The State Administration for Market Regulation (SAMR) has imposed administrative penalties totaling RMB 5.179 billion (approximately USD 770 million) on Trip.com Group Ltd. for abusing its dominant market position in China's online hotel booking platform services market.
The decision, announced on July 25, 2026, marks China's first antitrust enforcement action in the online travel sector and the first case targeting novel monopolistic conduct enabled by digital technologies.
Penalty Details
The penalty consists of three components: an order to refund RMB 122.78 million in order reserve funds forcibly deducted from hotel operators; confiscation of illegal gains amounting to RMB 1.658 billion; and a fine of RMB 3.521 billion, equivalent to 7.5% of the company's 2025 sales revenue in China (RMB 46.958 billion). This is the first platform-economy case in China to combine all three forms of relief, and the first to include confiscation of illegal gains. The 7.5% fine ratio is the highest ever imposed in a Chinese platform-economy antitrust case, compared to 4% for Alibaba and 3% for Meituan.
Investigation and Findings
The SAMR launched its formal investigation in January 2026 following numerous complaints from industry associations and hotel operators alleging that Trip.com forced merchants to accept unfair contractual terms and used technical tools to manipulate hotel pricing. The investigation found that since 2020, Trip.com had abused its dominant position in China's online hotel booking platform services market (with an estimated 56% market share of gross merchandise value as of 2024) through two principal abusive practices.
Two Abusive Practices
Exclusive Dealing
Trip.com offered "special-label" status to high-quality hotels, granting them maximum traffic allocation and promotional support, on condition that they enter into exclusive cooperation agreements and list their rooms solely on the Ctrip platform. Hotels found operating on rival platforms faced punitive measures such as traffic restriction, downgrading in search rankings, and delisting from the program. A homestay operator in Yunnan reported an immediate 90% drop in Trip.com orders after listing on another platform, with their search ranking falling from the front page to beyond page 100. The exclusive cooperation arrangement was not written into contracts but communicated orally by business managers, making it more difficult to detect.
Lowest-Price Mandates
Trip.com required "gold-label" hotels to price at least RMB 20 or 5% lower than on rival platforms, and unlabeled hotels to price no higher than on other platforms. The company enforced these clauses through automated pricing tools such as the "Price Adjustment Assistant" and "Listing Pass," which continuously monitored competitor platforms and automatically adjusted hotel prices downward without merchant consent. A hotel in Jiangsu reported that a room priced at RMB 480 per night during holidays was automatically adjusted by the system to RMB 130, and that the tool was forcibly re-enabled nine times after manual deactivation. Non-compliant merchants faced traffic restrictions, removal of labels, and deductions from order reserve funds.
Significance and Remedies
The case is notable for its demonstration that the use of data, algorithms, and technology does not immunize conduct from antitrust liability—a principle codified in China's 2022 amendments to the Anti-Monopoly Law. The investigation employed big data analysis and algorithmic forensics, processing tens of thousands of gigabytes of electronic data to establish the evidence chain. The case also addresses "involution-style" competition (neijuan), where businesses are driven into unsustainable price wars and resource battles that erode innovation and service quality.
Trip.com has publicly stated that it "sincerely accepts and firmly complies" with the decision and has announced 19 rectification measures, including the immediate cessation of exclusive cooperation requirements, the abolition of "all-network lowest-price" demands, and the elimination of automated pricing tools. The company committed to abandoning "involution-style" inefficient competition in favor of innovation-driven growth.
The case has drawn widespread attention from competition law scholars and industry analysts. Industry observers and legal experts point out that the enforcement action sends clear signals for the platform economy: regular antitrust supervision applies to all sectors without industry exemptions; technology cannot serve as a shield for anticompetitive conduct; and implicit exclusive dealing arrangements remain subject to antitrust enforcement. The case is regarded as a significant step in China's ongoing efforts to normalize antitrust oversight and curb "cutthroat competition" that hampers sustainable development, ultimately benefiting consumers and fostering a healthier ecosystem for all stakeholders.
