Agents have been left out of pocket after tour operator and travel agent Travellers Cities ceased trading this week.
The Kent-based company, run by Clive Allard, the brother of All Leisure Group executive chairman Roger Allard, sold flights through travel agents as well as city breaks and short breaks direct to consumers.
Many agents are seeking legal advice after paying upfront for special airline fares which failed to materialise.
Despite urging for them to be ticketed, they now find the bookings are not there following the collapse of the business.
Without an ATOL agreement between the travel agents and Travellers Cities, a system which came into place in April under the new ATOL regulations, the CAA has indicated it may not be able to reimburse them.
Alan Wright, of TEB Travel in London, said: "We made a booking with him in September where we made a bank transfer of £5,000 as he said he didn't take credit cards.
"Despite us asking for the e-ticket number he didn't reply and finally sent us a locator code which was for a non-ticketed booking.
"We checked he was ATOL licensed but now the CAA is saying we needed a written agreement."
Travellers Cities was established in 1991 but was not an ABTA member.
The company ceased trading on Monday, 15 October and its website is no longer available.
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