TA
There is a standard exemption from the need for an ATOL as follows:
"Section 5 Class Exemptions from the ATOL
Regulations
EXEMPTION 1
1 The Civil Aviation Authority, in exercise of its powers under Regulation 5 of the Civil
Aviation (Air Travel Organisers’ Licensing) Regulations 1995, hereby exempts from the
need to hold an Air Travel Organiser’s Licence (subject to paragraph 3 below) any
person who makes available flight accommodation:
(a)in aircraft with 19 or fewer seats available for occupation by passengers; "
At least there is at the moment - I would imagine that VE will have raised the profile of this at the CAA given that there is a consultation running on updating ATOL regulations.