Under the shadow of antitrust investigations, Trip.com Group (9961.HK) faces increasing regulatory pressure. On March 23, the Beijing Municipal Market Supervision Bureau publicly highlighted three major issues with the company during a meeting with 12 platform enterprises: automated price-matching interference with hotel pricing, unreasonable penalties for merchants accused of "customer diversion," and misleading "preferred/gold" hotel labels. Two days later, on March 25, the Shanghai Market Supervision Bureau organized antitrust compliance training for over 40 key platforms, including Trip.com.
Since the beginning of 2026, Trip.com has become a frequent subject of regulatory attention. Just before the Spring Festival holiday, financial and market regulators jointly interviewed six travel platforms, including Trip.com, pointing out problems in their cooperation with financial institutions regarding misleading marketing, insufficient disclosure, and inadequate consumer protection. On January 14, the State Administration for Market Regulation launched an antitrust investigation into Trip.com, which remains ongoing. The company stated in its February earnings report that it is fully cooperating with authorities, though it cannot predict the outcome.
This pattern is not new. In 2025, Trip.com was summoned twice by market regulators over concerns about using technological means to unreasonably restrict merchants on its platform. Lin Xianping, an associate professor at Zhejiang University City College, noted that Trip.com’s "high-margin + pricing control" business model is essentially a channel monopoly built on traffic dominance and deep supply chain integration. By controlling premium hotel inventory, implementing a tiered traffic system, and dominating pricing rules, Trip.com has achieved gross margins of over 80%. While this model creates strong barriers to competition, it also carries significant compliance risks.
As of March 27, Trip.com’s Hong Kong-listed shares closed at HKD 391 per share, with a total market capitalization of HKD 279 billion.
The company’s repeated regulatory encounters stem from long-standing tensions arising from its market dominance. Trip.com’s business now covers over 200 countries and more than 600 cities in China, aggregating a massive number of hotel listings. For many small and medium-sized accommodation providers, leaving the platform means losing a steady stream of customers. However, cooperation comes at a high cost. While base commissions typically range from 10% to 15%, merchants often pay additional hidden fees for better visibility, pushing total commission expenses close to 40% of room revenue. This has led to a dilemma: without Trip.com, there are few customers; with it, profitability suffers.
This use of market power to impose unfair trading conditions has triggered strong industry backlash. On December 8, 2025, the Yunnan Homestay Association publicly "declared war" on Trip.com, launching evidence collection for an antitrust complaint. The association cited numerous member complaints about practices such as forced "pick one of two" exclusivity, unilateral commission increases, and traffic blocking. It has hired a legal team to prepare a collective complaint to national and provincial market regulators.
Regulatory scrutiny has intensified in parallel. On December 17, 2025, the State Administration for Market Regulation signaled that practices like forced "lowest price" requirements may constitute monopolistic behavior. Its draft "Internet Platform Antitrust Compliance Guidelines" specifically target eight types of monopolistic risks, including exclusivity arrangements and algorithmic black boxes. Earlier, on September 4, 2025, the Zhengzhou Market Supervision Bureau issued a rectification order to Trip.com, demanding that it thoroughly address unreasonable restrictions on merchants and respect their operational autonomy.
Trip.com has publicly defended its "Price Adjustment Assistant" tool as a means to help hotels adapt to market prices and improve competitiveness. However, in practice, the tool has been criticized for allowing the platform to dominate hotel pricing. State media commentary has described such behavior as "algorithmic hegemony," accusing platforms of squeezing merchants while maintaining a low-price image to attract users.
On consumer complaint platforms, many merchants express frustration. One hotelier reported that Trip.com adjusted a room rate from CNY 455 to just over CNY 300 without consent, and another from CNY 788 to around CNY 500. Multiple hotel managers claimed that Trip.com uses technical means to modify room prices and promotional discounts without permission, comparing the price tool to a "faucet that can’t be turned off."
In August 2025, regulators in Guizhou province summoned Trip.com and four other travel platforms, urging them to comply with laws and prevent pricing misconduct. The latest guidance from the Shanghai Market Supervision Bureau, issued on March 26, 2026, emphasized risks such as "algorithmic collusion" and "pick one of two" arrangements, warning companies against using data, algorithms, capital, or platform rules to engage in monopolistic conduct.
Fu Jian, director of Henan Zejin Law Firm, noted that the relationship between Trip.com and hotels involves both cooperation and contention. While the platform provides essential traffic and booking channels, it also influences hotels through bidding rankings and commission rates. Some hotels, heavily reliant on Trip.com’s user base, find their bargaining power limited.
The "Price Adjustment Assistant" is an automated tool that compares hotel prices across competing platforms and adjusts rates on Trip.com in real time to ensure competitiveness. While it helps Trip.com attract price-sensitive consumers, many hotel operators say it severely restricts their pricing autonomy and compresses profit margins. Automatic price adjustments also lead to inconsistent pricing across channels, complicating revenue management.
Beyond the tool, Trip.com offers various paid visibility products, such as "Pyramid," "Cloud Ladder," "Competition Circle," and "Homepage Search," which merchants must purchase to appear higher in search results. Many report a sharp drop in orders once they stop buying these services.
Industry data shows that while the number of hotels in China continues to grow, key performance indicators are declining. The average revenue per available room fell to CNY 118 in 2024, down 9.7% year-on-year, while the average daily rate dropped to CNY 199.9, and occupancy rates fell to 58.8%.
Fu Jian emphasized that if cost pressures force hotels to cut service quality, consumer experience will suffer, undermining the market’s health. A sustainable business model should benefit platforms, hotels, and consumers alike.
With regulators stepping in, the online travel industry is entering an era of stricter oversight. Bai Wenxi, deputy chairman of the China Enterprise Capital Alliance, suggested that unless Trip.com establishes a transparent and auditable pricing mechanism, its profit model and market valuation could face systemic challenges. Hotels are hoping for more than just the removal of the "Price Adjustment Assistant" and exclusivity requirements—they want a return to rational industry practices where pricing power rests with merchants and choice remains with consumers.
Founded in 1999 and headquartered in Shanghai, Trip.com is a leading global one-stop travel service provider, offering accommodation, ticketing, vacation packages, and corporate travel management. It went public on NASDAQ in 2003 and completed a secondary listing in Hong Kong in 2021. Through investments and mergers, the "Trip.com family" now includes Qunar, Trip.com (international version), Skyscanner, and Rezen Group, among others. The company also holds stakes in several hotel chains.
According to Bank of Communications International, Trip.com accounted for 56% of China’s online travel market by gross merchandise value in 2024, far ahead of competitors like Tongcheng Travel, Meituan, and Fliggy. The company reported net revenue of CNY 62.4 billion in 2025, up 17% year-on-year, and net profit attributable to shareholders of CNY 33.3 billion, a 95% increase. Its gross margin has remained around 80% in recent years.
As it dominates the market, Trip.com continues to face compliance challenges. State media reports indicate that the platform’s issues involve deep intervention in pricing, transaction processes, and consumer choice. Among eight typical cases highlighted in the recent regulatory meeting, five involved Trip.com-affiliated platforms, with problems集中在 in four areas: depriving hotels of pricing autonomy via automated price-matching; penalizing hotels for "customer diversion" during offline extensions; misleading consumers with paid "ticket-booking acceleration" services and unsubstantiated hotel labels; and failing to establish adequate compliance mechanisms for promotions and rule changes.
Accommodation and ticketing remain Trip.com’s core businesses, contributing 42% and 36% of total revenue in 2025, respectively. While the company has achieved high profitability through integration, tensions with merchants persist. As regulatory pressure mounts, balancing growth with the interests of ecosystem partners and fostering healthier competition will be critical challenges for Trip.com.
Lin Xianping suggested that under tightening regulations—such as bans on algorithmic price discrimination and forced pricing control—Trip.com’s强硬管控 over hotels may become unsustainable. Instead, the company may shift toward compliant soft-binding strategies: clarifying traffic rules and replacing exclusivity with paid promotion; enhancing merchant stickiness through data services, AI revenue management, and system integration; and deepening ecosystem interoperability via membership programs and settlement services. The goal would be to transition from forced control to compliant empowerment.
