The Issuer should be the name of the business interfacing with the consumer. This is regardless of who generates the ATOL Certificate and provides it to the consumer. For example, if a consumer books a licensable package with an agent, but the ATOL Certificate is generated by the ATOL holder and e-mailed directly to the consumer, the Issuer box should still state the name of the agent.
If an ATOL holder has given an agent authority to act on its behalf for a flight-inclusive package or Flight-Only (i.e. provided an agency agreement) it is the agent’s responsibility under the ATOL Regulations to ensure that the ATOL Certificate is provided to the consumer at the point of accepting payment. This can be achieved in several ways, for example:
i. The agent issues the ATOL Certificate immediately, which the agent has generated from its own system.
ii. The ATOL holder gives the agent the facility to provide the consumer the ATOL Certificate directly from its (the ATOL holder’s) system immediately any payment is accepted by the agent.
The method should be agreed between ATOL holders and their appointed agents but if the ATOL holder does not have the facility to enable agents to have immediate access to an ATOL Certificate generated by the principal ATOL holder, the default position is that the agent must issue an ATOL Certificate when accepting payment.