Q: The websites of the major online travel agencies list the agencies' "seller of travel" registration numbers, either on the home page or in the website user's terms and conditions (T&C). Is there a legal requirement that all agencies must post their registration or license numbers? If so, can they list the numbers either on the home page or in the T&C, at their option? What about our agency, which has a website but sells nothing online?

A: Only six states have seller of travel registration laws: California, Florida, Hawaii, Iowa, Nevada and Washington.

None of the six states' statutes mentions websites, so you have to review each statute to see whether there are any other display or listing requirements for the registration number. Then you need to interpret the statute to see whether those mandates might apply to websites.

California's law says, "The registration number of the seller of travel shall be clearly and conspicuously displayed on all advertising ... or promotional materials of any kind which are advertised, displayed or disseminated in any manner to any persons in California, or from California to any person elsewhere."

California also requires that "Wherever 'seller of travel,' 'registered seller of travel' or similar terms are used in any advertising materials, they shall be accompanied by a statement which discloses, at least as prominently, that 'registration as a seller of travel does not constitute approval by the State of California.'"

So, the question becomes whether a website or any Web page can be considered advertising or promotional materials. If your website mentions specific destinations or prices or provides reasons to use your services, then I would say that it is "promotional material" and you therefore need to add your California number. In order to meet the "clearly and conspicuously" requirement, you probably have to list it on your home page.

Florida's requirements are simpler and clearer: "Each contract of a seller of travel must include the phrase '(Name of firm) is registered with the State of Florida as a Seller of Travel. Registration No._____.'"

Florida also requires that "Each advertisement of a seller of travel must include the phrase 'Fla. Seller of Travel Reg. No._____.'"

So, for Florida, I would say that you need to include the number in your T&C, which is, after all, a contract, and on your home page if you advertise specific destinations or prices on your website.

Nevada requires that the number appear in all ads in at least 10-point type. So if your website offers specific destinations or prices, then the number belongs somewhere on the site but not necessarily in the T&C.

Washington's requirements are simpler still: You must include the registration number in "all advertisements" but not in "institutional advertising." The latter is defined as advertising that does not include prices or dates.

Hawaii and Iowa do not require that you list your registration number anywhere.

So, only Florida requires that the number be listed within the T&C. California, Florida, Nevada and Washington require it in promotional materials and ads, which can include your website.

Mark Pestronk is a Washington-based lawyer specializing in travel law. To submit a question for Legal Briefs, email him at mark@pestronk.com.