Ctrip Fined 5.179 Billion Yuan for Abusing Market Dominance in Monopolistic Conduct

On July 25, China's State Administration for Market Regulation (SAMR) imposed administrative penalties on Trip.com Group Ltd. (hereinafter "Ctrip") in accordance with the law for abusing its market dominance to engage in monopolistic conduct, with fines and confiscated gains totaling 5.179 billion yuan.

Since January 2026, SAMR has opened an investigation into Ctrip under the Anti-Monopoly Law of the People's Republic of China (hereinafter the "Anti-Monopoly Law"). It set up a special task force and advanced the case in a strictly regulated, steady and orderly manner in accordance with the law, conducting on-site investigations of Ctrip and obtaining substantial evidence; carrying out extensive investigation and evidence collection among other competing platforms and a large number of hotel operators on the platform; comprehensively analyzing and sorting the evidence, and conducting in-depth big-data analysis and algorithm parsing; organizing experts for research and demonstration; and repeatedly hearing Ctrip's statements to safeguard its lawful rights.

The investigation found that, since 2020, Ctrip abused its dominant position in the market for online hotel-booking platform services within China, using the traffic-allocation mechanism as its core and leveraging platform rules and technical means to carry out two types of monopolistic conduct:

First, it required "Premier-badge" (特牌) hotel operators to engage in exclusive cooperation, using incentives such as maximum traffic priority and rights support to induce hotel operators with high transaction volume, good service quality and strong user appeal to choose the "Premier badge," and required them not to cooperate with competing platforms.

Second, it forced "Gold-badge" (金牌) and "no-badge" hotel operators to offer the "lowest price across the entire network," requiring cross-platform hotel operators to keep their prices on Ctrip the lowest anywhere and allowing Ctrip to adjust prices directly — if it found a hotel's price higher than on a competing platform, Ctrip would lower the price through technical tools such as the "Price Adjustment Assistant" and "Badge Manager" as well as manual means. At the same time, Ctrip used technical means to monitor hotel operators' compliance with exclusive cooperation and the "lowest price across the entire network," and enforced the conduct through punitive measures such as restricting traffic, "de-badging," and deducting order reserve funds. This conduct excluded and restricted market competition, restricted hotel operators' cross-platform operations, infringed hotel operators' right to set prices independently, harmed consumers' interests, intensified "involutionary" competition in the industry, and hindered the industry's healthy development, constituting the abuse of market dominance prohibited under Article 22, Paragraph 1, Items 4 and 5 of the Anti-Monopoly Law — namely restricting transactions without justification and attaching unreasonable trading conditions.

Pursuant to Articles 57 and 59 of the Anti-Monopoly Law, and taking into account the nature, extent and duration of Ctrip's monopolistic conduct, SAMR made an administrative penalty decision in accordance with the law: ordering Ctrip to cease its illegal conduct and fully refund the 122 million yuan in order reserve funds forcibly deducted from hotel operators; confiscating 1.658 billion yuan in illegal gains; and imposing a fine of 7.5% of its 2025 sales in China of 46.958 billion yuan, amounting to 3.521 billion yuan.

SAMR said it will supervise Ctrip's comprehensive rectification, require the rectification measures to be made public and subject to social supervision, effectively protect the lawful rights and interests of hotel operators and consumers, maintain a market order of quality goods at fair prices and healthy competition, and promote innovation and sound development of the industry.