Operating legally as a travel agency requires strict adherence to state Seller of Travel (SOT) regulations. Here is what every agency owner needs to know to stay compliant in 2026.

1. The Four Mandatory SOT States

  • California (CST): Requires annual registration and participation in the Travel Consumer Restitution Corporation (TCRC) or specific bond requirements.
  • Florida: Requires an annual Seller of Travel certificate and surety bond unless operating under a qualifying host agency exemption.
  • Washington: Mandatory registration and dedicated trust account management.
  • Hawaii: Requires physical activity registration and trust accounts for passenger funds.

2. Host Agency SOT Exemptions vs. Independent Registration

If you join a host agency, you can often operate under their Florida and California SOT numbers as an Independent Contractor (IC), provided you meet their contractual guidelines and do not collect client funds under your own merchant account.