220 LEGAL IMPACTS OF COVID-19 IN THE TOURISM INDUSTRY about by Legal Notice No. 80 of 2020, entitled “Package Travel and Linked Travel Arrangements (Amendment) Regulations”, wherein a provision was added to Regulation 11(4). Therefore, the 14-day deadline set out, within which the organiser has to refund the traveller, shall not apply to any refund required as a result of the termination of package travels, when such termination occurs between the 1 March 2020 and 31 May 2020 Consequently, the refund shall be paid by the organiser to the traveller by no later than 6 months after the package travel contract is terminated. Although the extension of the period from 14 days to 6 months was a step in the right direction to assist organisers in the COVID-19 situation, it is questionable as to why the legislator did not provide for the voucher structure. This would have been the ideal solution for the traveller, who would be able to travel when the situation would be better, as well as for the organiser, who would not have to pay the traveller. As a result, it could lead to a situation in which the organiser has to refund to the traveller from his own pocket, should the third parties to whom the amounts would have already been paid to (such as hotels and airlines), refuse to refund the amounts to the organiser. This is more so since the Directive does not regulate business to business relationships, and thus, it does not impose the same obligation on such third parties to refund the organiser. Moreover, the amended Maltese legislation provides for the termination of the packages occurring between the beginning of March and end of May 2020. Should the situation continue, it is noteworthy that this timeframe would have to be extended. 4. WHAT OTHER AMENDMENTS COULD HAVE BEEN CARRIED OUT IN MALTESE LAW TO ASSIST THE ORGANISER? The author regards that, although resorting to increasing the timeframe within which the refund has to be paid is a step in the right direction, other measures could be adopted to further assist organisers. As mentioned above, the voucher system, which replaces the obligation of the refund, contemplated in many EU Member States, provides for a situation in which the traveller would have a voucher that can be utilised for another package, in a specific timeframe. Moreover, in this scenario, the organiser would be in a position to use the payments made to third parties for a future package. The system of the vouchers would be ideal for many reasons. Primarily, the organiser is not refunding amounts which s/he might not have; secondly, the
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