Agents have had to balance refunding customers with staying afloat, as their commission is often the only form of payment for their services.

It comes as the Australian Competition and Consumer Commission announced it would not be taking a normal approach to enforcement, but working with travel agents and tour operators.

Bendigo travel agent Sara Doyle said the travel industry was really feeling the pinch, with "literally no way to make money" for Victorian agents.

"Everything's changed again now, because we still can't go anywhere," she said.

"There's a lot of people that were happy with a credit [in March] that are turning around and saying, 'I now want my money back'.

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"We can't even adjust our business model to make money in Victoria, because people can't go anywhere."

Ms Doyle said it was "heartbreaking" to cancel every single holiday that she had planned over the last 12 months.

She said there needed to be a level of understanding from the ACCC about how travel agents made their money.

Ms Doyle said often agents could not refund a cancelled holiday fully, because the earnings on bookings had gone towards overheads, for instance paying staff.

A parliamentary economics committee recently heard there was a six-fold increase in total complaints to the ACCC during the COVID-19 crisis, many about the travel industry.

ACCC commissioner Sarah Court said it was not the organisation's positions that all customers must get full refunds.

Ms Court said the watchdog was primarily concerned with false representations made to consumers that they were not entitled to any refund. She said terms and conditions often did allow for withholding some sort of commission or labor cost, as long as it was reasonable.

Ms Doyle said her clients had been really good about the process around refunding cancellations.

She said some had cancelled completely to get a refund of normally about 90 per cent, while others had held onto credit planning to rebook later.

Ms Doyle said she operated her business Make it Travel from home, meaning she could bunker down without overheads such as rent.