Trip.com Group Limited has been slapped with a combined penalty of 5.179 billion yuan by China's State Administration for Market Regulation (SAMR) for abusing its market dominance through exclusive dealing and "lowest price on the internet" clauses, marking a landmark antitrust enforcement action in the online travel sector.
The SAMR announced on July 25 that it had fined Trip.com Group Limited 3.521 billion yuan and confiscated illegal gains of 1.658 billion yuan, representing a total financial penalty of 5.179 billion yuan. The regulator also ordered the company to immediately cease the illegal practices, fully refund 122 million yuan in order reserves forcibly deducted from hotel operators, and implement comprehensive corrective measures that must be made public.
Where the investigation began
As China's largest online travel platform, Trip.com Group Limited operates across hotel booking, transportation ticketing, and vacation packages. Since 2025, the SAMR received multiple complaints alleging the company forced hotel merchants to accept onerous contract terms and used technology to manipulate hotel prices, leading to severely compressed profit margins in the hotel industry and undermining fair market competition.
In January 2026, the regulator formally launched an investigation into Trip.com Group Limited. A dedicated task force was established to gather critical direct evidence, conduct comprehensive surveys of competing platforms and numerous hotel operators, perform in-depth big data analysis and algorithm assessments, consult experts, and hear the company's arguments to protect its legal rights.
What the investigation uncovered
The SAMR found that Trip.com Group Limited abused its dominant position in China's online hotel booking service market. Using its traffic allocation mechanism as a core tool, the company imposed exclusive cooperation requirements and "lowest price on the internet" conditions on hotel operators through platform rules and technical means. This conduct eliminated or restricted market competition, limited hotel operators' ability to operate across multiple platforms, infringed on their independent pricing rights, harmed consumer interests, and hindered healthy industry development.
The regulator identified two specific monopolistic behaviors: requiring some hotels to enter into exclusive partnerships, constituting prohibited exclusive dealing under antitrust law; and compelling other hotels to offer "lowest price on the internet" guarantees, constituting prohibited imposition of unreasonable trading conditions.
Financial context of the punishment
In the first quarter of this year, Trip.com Group Limited reported net revenue of approximately 16.2 billion yuan, a 17% year-over-year increase. However, net profit attributable to shareholders fell 41.6% to about 2.5 billion yuan, while adjusted EBITDA stood at roughly 4.8 billion yuan.
On the cost side, operating expenses rose 23% to approximately 3.3 billion yuan. Product development costs increased 15% to 4.1 billion yuan, representing 25% of net revenue. Sales and marketing expenses climbed 25% to 3.7 billion yuan, while general and administrative expenses grew 8% to 1.1 billion yuan.
The company disclosed that its international platform bookings grew approximately 65% year-over-year in the first quarter, while inbound travel bookings surged about 90%.
Expert perspectives on the ruling
Shi Jianzhong, deputy head of the State Council's Expert Advisory Group on Anti-Monopoly and Anti-Unfair Competition and a professor at China University of Political Science and Law, noted that compared to previous platform economy antitrust cases, the Trip.com Group Limited case expands the focus from "choose one from two" to "lowest price on the internet," enriching the types of antitrust enforcement in the platform economy and sending a clear signal of normalized regulation.
Ning Lizhi, another member of the expert advisory group and a professor at Wuhan University Law School, highlighted three distinct messages from the penalty. First, normalized regulation applies to all industries without exception or size-based exemptions. Online travel platform services, as a key segment of the platform economy, are uniformly subject to antitrust legal rules. Second, technological methods cannot serve as a "shield" against antitrust enforcement. The complexity of technology does not create regulatory blind spots, and any behavior that uses technology to restrict competition will be legally addressed. Third, disguised exclusive cooperation is equally illegal. Incentive-based and penalty-based measures that indirectly force or induce merchants to accept exclusive conditions are still within the scope of antitrust enforcement, even if more covert.
What the company must do next
Shi Jianzhong emphasized that the penalty decision should mark the starting point for substantive remediation. Rectification should focus on four areas: completely stopping illegal practices by abolishing exclusive cooperation and forced lowest-price clauses; rebuilding compliance systems to embed antitrust compliance into algorithm design, pricing strategies, and contract terms; innovating business models to shift from a "traffic rent" harvesting model to an empowerment-oriented service approach; and establishing merchant co-governance mechanisms that allow hotel operators to participate in platform rule-making and have access to redress channels.
He concluded that the ultimate value of antitrust enforcement lies not in the size of the fine, but in unclogging the fair competition mechanisms obstructed by monopolistic behavior, allowing market forces to reassert their decisive role in resource allocation. "Restoring competition" is the true legal and economic value of this penalty decision.