Booking.com B.V.

Booking.com is one of the world's leading digital travel companies, connecting millions of travelers with accommodation and travel services globally.

Lobbying Activity

Meeting with Eva Maydell (Member of the European Parliament)

18 Nov 2025 · General Exchange

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

18 Nov 2025 · Digital Markets Act (DMA), EU competition policy and travel industry trends

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

18 Nov 2025 · Physical meeting - Exchange on the current geopolitical environment on EU tax policy, European competitiveness and share Booking experience

Meeting with Henna Virkkunen (Executive Vice-President) and

6 Nov 2025 · EU Digital Policy

Meeting with Andreas Schwab (Member of the European Parliament) and European Tech Alliance and

5 Nov 2025 · Digital omnibus

Booking.com Urges VAT Reform to Tax Non-EU Travel Platforms

16 Oct 2025
Message — Booking.com wants reforms that bring non-EU tour operators into the VAT scheme when selling EU travel. They request expansion of the VAT One Stop Shop to avoid multiple registrations. They also seek the ability to opt out of the special scheme for business-to-business sales.123
Why — This would create equal treatment with non-EU competitors and reduce compliance burdens.45
Impact — Non-EU travel platforms lose their current tax advantage when selling European destinations.6

Meeting with Andreas Schwab (Member of the European Parliament)

1 Oct 2025 · DMA implementation

Meeting with Isabelle Perignon (Director Justice and Consumers)

1 Oct 2025 · exchange of views on Package Travel Directive and the Digital Fairness Act

Meeting with Michalis Hadjipantela (Member of the European Parliament)

18 Jul 2025 · Introductory Meeting

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

2 Jul 2025 · Turismin tilanne EU:ssa

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

23 Jun 2025 · Simplification

Booking.com Urges EU Regulatory Simplification for Global Leadership

21 May 2025
Message — The company requests regulatory simplification to reduce overlapping obligations and fragmentation. They call for consistent enforcement across member states and greater legal clarity in digital rules. They want the EU to prioritize harmonization to support European tech champions' global competitiveness.123
Why — This would free resources from compliance to invest in product innovation and expansion.45

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

14 May 2025 · Simplification agenda and transatlantic relations

Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

14 May 2025 · Exchange of views on the new research paper by Booking “Booking.com note on European competitiveness and regulation”.

Meeting with Nikolina Brnjac (Member of the European Parliament)

7 May 2025 · To discuss the current and future challenges in the European tourism sector, review the upcoming findings of the 2025 European Accommodation Barometer, and understand Booking.com’s perspective on shaping tourism policy at the EU level

Meeting with Regina Doherty (Member of the European Parliament)

7 May 2025 · Fraud

Meeting with Daniel Attard (Member of the European Parliament)

6 May 2025 · Introductory Meeting

Meeting with Arba Kokalari (Member of the European Parliament) and Stripe, Inc.

8 Apr 2025 · Digital policy

Meeting with Renate Nikolay (Deputy Director-General Communications Networks, Content and Technology) and European Tech Alliance and

1 Apr 2025 · Exchange of views on AI Act, DSA, enforcement cooperation, digital taxation.

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné) and Bolt and

25 Mar 2025 · Challenges for European tech companies that want to leverage AI to compete globally. Need for a coherent, proportionate, and effectively enforced regulatory framework that increases the competitiveness of European industry.

Meeting with Marc Angel (Member of the European Parliament)

19 Mar 2025 · LGBTIQ Travel, Package Travel Directive

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Bureau Européen des Unions de Consommateurs and

19 Mar 2025 · Code of Conduct on Online Advertising – Workshop 4

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné) and eu travel tech and

11 Mar 2025 · Implementation of the STR Regulation

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

4 Mar 2025 · Code of Conduct on Online Advertising – Workshop 1

Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Feb 2025 · Competitiveness

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

6 Feb 2025 · competitiveness

Meeting with Apostolos Tzitzikostas (Commissioner) and

5 Feb 2025 · Possible cooperation on Code of Conduct for Internet reviews; digitalization of SMEs in the Tourism sector; future Strategy for Sustainable tourism.

Meeting with Anouk Van Brug (Member of the European Parliament)

5 Feb 2025 · Working dinner

Meeting with Marieke Ehlers (Member of the European Parliament)

5 Feb 2025 · Introductory meeting

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)

5 Feb 2025 · Competitiveness in the EU

Meeting with Filippo Terruso (Cabinet of Commissioner Apostolos Tzitzikostas), Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)

30 Jan 2025 · Preparation forthcoming meeting with the Commissioner

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament, Shadow rapporteur) and International Road Transport Union Permanent Delegation to the EU and

30 Jan 2025 · Package Travel Directive

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath), Joachim Herrmann (Cabinet of Commissioner Michael McGrath)

22 Jan 2025 · Exchange of views on initiatives in the field of consumer protection

Meeting with Johannes Ten Broeke (Cabinet of Commissioner Wopke Hoekstra), Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra), Myriam Jans (Cabinet of Commissioner Wopke Hoekstra)

21 Jan 2025 · Exchange of views on various taxation files.

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament, Shadow rapporteur)

13 Jan 2025 · Package travel

Booking.com calls data inventory disclosure obligation unnecessary and disproportionate

10 Dec 2024
Message — Booking.com requests removal of the data inventory publication requirement, arguing it creates legal uncertainty and poses disproportionate burdens. They seek clearer limits on disclosure obligations, more time to implement requirements, and stronger safeguards against data misuse by researchers.123
Why — This would reduce compliance costs and avoid creating comprehensive data catalogs.4
Impact — Researchers lose transparency about available datasets, making access requests harder to formulate.

Meeting with Stefano Cavedagna (Member of the European Parliament)

2 Oct 2024 · Introductory meeting - discussion about the next legislative proposals

Meeting with Svenja Hahn (Member of the European Parliament) and European Tech Alliance and

2 Oct 2024 · Exchange between MEPs and European Tech companies

Meeting with Eva Maydell (Member of the European Parliament)

1 Oct 2024 · EU Tech Agenda

Meeting with Laura Ballarín Cereza (Member of the European Parliament) and Ryanair Holdings and CaixaBank, S.A.

24 Sept 2024 · Priorities for the mandate 2024-2029

Meeting with Aura Salla (Member of the European Parliament)

23 Sept 2024 · EU Digital Policy

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament)

17 Sept 2024 · DMA and FiDA

Meeting with Jens Gieseke (Member of the European Parliament)

3 Sept 2024 · Austausch zu Tourismuspolitik

Meeting with Borja Giménez Larraz (Member of the European Parliament)

26 Aug 2024 · Booking.com priorities

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

15 May 2024 · Digital policy and AI regulation, competitiveness of the EU in digital and tech

Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

19 Apr 2024 · Platform regulation

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

22 Mar 2024 · Video-conference - Discussion on platform economy pillar of the VAT in the Digital Age (ViDA) proposal

Booking.com warns new travel rules reduce consumer flexibility

13 Mar 2024
Message — Booking.com opposes the proposed expansion of the package travel definition, arguing it limits consumer choice. They believe travelers should still be able to book standalone services with flexible terms.12
Why — This allows the company to avoid heavy administrative burdens and legal liability for individual service providers.3
Impact — Consumers lose privacy as companies would be forced to track their behavior to identify package bookings.45

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Airlines for Europe and

22 Feb 2024 · Stakeholder Meetings on Passenger Mobility Package

Booking.com Urges Lighter DSA Transparency Reporting Requirements

24 Jan 2024
Message — Booking.com requests removal of reporting requirements that extend beyond DSA obligations, including automated processing details and moderator numbers. They want monthly reporting eliminated and harmonized MAR reporting periods. The company argues provisions go beyond what is necessary to achieve DSA objectives.123
Why — This would reduce compliance costs and allow them to focus resources on core DSA obligations.45
Impact — Researchers and civil society lose detailed insights into content moderation practices and automated decision-making.67

Meeting with Tom Berendsen (Member of the European Parliament)

23 Jan 2024 · Introduction

Meeting with Christel Schaldemose (Member of the European Parliament)

29 Nov 2023 · accommodation providers

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Shadow rapporteur)

27 Oct 2023 · Green Claims

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Sonae SGPS, S.A.

20 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Catharina Rinzema (Member of the European Parliament)

29 Sept 2023 · Children's Rights

Meeting with Catharina Rinzema (Member of the European Parliament)

29 Sept 2023 · Child protection

Meeting with István Ujhelyi (Member of the European Parliament)

21 Aug 2023 · Tourism

Meeting with Karen Melchior (Member of the European Parliament)

26 Jun 2023 · Discussion on technology, travel and tourism

Booking.com calls for softer audit standard in DSA implementation

2 Jun 2023
Message — The company requests a 'limited level of assurance' audit standard instead of 'reasonable level of assurance'. They argue DSA obligations covering algorithms and content moderation are too qualitative for the stricter standard. They seek clearer guidance on compliance categorizations and audit timelines.123
Why — This would lower the bar for passing audits of their algorithmic systems and content moderation practices.45
Impact — Users and civil society lose stricter independent oversight of platform algorithmic systems and risks.

Meeting with Aliénor Margerit (Cabinet of Commissioner Paolo Gentiloni)

25 May 2023 · VAT in the digital age (with Erik Burckhardt)

Booking.com Urges Tougher Rules on DSA Data Access

23 May 2023
Message — Booking.com requests that data access only serves general monitoring and not formal investigations. They want researchers to sign contracts including non-compete clauses to protect business secrets. The company demands the right to control data interfaces and appeal access requests.12
Why — These restrictions would help the company protect trade secrets and limit regulatory overreach.3
Impact — Independent researchers face higher barriers and legal risks when seeking platform data.4

Meeting with Josianne Cutajar (Member of the European Parliament, Rapporteur for opinion)

27 Apr 2023 · Short Term-Rentals Regulation

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur for opinion)

30 Mar 2023 · Short Term Rentals

Booking.com supports GDPR streamlining but defends the one-stop-shop

22 Mar 2023
Message — The company requests clear deadlines for complaint transmission and fast-tracking amicable settlements. They also advocate for preserving the one-stop-shop principle across new digital regulations.12
Why — This would reduce operational complexity and provide legal certainty for digital businesses.3
Impact — National authorities may lose direct oversight power if enforcement remains centralized.4

Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

22 Mar 2023 · "Short-term rentals" file in IMCO (meeting held by assistant responsible)

Booking.com seeks limits on Commission's DSA inspection powers

16 Mar 2023
Message — Booking.com requests stronger safeguards around Commission inspections, including prior notice for recordings, limits on database access, conflict-of-interest requirements for auditors, reasonable response deadlines, and oral hearing rights. They argue current rules lack adequate protections for business operations and confidential information.123
Why — This would protect their proprietary databases and algorithms from external access and scrutiny.45
Impact — Regulators lose investigative tools needed to effectively assess Digital Services Act compliance.6

Booking.com Demands Stronger Procedural Safeguards in DMA Enforcement

9 Jan 2023
Message — Booking.com requests procedural protections matching antitrust cases: full file access, oral hearings, and eight-week response periods. They argue current proposals undermine defense rights despite DMA's quasi-criminal penalties.1234
Why — This would give them more time and information to defend against potential fines.56
Impact — Enforcement speed decreases as Commission faces longer timelines and additional procedural stages.78

Booking.com urges EU to preserve voluntary consumer commitments

21 Dec 2022
Message — Booking.com asks to maintain voluntary commitments to avoid punitive fines. They want coordinated decisions to prevent member states from re-opening cases. The platform also wants the rules applied to non-EU based businesses.123
Why — Standardized EU-wide enforcement protects the company from divergent national rules and expensive fines.45
Impact — National authorities lose autonomy to launch independent investigations into practices already settled centrally.6

Meeting with Isabelle Perignon (Cabinet of Commissioner Didier Reynders)

13 Dec 2022 · presentation by Booking of their efforts to enable greener choices in the travel sector, their Travel Sustainable Badge, empowering consumers in the green transition

Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur) and Zalando SE

6 Sept 2022 · Empowering consumers for the green transition

Meeting with Alex Agius Saliba (Member of the European Parliament)

27 Apr 2022 · sustainability in tourism

Meeting with István Ujhelyi (Member of the European Parliament)

27 Apr 2022 · Tourism

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and European Tech Alliance and

21 Jan 2022 · Discussion in light of the October OECD statement and the agreement on digital services taxes

Meeting with Thierry Breton (Commissioner)

8 Nov 2021 · Digital Markets Act - Tourism

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

27 Oct 2021 · State of the tourism ecosystem and gatekeepers regulation

Booking.com Urges EU Framework for Short-Term Rental Registration

14 Oct 2021
Message — Booking.com requests EU-level legal clarity on registration schemes for short-term rentals. They want platforms required to display only registered properties and support automated verification systems. They advocate for a single European API system rather than fragmented local systems.123
Why — This would streamline compliance across borders and eliminate competitive disadvantage against less compliant platforms.45
Impact — Unregistered hosts and smaller platforms lacking resources for compliance systems lose market access.6

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Booking.com welcomes the opportunity to provide input to the Commission’s work on the future Data Act initiative. We share the view that data is at the centre of the digital transformation of today’s economy and society. We therefore support the Commission’s intention to explore the possibility, technical feasibility, conditions, risks and opportunities for increasing data sharing between companies and governments, and between companies. The data economy is very dynamic, rapidly evolving and complex by nature. This is why we strongly believe that the future legislative initiative should set out very clear rules on matters such as data ownership or control, rights in subsequent uses/sharing of data and liability arising from the use of data. The way the future initiative approaches these issues can be the key to its success. In addition, it is important to ensure that technological solutions are available and trustworthy to effectively and easily implement legal requirements. It is also important that the future EU initiative for a Data Act takes into account the numerous pieces of legislation that have an impact on data ownership and sharing (e.g. GDPR, DAC7, Database Directive, Copyright) to avoid inconsistencies and build a fair, comprehensive and robust legal framework. Booking.com has made significant investments to be able to rely on data and technology to offer a quality and trusted service to travellers and accommodation partners alike - and to constantly improve that experience. As the Roadmap notes, appropriate incentives (including a FRAND remuneration) for B2B data sharing can unlock a wealth of data to the benefit of the EU market and its competitiveness. We support this ambition. For a meaningful and fair B2B data flow, we believe that the future Data Act should consider commercially viable, technologically reliable and secure ways for the exchange. Businesses need to be confident that data they may share will not be misappropriated. It is therefore crucial, in our view, that the legislative framework brings clarity and certainty as to the ownership of and liability arising from data gathered, created, analysed, enriched or otherwise processed. To achieve this, the future proposal should detail the purposes and clearly define the conditions under which data sharing, access and (re)use may take place. As Booking.com, we believe conditions applicable should not be limited to the fulfilment of contractual obligations between the data owner/holder and the data receiver but also encapsulate subsequent sharing and use by third parties or subsequent incorporation of that data into new sets/other uses. Keeping subsequent sharing out of the scope, or not addressing it decisively, risks taking away the incentive for businesses to confidently share data. It also raises the risk of beneficiaries gaining unfair competitive advantage at the expense of the business that made the initial investment to collect and analyse that data (including technological costs and legal compliance costs). This consideration is also relevant in a business-to-government-to-business (B2G2B) scenario. Overall, we believe it is important to make a distinction between sharing with public authorities (B2G) and sharing with other businesses or competitors. If an instrument mainly concerns data sharing for public safety purposes or other purposes of legitimate public interest, the absence of remuneration for data sharing may be justified under certain conditions. Booking.com is keen to contribute to the creation of a trusted, reliable and robust EU data sharing legal framework that enables all interested parties -public authorities, businesses along the supply chain and consumers- to reap the benefits of a data economy. As a European business, we look forward to discussions to identify solutions that are fair, proportionate and appropriate in the interest of the EU internal market, innovation and European competitiveness.
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Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and Fleishman-Hillard and

16 Jun 2021 · Digital levy

Booking.com urges targeted gatekeeper rules for digital platforms

5 May 2021
Message — Booking.com requests a narrower gatekeeper definition focused on ecosystem control and multi-homing. They want obligations divided into mandatory and selective lists, with selective rules tailored to specific platform types. They propose changes to prevent unintended consequences for travel platforms, particularly around customer contact rules and self-preferencing provisions.123
Why — This would protect their business model from rules designed for app stores.45
Impact — Google and other ecosystem platforms face stricter self-preferencing rules and commercial separation requirements.6

Response to Business taxation for the 21st century

1 Apr 2021

Booking.com welcomes the opportunity to submit views to the Roadmap for a modern tax framework. This is a timely initiative, considering the disruption caused by the pandemic, its impact on the EU and global economies and existing debates/trends predating Covid-19. Challenges of the digital economy: Globalisation, technological progress and digitisation have transformed today’s global economy and consumer experiences but also brought the need to adapt tax rules to ensure that rules are fit for the digital economy. We strongly support this initiative and believe that the expected international agreement will create a new era in taxation, the implementation of which will not be without challenges. A key challenge we see for the EU is the uniform implementation of the expected international agreement by Member States. The OECD-facilitated agreement will be a compromise between more than a hundred jurisdictions and is expected to be complex. We believe it is important for the EU to coordinate a uniform implementation of the future rules across the EU in order to limit divergent interpretations between EU countries while ensuring that unilateral national measures targeting certain digital activities/companies are withdrawn. Considering that it is not feasible to ring-fence the digital economy, measures considered should apply to all taxpayers. To avoid future competitive distortions, the EU business taxation framework must also ensure a level playing field for companies engaged in essentially the same business area. Coordination and simplicity: Even with the OECD solution in place, the taxation landscape will remain hard to navigate for companies operating globally such as Booking.com. It would be interesting to look into the possibility of relaunching the CCCTB proposals and in that framework ensure that they provide for R&D input (i.e. expenses related) incentives, but also for output (i.e. profit related) incentives to stimulate EU digitalisation and innovation. ‘Thematic’ taxes: As the Commission notes, climate change, digitisation and an aging population are growing challenges, prompting a rethink of how tax systems can contribute to addressing them. We believe that a cost-benefit analysis is necessary before introducing green or digital taxes as well as adopting adequate policies, beyond tax measures, that can encourage the twin transition. In this context, we also believe it is important to understand different business models as they evolve and consider this when developing/updating EU tax rules. We are keen to provide further insights and, where appropriate, data that could assist the Commission in these processes. Tax certainty: A modern EU business taxation framework should be shaped so that it reduces disputes between relevant tax authorities to a minimum. Also, it is important that taxpayers can obtain tax certainty through advance certainty processes. We strongly support that dispute resolution mechanisms are maintained and adequately monitored to allow taxpayers access to binding arbitration procedures. Any hurdles that deny taxpayers access to such binding arbitration procedures and/or result in double (or multiple) taxation should be avoided. A balance between social wellbeing and competitiveness: We recognise that taxes are an important way in how businesses contribute to the functioning and wellbeing of societies. That is why we believe that companies should act responsibly and we have always been happy to contribute our fair share. It is also important to keep in mind that taxation constitutes an important or even critical factor for competitiveness. The multiplication of tax obligations on companies, particularly of specific size or sector as well as inconsistent tax regimes can severely harm a business’ ability to compete on an equal footing with its competitors. We look forward to discussions around this initiative and remain available to share our views and experience in more detail.
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Booking.com urges stricter enforcement against illegal holiday rentals

31 Mar 2021
Message — The organization requests that platforms be required to verify registration numbers against official databases for short-term vacation rentals. They propose platforms should ensure only properly registered properties are listed. They also want the definition of advertising narrowed to exclude commission-based marketplaces and the Very Large Online Platform concept refined.123
Why — This would avoid treating every hotel listing as advertising and reduce compliance burdens.45
Impact — Competitors lose as advertising repositories could reveal proprietary ranking algorithms.6

Booking.com Urges EU to Abandon Digital Levy Plans

11 Feb 2021
Message — Booking.com requests the Commission abandon the digital levy and defer to OECD global tax reform efforts instead. They argue the levy would discriminate against digital businesses, create double taxation, and undermine international cooperation. They emphasize that travel companies like themselves were hurt, not helped, by Covid-19.1234
Why — This would allow them to avoid additional tax burden and competitive disadvantage in Europe.56
Impact — European citizens lose potential recovery funding and fairer tax contributions from digital companies.7

Meeting with Thierry Breton (Commissioner) and

2 Dec 2020 · Roundtable with platforms on DSA and DMA

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

23 Nov 2020 · Digital Services Act

Booking.com Urges No Change to Price Parity Rules

20 Nov 2020
Message — Booking.com requests no policy change on price parity clauses, arguing there is no justification to presume adverse effects below market share thresholds. They want narrow parity clauses treated as ancillary restraints and wide clauses subject to effects-based analysis.12
Why — This would protect their commission-based business model from free-riding by hotels offering lower prices elsewhere.34
Impact — Hotels lose flexibility to offer lower prices on their own websites or through competitors.5

Meeting with Thierry Breton (Commissioner)

12 Nov 2020 · DMA and pact for skills

Meeting with Nicolas Schmit (Commissioner) and

29 Oct 2020 · Pact for Skills Roundtable with the tourism sector

Meeting with Thierry Breton (Commissioner) and

29 Oct 2020 · Pact for Skills: Roundtable with tourism sector

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

27 Aug 2020 · Patronage vouchers

Response to A New Consumer Agenda

11 Aug 2020

Booking.com’s success is rooted in placing the consumer at the center of the travel experience. We bring transparency to a fragmented market by making it easy for consumers to compare offers in a standardized format. This reduces search costs and increases the actual choice set for consumers, leading to a more competitive market with lower prices and better matched choices. By offering consumers the opportunity to transact through a trustworthy intermediary, with i.a. customer support in 43 languages, Booking.com also instills confidence in online bookings, resulting in an expansion of the market as a whole. This benefits consumers and accommodations alike. We support the Commission’s objective to ‘align consumer protection with today’s realities, notably cross-border and online transactions.’ In fact, we believe that a true digital single market with uniform rules for consumer protection is in the best interest of consumers and businesses alike. We note that a recent empirical study (Roesner et al) concluded that ‘improved and standardized consumer protection within the European Union has positive effects on trust that consumers have vis-`a-vis retailers and services providers as well as public authorities, and on online purchases.’ Despite the efforts for greater harmonization, today’s consumer protection rules are still fragmented and there is unequal enforcement. This causes unnecessary friction and skews competition. Consider the following example: Booking.com, working with the CMA and CPC, has recently led the way in creating clear guidance for the application of consumer law in online travel. While we believe that these commitments are in the best interest of consumers, we see unequal implementation. This can lead to a competitive disadvantage. We therefore strongly urge the Commission to pursue harmonization to the greatest possible extent. This will help in better protecting consumers, creating a level playing field for businesses, and stimulating cross-border trade. We are aware that uniform legal rules are not always easy to achieve in a timely manner, in particular on emerging issues. For example, there is a growing discussion about the use of behavioral nudges in online sales. We laud the approach of the Dutch ACM in this respect, which has published guidelines for businesses on what it considers to be permissible. However, again, it would be better if such guidance was agreed upon on the EU level. Finally, we would like to touch upon the impact of the COVID-19 crisis on consumer protection and the specific implications it has had on the travel sector. Booking.com believes that consumers should, in the event of force majeure, have the right to a full cash refund. This is the policy enshrined in our general delivery terms with our accommodation partners. We recognize that this policy has not in every instance been well received by our accommodation partners as the crisis was outside of their control and in some instances created financial challenges. However, we do agree with the COVID-19-Consumer Law Research Group that ‘[i]n favour of such a policy is the consideration that the economic burden is often substantially greater for the consumer.’ In fact, many governments set up support schemes for businesses to improve their liquidity. Businesses also have access to credit lines and capital markets while consumers do not. We also note that some Member States took unilateral action to force consumers to accept vouchers. While we are not fundamentally opposed to such schemes, we believe there is a need for greater coherence. At least, there should be a minimum standard in terms of state guarantees for such vouchers and hardship exemptions for consumers. For consumer protection laws to be effective and fostering trust, they cannot be arbitrarily enforced. This underlines again the need for a stronger harmonization in the EU.
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Booking.com urges preservation of limited intermediary liability protections

30 Jun 2020
Message — Booking.com requests maintaining existing liability protections while clarifying specific rules. They want to preserve the principle that platforms are only liable after gaining actual knowledge of illegal content, and maintain the prohibition against general monitoring obligations.12
Why — This would allow them to continue hosting user reviews without proactive content monitoring.3
Impact — Governments and regulators lose ability to impose stricter monitoring and liability requirements.4

Booking.com urges broad competition tool over platform-specific regulation

30 Jun 2020
Message — Booking.com supports a broadly applicable New Competition Tool that can address structural competition problems across all sectors through case-by-case market inquiries. If a gatekeeper regulation proceeds, it must be very narrowly constructed to focus only on practices with a strong presumption of harming competition, such as self-preferencing by vertically integrated platforms.12
Why — This would allow flexible, proportionate regulation avoiding rigid platform rules that could harm their business model.34
Impact — Consumer groups lose stronger protections against anti-competitive leveraging and self-preferencing by dominant platforms.5

Booking.com urges broad competition tool over narrow platform regulation

30 Jun 2020
Message — Booking.com supports a broadly applicable New Competition Tool that can intervene across all markets and sectors. If a gatekeeper regulation is introduced, it must be constructed very narrowly to avoid overlap and focus only on practices with a strong presumption of harming competition.12
Why — This would allow case-by-case assessment avoiding rigid rules that could harm their business model.34
Impact — Consumers and smaller competitors lose if narrow regulation fails to address gatekeeper abuses.5

Meeting with Thierry Breton (Commissioner) and

11 Jun 2020 · Recovery of the tourism sector and role of online platforms

Meeting with Cláudia Monteiro De Aguiar (Member of the European Parliament)

10 Jun 2020 · Establishing an EU Strategy for Sustainable Tourism - Rapporteur

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

28 May 2020 · Impact of COVID-19 (virtual)

Response to Evaluation of the Commission Notice on market definition in EU competition law

14 May 2020

Booking.com welcomes the European Commission’s evaluation of the functioning of the Market Definition Notice as an essential part of the on-going work to adapt the European competition toolkit to the dynamics of the digital economy. As the first step taken in antitrust and merger investigations, the definition of the relevant market provides the foundation on which the competitive analysis is built. Booking.com firmly believes that this should remain the case, despite suggestions to the contrary. A good understanding of the relevant market and the market dynamics is essential for assessing the effects on competition. It significantly enhances legal certainty, consistency and a level playing field which are just as important factors as a sound competition policy to ensure the best outcomes for competition, innovation and ultimately consumer welfare across the EU. Booking.com strongly believes the dynamics of the digital economy are currently not properly captured by the Market Definition Notice and an update is very welcome. This would also contribute to the strengthening of the EU’s Digital Single Market, a key concept for cross-border companies such as ourselves. Booking.com has experienced firsthand that consideration of economic specificities and the magnitude of possible corresponding externalities of two-sided/multi-sided markets is still limited when it comes to market definition. Booking.com therefore welcomes the opportunity to engage with the Commission in order to refine the Market Definition Notice to reflect the crucial differences in business models deployed by various platforms and their likely competitive effects. In particular, the review of the Market Definition Notice offers the opportunity to address numerous challenges that have been identified in the context of platform markets, ranging from the difficulty of applying the traditional conceptional tools to zero-price and two-sided/multi-sided markets, to the dynamic nature of fast-changing markets, and to the question of competition in versus competition for the market. While interdependencies in two-sided markets as well as the speed of market dynamics in the digital sector do pose additional challenges for market definition, this does not make the task less relevant. To the contrary, given the importance of market definition in Article 102 TFEU cases, the issue deserves an approach that considers all actual and potential substitutes, the competition between off- and online, and the degree to which platforms may have a differentiated offering but nonetheless act as a competitive restraint.
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Meeting with Margrethe Vestager (Executive Vice-President)

20 Apr 2020 · To discuss the digital potential for the wider economy and society

Meeting with Paolo Gentiloni (Commissioner)

23 Jan 2020 · Digital taxation

Meeting with Carlos Moedas (Commissioner) and

24 Jan 2019 · Artificial intelligence/Technology/ Research and Innovation

Meeting with Pierre Moscovici (Commissioner)

23 Jan 2019 · Digital taxation

Meeting with Věra Jourová (Commissioner) and

6 Nov 2018 · New Deal for Consumers

Meeting with Mariya Gabriel (Commissioner)

19 Jun 2018 · Women in Digital, Digital Skills

Meeting with Pierre Moscovici (Commissioner) and Google and

7 Mar 2018 · Meeting to discuss digital taxation (also with representatives from Deezer and Volumental)

Meeting with Stephen Quest (Director-General Taxation and Customs Union) and Google and

7 Mar 2018 · Meeting to discuss digital taxation

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici)

16 Feb 2018 · Digital taxation and economic model of Booking.com

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen) and eu travel tech

1 Feb 2018 · Collaborative economy and regulatory developments impacting the short-term rental sector

Booking.com urges soft law over platform regulation

22 Nov 2017
Message — Booking.com opposes new EU legislation on platform-to-business relations, arguing existing laws are sufficient. They advocate for industry-led soft law approaches instead of regulation, claiming regulatory action would punish all platforms and harm innovation.123
Why — This would allow them to avoid new compliance requirements and maintain current business practices.45
Impact — Small accommodation providers lose stronger protections against potentially unfair platform practices.6

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

23 Mar 2017 · Platform regulation in EU member states and obstacles to the single market

Meeting with Andrus Ansip (Vice-President) and

24 Oct 2016 · Platforms, startups

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

22 Jun 2016 · Online platforms and sharing economy and protection of consumers in digital environment

Meeting with Kilian Gross (Digital Economy), Michael Hager (Digital Economy)

22 Jun 2016 · platforms

Meeting with Andrus Ansip (Vice-President) and

24 May 2016 · Platforms, e-Commerce, startups

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

17 May 2016 · meeting with the new Director of Public Affairs

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

17 May 2016 · Meeting the new Director of Public Affairs

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip), Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

30 Mar 2016 · DSM platform regulation - competition and consumer protection policy