trade (JSCFADT), through its Trade Subcommittee, to inquire into Australia’s tourism and international education sectors.

AFTA members play an important role in facilitating bookings of inbound and outbound travel, accommodation and related services, which contribute to the tourism industry in Australia. As the peak body for a broad array of Australian travel professionals, AFTA is uniquely placed to comment on the challenges and opportunities for growth in tourism. AFTA strives to promote competition across the entire tourism sector, alongside world-leading practices to ensure an efficient and positive traveller experience.

Our submission brings together AFTA’s established and long-term policy positions as well as our recent positions on the key areas of: 

  • Importance of outbound travel, 
  • Taxation (PMC),
  • Requirements for additional skills funding, 
  • Importance of ATAS, 
  • Support of Smartraveller, 
  • Passenger facilitation,
  • Airline carrier coordination, 
  • Airport slot usage,
  • Importance of business travel, 
  • Climate change.

January 2023: Qantas Group and Jetstar

AFTA has submitted to the ACCC this submission seeking clarification on a number of issues regarding ultimate outcomes for consumers.

Information about the application:

Qantas Airways Limited (Qantas), its related bodies corporate and Jetstar Airways Pty Limited (Jetstar) (together, the Applicants) seek revocation of authorisation AA1000395 and substitution for a new authorisation AA1000626 for the continuation of coordination involving Qantas and Jetstar branded low cost carriers and, in certain circumstances its full service airline shareholder, Japan Airlines Co. Limited, in the Asia-Pacific region.

January 2023: Qantas Group and China Eastern Airlines Corporation Limited

AFTA has submitted to the ACCC this submission seeking clarification on a number of issues regarding ultimate outcomes for consumers.

Information about the application:

Qantas Airways Limited (Qantas) & China Eastern Airlines Corporation Limited (China Eastern) (together, the Applicants) and their related bodies corporate seek revocation of authorisation AA1000526 and substitution for a new authorisation AA1000624 for similar conduct, administered through an Extended Joint Coordination Agreement. The Extended Joint Coordination Agreement would permit Qantas and China Eastern to continue their alliance and coordinate on operations between Australia and mainland China beyond 31 March 2023 when the current authorisation is due to expire.

January 2023: Qantas Group and Emirates

AFTA has submitted to the ACCC this submission seeking clarification on a number of issues regarding ultimate outcomes for consumers.

Information about the application:

The Applicants also seek interim authorisation on the basis that the existing authorisation will expire on 31 March 2023, such that the Applicants can continue to discuss and plan while the substantive application for re-authorisation is being assessed by the ACCC.

Under the Restated MCA, Qantas and Emirates propose to cooperate for a further period of five years across their global networks, including in relation to:

  • planning, scheduling, operating and capacity
  • sales, marketing, advertising, promotion, distribution strategies, reservation priority and pricing for passengers, freight customers and agents
  • connectivity and integration of certain routes
  • codeshare and interline arrangements
  • control of inventories and yield management functions
  • frequent flyer programs
  • all passenger-related aspects of service to customers, including ground services and lounge access
  • harmonising service and product standards in order to provide a seamless product to passengers
  • harmonising IT systems
  • joint airport facilities
  • joint offices for sales activities
  • potentially other aspects of operations including ground handling, joint procurement and flight operations
  • where appropriate and mutually agreed, making joint submissions to authorities on operational matters
  • services and activities that are required to facilitate any of the matters referred to above.

Re-authorisation is sought until at least 31 March 2028.

February 2022: Pre-Budget Submission

AFTA's 2022-2023 Pre-Budget Submission calls for a Travel Sector Skills Retention and Impaired Recover package of $190 million to support the continued recovery of the travel sector.

The Submission highlights the fact that the travel industry remains in a stage of significantly impaired recovery due to the ongoing effects of COVID-19.

August 2020: Pre-Budget Submission

AFTA's 2020-21 Pre-Budget Submission with Treasury, urgently calls for a Sector Specific Support Package of $125 million as a result of COVID-19.

The Submission highlights the fact that travel agents, tour operators and travel wholesalers are on the pandemic frontline supporting consumers while being among the worst hit of Australian businesses with 90%-plus revenue drops and little sign of real recovery without the resumption of international travel.

March 2020: AFTA’s Travel Industry Emergency Package COVID-19 Response

On Thursday 19th March AFTA lodged AFTA’s Travel Industry Emergency Package COVID-19 Response with the Coronavirus Business Liaison Unit within Federal Treasury. AFTA is working with lobbyists to brief key decision makers within Government and the Opposition including the PM, Treasurer, Finance Minister, Opposition Leader and Treasury.

The submission outlines 8 key measures which the Government must enact  to provide immediate relief to struggling businesses in desperate need of cashflow.

We are also making sure they understand the unique challenges the travel sector faces in terms of the purchase cycle, and the fact that the sector is more than just airlines.

January 2020: Commonwealth Pre-Budget Submission 2020-21

AFTA’s 2020-21 Commonwealth Pre-Budget Submission details initiatives that will support the growth of the travel and tourism sector, while also supporting the Government’s plan to bring the budget back to surplus.

The submission calls for the continuation of a freeze on the Passenger Movement Charge (PMC), along with supporting current levels of Government appropriation and support for the Department of Foreign Affairs, Consular Services and passenger facilitation.

In light of the recent devastating Australian bushfires, AFTA urges to Government to ensure the appropriation of funds from the National Bushfire Recovery Fund include ATAS accredited Australian based travel agency businesses for distribution arrangements, who are committed to advocating for the benefits of domestic tourism.

September 2019: Federal Government Calls for submissions relating to Add-On insurance reforms

The Federal Treasury released a discussion paper which calls for reform in the way Add-On insurance may be sold in Australia following recommendations made in the Hayne Report (The Banking Royal Commission).

AFTA has prepared a detailed submission which supports the travel agency community for the continued sale of travel insurance under an exemption from the reform being suggested.

The submission outlines the current market, reasons why travel agents remain well placed for this exception and the value consumers gain by being able to continue to access travel insurance from travel agents.


August 2019: Currency (Restrictions on the Use of Cash) Bill 2019

In the 2018-19 Budget, the Government announced it would introduce an economy-wide cash payment limit of $10,000 for payments made or accepted by businesses for goods and services. Transactions equal to, or in excess of this amount would need to be made using the electronic payment system or by cheque. The Black Economy Taskforce recommended this action to tackle tax evasion and other criminal activities.

The Government released for public consultation exposure draft legislation and accompanying explanatory material to implement the economy-wide cash payment limit from 1 January 2020 and for certain AUSTRAC reporting entities from 1 January 2021.

You can read the exposure draft legislation here:

March 2019: Beyond Tourism 2020

In February 2018, the Australian Government established the Beyond Tourism 2020 Steering Committee to shape Australia’s next long-term tourism strategy to commence in January 2021.

The Beyond Tourism 2020 Steering Committee submitted its report to Government in December 2018, and in February 2019 a consultation processes was launched to seek industry and governments’ views on the report.

AFTA continues to maintain a strong position on not lifting the PMC, reforming the Tourist Refund Scheme and ensuring holistic approach is undertaken to market development.