Sellers of Travel Services Registration - Division of Occupational and Professional Licensing

Maryland's House Bill 994 is set to go into effect on October 1, 2026. The new law establishes updated requirements for qualifying sellers of travel operating in Maryland, including registration and professional liability insurance provisions designed to strengthen consumer protections and enhance accountability in the travel-selling marketplace. These measures are intended to promote transparency and responsible business practices throughout the industry and increase consumer confidence.

As the law's effective date approaches, the Maryland Department of Labor is working closely with sellers of travel, independent agents, consumers, advocates, and other stakeholders to ensure broad understanding of the new requirements.

The Maryland Department of Labor is taking the following steps to support implementation:

Reviewing internal policies and procedures to align with the new statutory requirements
Providing guidance and educational resources for clients, partners, and stakeholders
Working collaboratively with state officials and industry representatives to facilitate compliance.
Monitoring implementation and communicating updates as additional guidance becomes available

We are asking members of the industry to answer the following questions to assist the Department in better understanding the day-to-day operations and trends of the travel selling industry in order to provide guidance and develop regulations related to HB 994:

In your view, what are the most critical factors defining the operational and contractual relationships between travel sellers and independent agents?
Where do you believe the distinct operational boundaries should be drawn between travel sellers and independent agents in daily practice?
What is your perspective on how both professional liability and errors & omissions insurance should ideally be structured across the industry?
In your opinion, under what specific circumstances is it most appropriate for an independent agent to rely on a travel seller's insurance coverage versus maintaining their own independent coverage?
Based on your experience, what do you believe is the most sustainable or manageable scale for an independent agent network attached to a single travel seller?
How do you view the impact of a travel seller's business size on how their independent agent network operates?
What are your thoughts on independent agents affiliating with multiple travel sellers simultaneously? Is this a common practice in the industry?
In your opinion, what is the most effective way to manage insurance coverage when an agent operates across different sellers?
How do you view the trend of agents alternating between working under a travel seller and operating entirely on their own? Is this a common practice in the industry?
From your standpoint, what is the best approach for managing insurance coverage when an agent frequently transitions between operating independently outside a seller's umbrella?
Which specific areas of HB 994 do you feel are in need of deeper guidance from the Department before the Travel Services Registration Fund is officially implemented?
What do you believe are the most significant operational realities or challenges within the Maryland travel services industry that the Department must keep in mind to ensure these regulations are practical and fair?
Please share any insights, concerns, or questions that you feel are most important to share with the Department as regulations are drafted and policy is developed.

Please send your comments to [email protected] by August 31, 2026.

The Department is also inviting stakeholders to attend a virtual meeting on September 3, 2026, at 10 a.m via our Google Meet link. to learn more about the new requirements and implementation efforts. A recording will be made available after the session. Stakeholders are also encouraged to review the legislation, evaluate its potential impact on their operations, and engage with legal and compliance advisors as appropriate.

The Maryland Department of Labor is committed to serving as a trusted resource throughout the implementation process and will continue to provide timely information and guidance.