Usually, the AI agent does not owe you the refund. The responsible party is determined by the booking contract, the service you bought, who accepted your payment, the reason for cancellation, and the law that applies. That may be an airline, hotel, package organiser, travel agent or online booking platform. An AI system can place the reservation, but its involvement does not create a universal refund rule or automatically make its developer the payer.
Start with the confirmation and payment record. Identify the contracting supplier, any intermediary, the merchant of record, the cancellation terms and whether the reservation is a package or a standalone service. The answer differs sharply between a US airline ticket, an EU package holiday and an individually booked hotel.
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What to check before contacting anyone
Do not begin by asking the AI assistant what it thinks the policy is. Treat the booking record as the authoritative starting point, because an agent may have searched several providers, selected a rate with restrictive terms or completed payment through a different company.
- Download the original confirmation. Save the itinerary, receipt, fare or room type, cancellation deadline, refund wording and the terms shown immediately before payment.
- Inspect the card or bank statement. The legal or commercial entity that charged you may differ from the airline, hotel or website displaying the itinerary.
- Separate the products. List airfare, seats, bags, priority boarding, hotel nights, transfers and insurance separately. Different companies can be responsible for different charges.
- Classify the booking. Decide whether it is an airline ticket, an individual hotel or car-rental reservation, or a package combining two or more travel services.
- Record why the trip ended. A traveler-requested cancellation, an airline cancellation, a significant schedule change and a supplier failure can trigger different remedies.
Keep screenshots if the platform and the supplier display conflicting policies. The version shown when you paid can be important evidence, especially when a booking agent has presented a summary that does not match the supplier’s full terms.
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Which party normally handles the money?
The following map is a practical starting point, not a substitute for the contract or the law of the country involved.
| Booking situation | First party to identify | Why that party matters |
|---|---|---|
| US flight cancelled or significantly changed by the airline | Airline and the ticket seller that took payment | For covered airfare refunds, a ticket agent that is the merchant of record must make the proper refund when due. The airline handles certain optional-service and baggage-fee refunds. |
| EU package holiday | Package organiser | The organiser is responsible for proper performance of the travel services and for refunds required by the package-travel rules. A retailer can also have responsibility under applicable national law. |
| Individual hotel or car rental for specified dates | The provider named in the contract and the platform or agent that sold it | Cancellation rights generally depend on the rate terms, the contract and national law rather than a universal online-shopping cooling-off period. |
| Intermediary-issued airline ticket in the EU | Airline and intermediary together | A Court of Justice of the European Union ruling addresses when an unavoidable intermediary commission must be included in the passenger’s reimbursement. |
The merchant of record is especially important for a US airfare claim. The US Department of Transportation defines it as the entity shown on the debit- or credit-card statement for the ticket purchase. A travel platform can therefore be the refund contact even when the flight is operated by an airline.
US airline bookings: airfare, add-ons and deadlines
When a ticket agent must refund the airfare
Under the US Department of Transportation’s refund guidance, when an airline cancels or significantly changes a covered flight to, from or within the United States, a traveler who rejects the offered alternative transportation can be entitled to a ticket-price refund. If a ticket agent, including an online travel agency, is the merchant of record, that agent must issue the proper airfare refund when due.
The airline’s identity on the aircraft or itinerary does not by itself answer who sends the money. Check the statement line for the ticket transaction. If it names the agent, direct the airfare request to that merchant of record and copy the airline if necessary.
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Ancillary charges can follow a different route
Do not combine the ticket price with every amount on the receipt. DOT says ticket agents are not responsible for refunding certain optional service fees or baggage fees and directs travelers to request those refunds from the airline. Seat assignments, checked bags and other extras can therefore require a separate request even when the agent refunds the base fare.
What happens after an alternative flight is offered
When the airline offers alternative transportation after a cancellation or significant delay or change, DOT says it must tell consumers that they are entitled to a refund if they reject the alternative. Read that notice before accepting a replacement, because accepting transportation can affect the right to reject it and claim a ticket-price refund.
For the situations described in DOT’s guidance, the regulatory payment deadlines are seven business days for a credit-card payment and 20 calendar days for other forms of payment. These are legal time limits for the specified US aviation cases, not average processing times and not deadlines that automatically apply to hotels, non-US flights or every kind of cancellation.
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Why the organiser is central
A package combines at least the travel services covered by the package rules, such as transport and accommodation purchased together under the relevant arrangements. The organiser identified in the contract is responsible for the proper performance of the included services. EU consumer material also states that the organiser is responsible for required refunds, while a retailer may be liable where the applicable national law says so.
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Look for the organiser’s legal name and contact details in the confirmation or pre-contract information. The company that answered your booking request may be only the retailer; the organiser is the party whose package obligations usually control the remedy.
Refund timing and the 2026 transition
The package-travel framework provides for refunds within 14 days in specified cancellation situations. Do not turn that into a general 14-day cancellation right for every trip: the trigger, the party cancelling and the applicable national implementation all matter.
The European Commission reported on 28 May 2026 that Directive (EU) 2026/1024 gives Member States 28 months to transpose the amendments and that the amended rules become binding on operators six months later. As a result, the amendment is not proof that every new duty already applies uniformly across the EU. For a country-specific claim, check that country’s transposition and the date applicable to your contract.
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EU hotels and other date-specific bookings
No automatic 14-day cooling-off period
EU consumer guidance lists flights, trains, hotel bookings and car rentals for specific dates among the exceptions to the general 14-day withdrawal right for distance contracts. An AI making the reservation online does not remove that exception or create a new right to cancel for any reason.
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Read the rate and the governing law
For individually booked accommodation, the European Commission’s accommodation guidance says rights depend on national contract law and the booking terms, including whether the rate is refundable and the provider’s stated cancellation policy. A non-refundable rate may permit no repayment for a voluntary cancellation, while a flexible rate may provide a deadline and fee schedule.
That guidance was published in the context of COVID-era disruption. It is useful for distinguishing individual accommodation from package travel and for explaining the role of contract and national law; it is not a blanket ruling about a current health emergency.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.When an intermediary fee is part of an EU flight refund
In Case C-45/24, addressed in a Court of Justice of the European Union press release dated 15 January 2026, a cancelled flight had been booked through an intermediary. The Court said that when an airline accepts an intermediary issuing tickets in its name and on its behalf, the airline may be assumed to know that intermediary’s practice of charging a commission. The unavoidable commission had to be reimbursed even though the airline did not know its exact amount.
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This holding concerns the case’s EU air-passenger-law context. It is not a blanket rule that every travel-agent fee must be refunded in every country or for every service. Preserve the agent’s invoice and identify whether the fee was unavoidable for obtaining the ticket.
What AI changes—and what it does not
An AI agent may search, select, reserve and pay, but those actions do not rewrite the supplier’s contract. The confirmation normally identifies the company selling the service, the provider performing it and the terms accepted at checkout. Those documents, rather than the conversational interface, determine the ordinary refund route.
There is a separate issue for businesses that deploy booking or customer-service agents. The UK Competition and Markets Authority’s Complying with consumer law when using AI agents guidance, published 9 March 2026, tells businesses to ensure agents respect statutory rights and contract terms, obtain required consent and are monitored. It states: “Ultimately, you will be responsible if an AI agent does something illegal.” That is a UK business-compliance warning. It does not make an AI provider the refund payer for a traveler’s airline, hotel or package claim in another jurisdiction.
A contact sequence that prevents dead ends
- Send the claim to the party controlling the relevant charge. For US airfare, start with the merchant of record; for an EU package, start with the organiser; for a hotel, use the provider or platform named in the booking terms.
- Describe the legal trigger precisely. State whether the supplier cancelled, made a significant change, offered an unacceptable replacement, or whether you are requesting a voluntary cancellation under the rate policy.
- Itemise the amount. Ask separately for the ticket price, bags, seats, hotel amount, taxes and any intermediary fee. This avoids a platform treating an ancillary charge as part of the airfare refund.
- Attach evidence. Include the confirmation, terms shown at purchase, payment statement, cancellation notice and any replacement itinerary. Keep the original files and a dated copy of your request.
- Preserve the decision window. If an airline offers alternative transportation, note the deadline and whether you accepted or rejected it before demanding a refund.
- Escalate with the same record. If the first contact says another company is responsible, request a written explanation and forward the complete evidence to that company. Do not rely on an AI chat transcript as the only proof.
Common mistakes and how to avoid them
- Blaming the AI instead of identifying the seller. The agent’s brand or app name may not appear on the payment statement or contract.
- Assuming the airline refunds every line item. Base airfare and baggage or seat fees can have different refund contacts.
- Calling every multi-service booking a package. A flight and hotel bought separately may not receive package-law protection; check how the transaction was arranged and what the contract identifies.
- Using the EU 14-day rule for a date-specific hotel or flight. Those services are listed exceptions to the general withdrawal right.
- Applying a new EU amendment before it takes effect nationally. Verify transposition and the applicable date before relying on Directive (EU) 2026/1024.
- Relying on a verbal promise. Obtain the refund decision, amount and expected payment date in writing.
The practical answer in one sentence
Follow the money and the contract: the airline or its merchant-of-record agent handles a qualifying US airfare refund, the package organiser generally handles an EU package refund, and a standalone hotel or date-specific booking follows its stated terms and national law—not the fact that an AI agent made the reservation.
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