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eu travel tech

eu travel tech

eu travel tech represents travel technology companies and global distribution systems, promoting transparency, fair competition and consumer choice in travel distribution.

Lobbying Activity

Meeting with Philippe Moseley (Cabinet of Commissioner Dan Jørgensen)

27 Jan 2026 · Affordable housing, short term rentals

Meeting with Gordan Bosanac (Member of the European Parliament)

12 Dec 2025 · Exchange of views on short-term rentals and the European Affordable Housing Plan

Response to Digital Fairness Act

23 Oct 2025

eu travel tech, representing leading travel intermediaries, welcomes the European Commissions efforts to improve consumer rights in the digital environment. Consumer protection, trust and transparency are inherent priorities of companies in the travel tech sector, who remain committed to continue upholding the high consumer protection standards that the EU prides itself on. The EU already has a comprehensive body of law (some of it only recently enacted or subject to ongoing revision) covering the issues raised in the consultation, including the UCPD, CRD, DSA GDPR, AI Act, and sectoral regimes such as the Package Travel Directive (PTD) and the Air Services Regulation (ASR). These instruments are technologically neutral and principle-based, allowing them to flexibly capture new digital practices without requiring constant legislative updates. We are concerned that introducing additional legislative layers risks duplicating existing obligations, creating regulatory overlap and complexity, particularly for businesses that operate across the EU. Instead, where we see a need for improvement is the fragmented enforcement, diverging national interpretations, and inconsistent application of existing rules, all of which create legal uncertainty, distort competition, and erode consumer trust. Against this backdrop, eu travel tech would suggest a shift of focus to measures enabling more coordinated and harmonised enforcement of consumer and other relevant rules across the EU. Where needed, guidance to clarify the application of rules and the interplay between laws would be valuable. Our recommendations draw directly on our extensive experience in the travel tech sector. Coordinated enforcement, such as past CPC joint actions on interface design and pricing transparency in accommodation and flight ticket sales, has yielded rapid and lasting compliance improvements. Conversely, vague or overlapping obligations have resulted in inconsistent application, legal uncertainty, and competitive distortions. We believe that there is room to build on the success of the CPC Regulation to increase the legal certainty that comes with the coordinated and joint nature of decisions. Overall, we urge EU policymakers to focus on the three mutually reinforcing pillars: 1. Guidance to clarify the interplay of different rules to ensure consistent enforcement of existing EU consumer law across Member States; 2. Coordinated enforcement between Member States and various authorities; 3. Harmonised enforcement mechanisms with proportionality and safe harbour incentives for responsible businesses. More detailed policy recommendations are set out in the attached position paper
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Meeting with Mehdi Hocine (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

6 Oct 2025 · STR implementation and new initiative announced by the President

Response to Targeted revision of Regulation (EU) 2021/782 on rail passengers’ rights and obligations

22 Sept 2025

Cross-border, long-distance, and regional rail travel is essential to Europes sustainable mobility transition and to achieving the EUs climate neutrality target by 2050. Regulation 2021/782 (RPRR) provides a baseline for rail passenger rights and a solid framework for carriers and intermediaries to operate. Yet, significant barriers still make rail the less attractive option for travellers compared to aviation or road. Fragmented implementation of the rules, unclear definitions of ticket types, weak governance of minimum connecting times (MCTs), restricted access to essential rail content/tools, and inconsistent enforcement of rail passenger rights significantly hinder rails competitiveness, slowing the modal shift from air and road to rail. Recently, calls have emerged for the RPRR to address operational and digital barriers that can affect journeys involving multiple rail operators. Passengers in particular complain about the lack of consistent protection, which discourages them from booking multi-leg rail trips and weakens confidence in rail as a convenient, reliable option for long-distance travel. The forthcoming targeted revision of the RPRR is a timely opportunity to close these gaps and ensure passengers enjoy practical and enforceable rights for all rail journeys across the EU, regardless of the operator or booking channel. eu travel tech, representing leading travel intermediaries, welcomes this targeted revision and proposes three key recommendations to support seamless, consumer-friendly cross-border rail travel: 1. Clarify and strengthen passenger rights, without shifting undue liability to intermediaries Clearly define through-tickets, combined tickets and minimum connecting times Ensure liability rests with railway undertakings (RUs) for their operations, while obliging them to cooperate so passengers reach their final destination. Recognise journey continuation as a potential way forward to provide passengers with a minimum enforceable guarantee for combined tickets, while avoiding disproportionate liabilities that could discourage cooperation or reduce the availability of multi-leg offers. Confirm that intermediaries role is to facilitate consumer support, not assume financial liability for operational disruptions. 2. Mandate real-time, standardised, and non-discriminatory data access Require RUs to provide schedules, fares, inventory, disruption alerts, MCTs, and after-sales functionality to third parties on FRAND terms. Ensure obligations are binding, while allowing flexible, industry-driven technical implementation (building on OSDM, TAP TSI, and aligned with the forthcoming Multimodal Digital Mobility Services Regulation). Empower intermediaries to provide post-sale assistance by granting them the ability to process refunds or re-bookings on behalf of the passenger, with timely access to the necessary tools and without undue restrictions imposed by carriers. 3. Strengthen enforcement and consumer confidence Establish an EU-level complaint portal (multilingual, one-stop) linked with NEBs for national handling and monitored at EU level to ensure consistency, transparency, and timely resolution. Harmonise reporting and empower NEBs with clear oversight powers, backed by EU-level monitoring and proportionate sanctions. Ensure passengers always retain the right to monetary refunds, with vouchers offered only as a voluntary, consumer-friendly option. Together, these measures, underpinned by a vibrant ecosystem of independent distribution channels, will enhance access, transparency, and choice for consumers. They will help unlock rails full potential as the backbone of sustainable European mobility, supporting both the EUs Green Deal and its digital ambitions. Our position paper attached set out our policy recommendations in more detail.
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Meeting with Daniel Attard (Member of the European Parliament, Rapporteur)

18 Sept 2025 · Sustainable Tourism Report, focusing on usage of data, generative AI

Meeting with Ana Vasconcelos (Member of the European Parliament)

16 Jul 2025 · Count Emissions EU

Meeting with Mehdi Hocine (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

16 Jul 2025 · Spanish Royal Decree implementing the Short-Term Rental (STR)Regulation

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

27 Jun 2025 · Review of the Air Services Regulation

Response to Revision of EU rules on air services

11 Jun 2025

eu travel tech welcomes the Commissions call for evidence for an impact assessment regarding the upcoming revision of Regulation 1008/2008 on Air Services. This revision is an historic opportunity to ensure full price comparability, reinforce passenger rights and advance the Green Deal by closing key gaps that have emerged since 2008. We therefore recommend: 1. Non-discriminatory access to fares Ban airlines from withholding fares, fees or taxes from indirect distribution channels or applying surcharges on them. Insert an explicit ban on discrimination based on booking channel so consumers can access all fares regardless of distribution channel. Require airlines to provide identical fare-and-tax data via at least one open, standardised API on FRAND terms, enabling every distributor to show the same core price. 2. Licence conditional on refund compliance Make airlines operating licences conditional on full compliance with Regulation 261/2004, including seven-day cash refunds and a permanently interoperable refund interface covering indirect and direct sales. Add proportionate financial resilience buffers and an EU-level monitoring framework. 3. Modern price transparency Define an EU-wide list of unavoidable and foreseeable elements always included in the initial fare: cabin hand-luggage, seating of minors with adults, VAT on domestic flights, online check-in and payment method fees. Redefine final price as price of the minimum flight offering and keep display rules outcome-based to allow mobile-friendly design. Oblige airlines to supply full, uniform price breakdown datasets (distinguishing refundable from non-refundable fees) to intermediaries, while limiting intermediaries liability to only the data they receive. 4. Transparent optional services Introduce a reviewable Annex listing core optional price supplements (e.g. checked baggage, seat selection, ticket-change, priority boarding, payment fees). Require airlines to publish prices for these optional prices through the same open API so consumers can compare like-for-like across channels. 5. Sustainability data for informed choice Introduce a harmonised, route-based CO metric aligned with CountEmissions EU and make emissions data available free of charge to intermediaries and accredited calculators, allowing greener flights to be visible wherever consumers shop. 6. Mandatory airline insolvency protection Oblige airlines to hold insolvency guarantees or insurance, modelled on the Package Travel Directive, to cover refunds and, if needed, repatriation. Red flag: between 2011-2019, 87 airline failures affected 5.6 million passengers, who incurred on average 431 each in costs, 83 % of which went unrecovered. A future-proof Air Services Regulation that enforces fair access to content, protects passengers against refund failures and bankruptcies, and delivers trustworthy price and emissions information across all sales channels will foster genuine competition and accelerate decarbonisation in EU aviation.
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Meeting with Martine Kemp (Member of the European Parliament)

28 May 2025 · Passenger rights

Meeting with Polona Gregorin (Head of Unit Climate Action)

19 May 2025 · Discuss the promotion of modal shift towards more sustainable transport modes, including multimodal ticketing initiatives: Multimodal Digital Mobility Services (MDMS) Single Digital Booking and Ticketing Regulation. (SDBTR)

Meeting with Daniel Boeshertz (Head of Unit Competition)

14 May 2025 · Exchange of views on the online rail ticketing market.

Meeting with Mehdi Hocine (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

13 May 2025 · State of play on the STR Regulation implementation

Response to Connecting Europe through high-speed rail

8 May 2025

eu travel tech is pleased to provide its views on the planned "Connecting Europe through High-Speed Rail
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Meeting with Kai Tegethoff (Member of the European Parliament)

8 Apr 2025 · Panel Discussion on MDMS / SDBTR

Response to Technical specification for interoperability relating to the telematics subsystem of the rail system

14 Mar 2025

Please see in the attached eu travel tech's full comments on the European Commission's proposal to revise the TSI Act and Annex.
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Meeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné) and Booking.com B.V. and

11 Mar 2025 · Implementation of the STR Regulation

Meeting with Elisabeth Kotthaus (Head of Unit Mobility and Transport)

5 Mar 2025 · Questions on Council’s two General Approaches on passenger rights of December 2024

Meeting with Kai Tegethoff (Member of the European Parliament, Shadow rapporteur)

4 Mar 2025 · Passenger rights in the context of multimodal journeys

Meeting with Arash Saeidi (Member of the European Parliament) and Humane World for Animals Europe and L214 Ethique et Animaux

15 Jan 2025 · Echange de point de vue

Meeting with Vicent Marzà Ibáñez (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · Passenger's rights - Travel Package Directive

eu travel tech seeks risk-based minor safety guidelines

30 Sept 2024
Topic — New guidelines establishing safety and privacy requirements for minors on online platforms.
Message — The industry calls for a risk-based approach that reflects platform differences. They seek to avoid uniform rules for sites focusing on adult travel transactions.1
Why — Exempting travel platforms from generic safety mandates would lower their regulatory compliance burden.2
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Meeting with Jeannette Baljeu (Member of the European Parliament)

18 Sept 2024 · Multimodal ticketing

Meeting with Pierfrancesco Maran (Member of the European Parliament)

18 Sept 2024 · Priorities new legislature

Meeting with Adrian-George Axinia (Member of the European Parliament)

17 Sept 2024 · voice of travel tech players in Europe-make travel more sustainable, more accessible and more competitive

Meeting with Daniel Attard (Member of the European Parliament)

10 Sept 2024 · Introductory meeting - EU Travel Tech

Meeting with Johan Danielsson (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs and ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU

3 Sept 2024 · Möjligheten att boka och resa med flera trafikslag med en biljett

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

28 Aug 2024 · EU Travel Tech priorities

Response to Better protection for passengers and their rights

8 Mar 2024

We welcome the European Commission's initaitive to reform EU passengr rights including its proposals on the enforcement on passenger rights in the Union and on multimodal passenger rights. Please find attached our full views and recommendations.
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Response to Package travel – review of EU rules

5 Mar 2024

eu travel tech recommendations: 1. Levelling the Playing Field for Consumer Protection: It is imperative that negotiators prioritise harmonising consumer protections across all aspects of travel, ensuring that standalone services, such as flights, are subject to similar mandatory insolvency protection schemes as travel packages. This would create a fairer landscape for both consumers and package organisers, reducing financial and legal risks. 2. Addressing the Real Source of Financial Risk: Limiting pre-payments for package organisers, as suggested in Article 5a, will not effectively address the primary source of financial risk: flights. Enhancing consumer protection requires a focus on amending and enforcing Regulation 261 on Air Passenger Rights, as well as exploring alternative measures for protecting packages that include a flight component, such as requiring industry organisations to hold consumer funds in trust until the completion of the flight component of a package. We recommend reconsidering Article 5a and exploring alternative solutions. 3. Clarity and Simplification in Defining Travel Packages: The PTD review aimed to simplify provisions, yet the proposed broader definition of a package and introduction of new complex criteria for determining when a package was formed will create additional uncertainty for consumers and considerable financial and administrative burden on package organisers. We suggest removing the 3- and 24-hour timeframes criteria for forming packages and emphasise a package definition based on explicitly bundled services, promoting transparency and consumer choice. We also propose the reintroduction of the 24-hour limit for click-through packages, and for Article 3(2)(b)(v) to be amended to ensure that the scope of package only covers the transfer of travellers other personal data when it is in addition to the transfer of the travellers name, payment details and email address to another trader. 4. Alignment with Regulation 261 on Air Passenger Rights: Bridging the gap between the PTD and Regulation 261 on Air Passenger Rights in relation to a consumers cancellation rights during unavoidable and extraordinary circumstances is essential. The consumer cancelling rights foreseen in the PTD should be mirrored in Regulation 261 on Air Passenger Rights, to ensure consistency for consumers and protecting package organisers from disproportionate and unfair financial burdens. 5. Enhanced B2B Refund Obligations: While Article 22 introduces important refund rights for package organisers, we recommend expanding these rights to include a right of refund where unavoidable and extraordinary circumstances have occurred, even if services have not been cancelled and could still be provided. This approach balances consumer protection with the realities of the travel industry, allowing package organisers to navigate exceptional challenges beyond their control while safeguarding the interests of all stakeholders.
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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

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

6 Feb 2024 · State of play of the MDMS initiative

Response to Payment services – revision of EU rules (Directive)

30 Oct 2023

The EUs payment services legislation has been an important driver of change in how travel technology businesses handle payment transactions. eu travel tech broadly views the revised Payment Services Directive (PSD2) as a piece of legislation that has enabled the development of innovative payment services, increasing competition in the relevant markets and making payments more efficient, swift and secure for consumers. At the same time, there have been implementation challenges and uncertainties, which makes the new proposal on the Payment Services Regulation (PSR) and Payment Services Directive (PSD3) all the more relevant. eu travel tech broadly supports the decision to transfer relevant elements of the revised Payment Services Directive into the newly proposed Payment Services Regulation. The adoption of a Regulation will serve the interest of ensuring a uniform application of rules across the EU, thereby avoiding competitive distortions due to varying transpositions into national law and diverging enforcement practices across Member States. We call on EU policymakers to adopt a revised framework which is fit for purpose and closely considers the relevant specificities of the travel sector, in its low-fraud and complex nature. Please find our full views in the attached position paper.
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Response to Payment services – revision of EU rules (new Regulation)

30 Oct 2023

The EUs payment services legislation has been an important driver of change in how travel technology businesses handle payment transactions. eu travel tech broadly views the revised Payment Services Directive (PSD2) as a piece of legislation that has enabled the development of innovative payment services, increasing competition in the relevant markets and making payments more efficient, swift and secure for consumers. At the same time, there have been implementation challenges and uncertainties, which makes the new proposal on the Payment Services Regulation (PSR) and Payment Services Directive (PSD3) all the more relevant. eu travel tech broadly supports the decision to transfer relevant elements of the revised Payment Services Directive into the newly proposed Payment Services Regulation. The adoption of a Regulation will serve the interest of ensuring a uniform application of rules across the EU, thereby avoiding competitive distortions due to varying transpositions into national law and diverging enforcement practices across Member States. We call on EU policymakers to adopt a revised framework which is fit for purpose and closely considers the relevant specificities of the travel sector, in its low-fraud and complex nature. Please find our full views in the attached position paper.
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE

13 Sept 2023 · Green Claims

Meeting with Jakop G. Dalunde (Member of the European Parliament)

6 Jul 2023 · Multimodal Ticketing (Staff Level)

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

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

Response to Revision of the specifications for EU-wide Multimodal Travel Information Services (Delegated Regulation 2017/1926)

26 Jun 2023

Data is at the heart of the services that travel technology companies provide to consumers and businesses. Through the sharing of data between transport operators and digital mobility providers, travelers can be empowered to easily find the right travel options and can be kept fully informed of their journeys at all times. As attaining the right data in a useable format and within the correct timeframe from the relevant transport operators is not always possible through purely commercial or voluntary approaches, the Delegated Regulation on Multimodal Travel Information Systems (MMTIS) provides a valuable tool for digital travel providers to access such data. Please find the full details of our views and concerns in the attached position paper.
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Meeting with Liliane Karlinger (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

28 Apr 2023 · Multimodal Digital Mobility Services.

Meeting with Jakop G. Dalunde (Member of the European Parliament)

19 Apr 2023 · Multimodal Ticketing (Staff Level)

Response to VAT in the Digital Age

3 Apr 2023

The short-term rental (STR) market is among the most dynamic aspects of Europes tourism sector today. Over the past years, STRs have come to revolutionize the way many Europeans travel. Platforms engaged in the intermediation of STRs have played a significant role in the trend, providing consumer transparency and convenience to an otherwise opaque market. This has benefited both consumers and many STR hosts. eu travel tech recognizes the need to adjust and modernize EU tax legislation in light of these developments. A step in this direction was taken with the 7th revision of the Directive on Administrative Cooperation and the Central Electronic System of Payment Information. Our members fully support the objective of combating tax fraud and are committed to supporting authorities in the enforcement of VAT legislation wherever reasonable. Nonetheless, we are concerned about certain elements of the VAT in the digital age (ViDA) package of proposals as presented by the European Commission, particularly the VAT deemed supplier regime and its possible application to platforms active in the STR market and passenger transport services. The proposed regime would introduce significant compliance costs, negatively affect VAT and STR channel neutrality and disproportionately impact SMEs and consumers engaged in the rental of short-term accommodation. eu travel tech wishes to be a constructive partner to policymakers, facilitating the development of legislation which is proportionate and fit for purpose. The attached paper is thus split in two sections: firstly, we outline our general views on the concept and justification of the deemed supplier regime and second, we raise concrete issues we have identified in the proposals of the ViDA package that we believe would benefit from clarification and improvement. While this paper focuses on STR services, the views outlined below also apply in relation to passenger transport services. Please find our full views in the attached position paper.
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Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

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

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

9 Mar 2023 · Short-Term Rentals

Meeting with Leila Chaibi (Member of the European Parliament, Shadow rapporteur)

9 Mar 2023 · Short term rental

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

7 Feb 2023 · Short Term-Rentals Regulation

Response to Methodology for the calculation of the supervisory fee provided for in the Digital Services Act

19 Jan 2023

eu travel tech welcomes DG CNECTs ongoing efforts to support the implementation of the Digital Services Act. We would like, however, to raise some concerns with regard to one of the core elements of the methodology indicated in the draft delegated regulation to calculate the supervisory fee charged to VLOPs and VLOSEs. The DSA and the draft delegated regulation mandate that the methodology is based on the estimated supervisory costs, proportionate to the number of average monthly users of the designated service. The methodology also takes into account the period during which the service has been designated as VLOP. In this regard, we would like to stress the challenges linked to the lack of clarity on how platforms should calculate their monthly users. This carries the risk of leading to major inaccuracies in terms of how recipients of the service are calculated, thereby distorting the supervision costs individual VLOPs/VLOSEs will have to cover. The DSA provides limited detail, especially in view of the vast and divergent business models covered by the regulation, on how to calculate average monthly active recipients of an online platform. In the absence of a methodology for counting users established by a delegated act, which is foreseen by the DSA regulation, eu travel tech would like to underline the risk that a lack of common understanding and alignment on how platforms are counting users will lead to distorted and inaccurate supervisory fee calculations. In addition, eu travel tech would like to highlight an additional distortive element. Travel tech platforms differ from other platforms in scope of the DSA, e.g., social media. Social media platforms, for instance, require user registration. Users need to login to access the platform, which allows for accurate counting of user numbers. This is not the case for travel platforms, where signed out usage is common practice. Everyone browsing the web can access content of platforms including Booking.com, Expedia, Skyscanner, and Tripadvisor without being logged in. Significant overcounting derives from considering signed-out usage due to the fact that it is highly complex if not often technically impossible to accurately identify how many signed-out sessions a single user has or whether the user responsible for a signed-out session is a non-active or artificial user. Moreover, there are also issues related to accurately accounting for signed-in usage (e.g., where a user has multiple accounts). In order to support the correct implementation of the DSA, eu travel tech believes that a much clearer and common understanding of what constitutes an active user must be established to ensure fair, accurate and representative user numbers, including for the calculation of the supervisory fee for VLOPs and VLOSEs. Finally, eu travel tech would like to raise concerns regarding the very short timeframes envisaged by the draft delegated regulation for platforms to meaningfully assist the European Commission or contribute to the supervisory fee calculation at any stage of the process. The draft timeline means that platforms are (i) unlikely to be able to provide the most relevant and accurate information on their economic capacity at the beginning of the supervisory fee methodology, and (ii) given very little time to accurately and effectively contribute to the final stages of the supervisory fee calculation. See attached paper for the full response.
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Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager)

17 Jan 2023 · MDMS proposal

Meeting with Ciarán Cuffe (Member of the European Parliament) and Community of European Railway and Infrastructure Companies and

13 Jan 2023 · Passenger rights

Response to Short-term rental initiative

21 Dec 2022

eu travel tech welcomes the European Commissions proposal on short-term rentals (STRs). We see great value in an EU-wide framework regulating STRs. While STRs are loved by travellers and hosts, we recognise that the market growth in recent years has created challenges for local authorities, especially in popular tourism destinations. At the same time, the measures put in place by Member States across Europe to address these challenges as well as the data sharing requests to platforms have been extremely fragmented and sometimes disproportionate, necessitating an EU tool to ensure greater harmonisation and proportionality. In this regard, we share the proposals ambition to harmonise rules on registration for hosts and data sharing requirements for STR platforms across Europe. The rules will complement legislation such as the Digital Services Act (DSA), the Data Act and the Directive on administrative cooperation in the field of taxation (DAC7). Ensuring an alignment between these rules will be essential to design a coherent and well-functioning legislative framework that helps public authorities better manage the STR sector and allows STR platforms to operate smoothly. In our view the proposal takes a balanced approach with regard to the different roles and responsibilities of hosts, platforms and public authorities. Preserving this balance will be important for the success of this instrument. In particular, the set-up of registration schemes and digital infrastructure by Member States (so called Single Digital Entry Points) will be essential for the effective implementation of obligations on online platforms both with regard to the sharing of activity data and for the performance of random checks. At the same time, we still see the merits of an EU-wide register and digital infrastructure as a centralised system would ensure greater simplification and clarity for Member States, platforms and hosts and be a more efficient solution to achieve the proposals goals. In addition, we feel that the proposal should have gone further and contributed to providing some clarity regarding the proportionality and compliance with EU law of local market access rules adopted to address the challenges related to STRs. We would therefore encourage negotiators to consider adding some clarifications in this regard in the current text or to ensure that further guidance is provided as soon as possible following the adoption and implementation of the STR framework. Further details on our position can be found in the attached paper.
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Response to Creation of the Common European Mobility Data Space

6 Dec 2022

eu travel tech is pleased to support the Commissions initiative on the common European Mobility Data Space (EMDS). As the organization representing digital travel intermediaries, we recognize the crucial role data plays not only in the business models of our members, but also the wider transport ecosystem. eu travel tech members have made it their mission to facilitate data availability regarding mobility offers both for consumers and businesses, providing transparency on travel options and enhanced distribution capabilities. Please find further details on our views and concerns in the attached position paper.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

30 Nov 2022 · Multimodal ticketing

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur)

10 Oct 2022 · Data Act

Response to Review of EU rules on payment services

1 Aug 2022

Please see attached eu travel tech's views on the review of the revised Payment Services Directive.
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Meeting with Sara Cerdas (Member of the European Parliament)

20 Jun 2022 · Reunião sobre proposta legislativa de alegações sustentáveis

Meeting with Alviina Alametsä (Member of the European Parliament, Shadow rapporteur)

13 Jun 2022 · ITS Directive

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

9 Jun 2022 · Data Act

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

8 Jun 2022 · EU Travel Industry

Meeting with Ismail Ertug (Member of the European Parliament)

8 Jun 2022 · Multimodal Digital Mobility Services

Meeting with Henna Virkkunen (Member of the European Parliament)

8 Jun 2022 · EU Digital Policy

Meeting with Marc Angel (Member of the European Parliament)

7 Jun 2022 · UCDP, CRD, STRs and Package Travel Directive

Meeting with Rovana Plumb (Member of the European Parliament, Rapporteur)

31 May 2022 · ITS Directive

Meeting with Jakop G. Dalunde (Member of the European Parliament)

17 Mar 2022 · Regulation on Multimodal Digital Mobility Services

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean)

7 Mar 2022 · Meeting on multi-modality.

Response to Better protection for passengers and their rights

17 Jan 2022

eu travel tech welcomes the opportunity to comment on the European Commission’s call for evidence for an Impact Assessment regarding the the initiative on Better protection for passengers and their rights. See attached eu travel tech's position paper.
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Response to Count your transport emissions: CountEmissions EU

15 Dec 2021

eu travel tech welcomes the opportunity to comment on the European Commission’s call for evidence for an Impact Assessment regarding the CountEmissions EU initiative. See attached eu travel tech's position paper.
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Response to Revision of the provision of air services

6 Dec 2021

eu travel tech welcomes the opportunity to comment on the European Commission’s call for evidence for an Impact Assessment regarding the revision of the Air Services Regulation (Regulation 1008/2008). See attached eu travel tech's position paper.
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Response to Multimodal Digital Mobility Services

1 Nov 2021

eu travel tech is pleased to provide its support for and comments on the Inception Impact Assessment for the Regulation on Multimodal Digital Mobility Services. This initiative will pave the way to the future of passenger transport in the EU and will play a significant part in achieving the sector’s ambitious climate goals. It is clear that Europe should be a leader in global multimodal offerings: its transport system provides unique possibilities for the combination of all modes of transport, making travel more efficient but also more sustainable, allowing travellers to adopt less polluting modes of transport whenever possible. In 2016, the total multimodal market was estimated at approximately 65.7 million passengers of the total 10.6 billion passengers, representing 0,6% of travels . And only 5% of these 65.7 million passengers used a single contract for their travel. In order to move the dial towards a fully integrated, sustainable and multimodal travel sector, we need to create favourable conditions for users. Developing an EU- wide multimodal ticketing and payments system in Europe is a precursor for increased multimodal uptake. Europe already has the technology for this. GDSs, OTAs and other content aggregators have developed the technical capability and transport connections and have been offering multimodal solutions for many years. However, to truly unleash the potential of multimodality, they need not to be hindered by transport operators and particularly need to be able to operate under fair, reasonable and non-discriminatory terms with those operators so as not to operate at a loss, under unfair restrictions, or not on a level playing field with operators’ own distribution channels. They also need access to all fare data. Pooling content from all transport modes into a single system – and allowing travel agencies and consumers to benefit from the vast transport network Europe has to offer - is an important approach to overcome what has, up to now, been a fragmented transport ecosystem. Considering the lack of voluntary developments, such access to all content and to fair, reasonable and non-discriminatory terms can only be ensured through regulatory intervention at EU level, which is why EUTT is thrilled to support the Commission’s ambitions in its MDMS initiative. Please find the full details of our views and concerns in the attached position paper.
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Response to Short-term rental initiative

14 Oct 2021

In this paper, eu travel tech sets out its initial views on the European Commission´s plan for a possible legislative proposal to address issues in the short-term rental sector, based on the Inception Impact Assessment. We look at the preliminary problem analysis and explain why this instrument is important for our association, and detail what in our view would be the most efficient way forward in terms of objectives and policy options. Please refer to the document attached to read the eu travel tech input to the Roadmap.
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Response to Package travel – review of EU rules

17 Sept 2021

The Package Travel Directive (“PTD”) has now been applied since 2018 and these last three years have allowed for a “stress test” of its provisions in light of its objectives: the proper functioning of the internal market and a high level of consumer protection in the area of package travel. It is eu travel tech’s assessment that its application, including in the context of the COVID-19 crisis but not limited to, has exposed some structural flaws of the text which should be remedied. Eu travel tech therefore calls for a thorough revision of the PTD. Before such a revision, the swift issuance of interpretative guidelines of the current Directive is also called for to address the most urgent issues and support travel in the EU and trust in travel for EU travellers. See attached document for more details.
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Meeting with Didier Reynders (Commissioner) and ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU and

8 Jul 2021 · EU Digital COVID Certificate

Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

1 Mar 2021

Eu travel tech strongly supports the proposal of the European Commission for a Digital Markets Act. Digital platforms bring important benefits for European consumers and contribute to the internal market by increasing consumer choice, opening new business opportunities and facilitating cross-border trading. But longstanding concerns have been raised by many stakeholders, including eu travel tech members, regarding unfair practices of a few large platforms acting de facto as ‘gatekeepers’. Intervention based on competition law alone has proven insufficient to address and deter such conducts. Eu travel tech therefore believes that ex post enforcement should be complemented by ex ante rules such as those proposed by the Commission, ensuring EU markets remain fair and contestable to the benefit of consumers. We identify the following areas for improvements in the Commission proposal. Regarding the definition of gatekeepers and the scope of the Regulation: ● The concept of “user dependency”, characterised by the lack of multi-homing, shall be a core element of the definition of gatekeeper, as the key feature of such platforms is the lock-in effects that they have on consumers and businesses. If consumers and business users retain wide possibilities to circumvent the gateway by transacting outside the platforms, then the platform cannot be considered a gatekeeper. ● The notion of “active end users” shall be adequately defined, taking into account the specificities of each business model and their ability to monetise their core platform services. Indeed, for certain type of platforms such as marketplaces, a high number of “visitors” combined with a lower number of ‘transactors’ could actually be a clear sign of wide multihoming for end users. ● The designation procedure shall be as efficient as possible to avoid unnecessary delays. Regarding the obligations imposed on gatekeepers: ● The horizontal approach of the proposal may limit its effectiveness as improperly defined obligations could have for effect a slowing down of the application of the text. All prohibitions under articles 5 and 6 shall be sufficiently well tailored to avoid this impediment. To this end, we suggest for these obligations to be adapted for each specific business model. ● The ban on self-preferencing (article 6 (d)) shall be made more prescriptive by taking into account the specific issues raised by the search engine business model. In order to be effective, the ban shall cover not only discriminatory ranking but also discriminatory display in favour of the services offered by the search engine. Finally, sufficient resources shall be allocated to the enforcement of the Regulation to ensure its effective implementation, and a clear framework shall be provided for the participation of third parties in proceedings. As the European lawmakers are starting their work, eu travel tech would like to present its views regarding the refinements that can be brought to the text.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

1 Mar 2021

Eu travel tech welcomes the proposal for a Digital Services Act, which paves the way for a more responsible online environment, in particular the European Commission’s approach to keep the core principles of the eCommerce Directive with a proven track-record - such as the Country of Origin principle and the absence of a general obligation to monitor. Many of the provisions go in the direction of increasing transparency, accountability and legal certainty. EU Travel Tech members consist of digital travel companies selling or advertising travel products and services to businesses and/or consumers. Our members’ content tends to pose very different risks compared to other types of digital business models, notably social media platforms or advertising-funded business models, where the incentives are very different. The content displayed by our members tends to be purpose limited and does not lend itself easily to illegal activity. Fraudulent properties, hate speech in consumer reviews and illegal short term holiday rentals are examples of the types of illegal content that our members come across in their businesses. The current lack of legal clarity around illegal short term rentals has created a very antagonistic debate and eu travel tech looks to the DSA to provide much needed clarity in terms of how platforms should address and remove this type of illegal content. In view of the horizontal nature of the DSA, which by and large treats all illegal content in the same way, we believe that it is important to bear in mind the very different types and risk profiles of illegal content that are covered by the proposed regulation. Going forward, we see an opportunity to further enhance a risk-based approach that would support a thriving environment for all sectors present in the digital economy - beyond social media platforms - which ultimately will allow consumers to benefit from a more responsible digital market, consistent with the overall objectives of the proposal.
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Response to Digital Levy

9 Feb 2021

In this paper, eu travel tech sets out its initial views on the possibility of the EU applying a digital levy to digital companies, based on the European Commission Inception Impact Assessment. eu travel tech acknowledges that today’s world economy has been fundamentally transformed, with digitalisation enhancing and permeating all sectors. Notwithstanding the resulting benefits to businesses and consumers, whilst adapting to fast-paced global markets, this digital transformation inevitably brings challenges, such as the need to ensure that tax systems reflect the new realities of a digital economy. At eu travel tech we hold in high regard the global community effort to address these tax challenges of the digital economy, and strongly support the European Commission in giving preference to an OECD agreement on an international solution, as previously announced by Vice-President Dombrosvskis and Commissioner Gentiloni. We believe that such a solution is crucial to ensure a level playing field on tax internationally, and to avoid negative and discriminatory implications for the EU economy. As such, we are concerned about the unintended consequences that initiatives such as a new EU digital services tax (‘DST’) or a EU digital levy could have, ultimately harming both the competitiveness of the markets and consumers. EU travel tech members, having felt significantly the effects of the pandemic, share the urgency of identifying measures that support recovery and return to growth. At the same time, we call for caution with introducing a digital levy that could go counter to that objective. We believe that the considerations presented in this paper would help design a balanced solution that avoids negative and discriminatory implications for the EU economy.
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Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean) and ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU

25 Nov 2020 · Follow up meeting to discuss latest developments in the sector.

Response to Revision of the Intelligent Transport Systems Directive

19 Nov 2020

As part of its new Smart and Sustainable Mobility Strategy, the European Commission will revise the Directive on Intelligent Transport Systems (“ITS Directive”). In the attached document, eu travel tech is providing its input to feed the preparation of this revision by the Commission, focusing specifically on the facilitation of seamless multimodal travel through data-sharing between transport services suppliers and mobility platforms. Eu travel tech members are providing the technology that is helping to power Europe’s travel sector, adding value for travel services suppliers in Europe but also for European consumers. Thanks to their position at the centre of the travel and tourism sector, they are key players to achieve sustainable, efficient, seamless, smart mobility across the transport modes.
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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Gaëlle Michelier (Cabinet of Commissioner Adina Vălean)

12 Nov 2020 · Discuss horizontal developments in the transport industry.

Response to Possible revision of the Code of Conduct for computerised reservation systems (CRS)

2 Sept 2020

This possible revision of the Code is welcomed by eu travel tech. eu travel tech supports the principles the Code promotes: level playing field, transparency for consumers and business users and fair competition. This is especially important in a COVID-19 environment and beyond, where consumers are in need of transparent information that re-establishes their trust and confidence in travel, and where small airlines and travel businesses are able to compete on an equal footing with larger players. But, as fully acknowledged by the evaluation study, the air travel distribution landscape has undergone major changes over the last ten years, making the existing regulatory framework and the Code unfit for purpose. The Regulation must therefore be significantly amended and partially repealed (option 3 of the Inception Impact Assessment; see document attaced). As a result, we would support option 3 only if it reflects the below conditions, with a partial repeal of the Regulation combined with an updated scope and other provisions so as to take into account market developments and foster competition and innovation in airline ticket distribution: - Apply to all players competing in the airline ticket distribution market; and in particular airline-controlled interfaces accessible by consumers or travel agents (airline agency portals, airline websites, mobile apps). - Display obligations on CRSs should be balanced with content quality commitments by airlines that choose to participate in CRSs so that European consumers can continue to make well-informed choices and compare and choose travel options that best suit their needs; - Be adequately enforced by the European Commission. You will find a more detailed presentation of our views in the attached document. *** eu travel tech represents the interests of travel technology companies. eu travel tech uses its position at the centre of the travel and tourism sector to promote a consumer-driven, innovative and competitive industry that is transparent and sustainable. Our membership spans Global Distribution Systems (GDSs), Online Travel Agencies (OTA), Travel Management Companies in business travel (TMCs) and metasearch sites.
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Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

30 Jul 2020 · DSA: ex ante gatekeeper proposal

Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

eu travel tech represents the interests of travel technology companies. Our membership spans Global Distribution Systems (GDSs), Online Travel Agencies (OTA), Travel Management Companies in business travel (TMCs) and metasearch sites. Our members are providing the technology that is helping to power Europe’s travel sector, adding value for travel services suppliers in Europe but also for European consumers. Thanks to their position at the centre of the travel and tourism sector, they are key players to achieve sustainable, efficient, seamless, smart mobility across the transport modes. Reconciling the need for seamless mobility with Europe’s decarbonisation objectives calls for a rethink of European mobility. Further developing a multimodal framework is a clear solution to this issue as it would facilitate the shift towards low-emission transport modes by moving passengers to more sustainable alternatives. However, to truly unleash the potential of multimodality, access to fare data from all travel services providers must be ensured. Pooling data from all transport modes into a single system – and allowing travel agencies and consumers to benefit from the vast transport network Europe has to offer - is the only solution to overcome what has, up to now, been a fragmented transport ecosystem. Ensuring a non-discrriminatory access to transport data, static and dynamic, for all distribution channels, should be the cornerstone of a seamless multimodal transport system. Today, European Commission has many opportunities to enshrine data sharing as a cornerstone of the Single European Transport Area through the many regulatory files being reviewed: - Review of the Commission Regulation 2017/1926 on the provision of EU-wide multimodal travel information services: the obligation to share data for travel services providers shall be extended to dynamic data. - Review of Regulation 1008/2008 (price transparency part): to ensure that customers are able to effectively compare options, the regulation shall ensure that information on fares and core optional services are available and bookable on all distribution channels. - Review of Regulation 80/2009 (CRSs Code of Conduct): the new regulatory framework shall allow consumers to compare offers and services in one place, in order to ensure fair competition and transparency in the air travel market. Airlines participating in a CRS or alternative distribution systems must be required to provide “essential” air fare content, including basic fares and core ancillary services to all distribution channels, thus preventing discriminatory practices. - Review of Directive 2012/34/EU establishing a single European railway area: a horizontal initiative regulating the asymmetric power of legacy railways undertakings vis a vis indirect distribution channel is necessary to ensure fair and loyal competition in the rail distribution internal market Please find a more detailed presentation of our views in the attached paper.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

8 Jul 2020 · To discuss Digital Services Act

Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

29 Jun 2020

In this paper, eu travel tech sets out its initial views on the Digital Services Act package, in particular on the ex ante regulatory instrument for large online platforms with significant network effects acting as gate-keepers, based on the European Commission Inception Impact Assessment. We look at the preliminary problem analysis and explain why this instrument is important for the travel tech sector, and detail what in our view would be the most efficient way forward in terms of policy options to deliver ex ante regulation that complements competition law and guarantees fairer trading practices in digital markets.
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Meeting with Didier Reynders (Commissioner) and

15 Apr 2020 · impact of COVID-19 on the sector

Meeting with Isabelle Perignon (Cabinet of Commissioner Didier Reynders)

7 Apr 2020 · impact of COVID-19 on consumers

Meeting with Gaelle Garnier (Cabinet of Commissioner Thierry Breton), Valère Moutarlier (Cabinet of Commissioner Thierry Breton) and

7 Apr 2020 · Impact of Covid-19 crises on Tourism

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

17 Feb 2020 · Digital policy

Meeting with Christiane Canenbley (Cabinet of President Jean-Claude Juncker)

7 Jun 2018 · Digital Single Market

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

16 May 2018 · Illegal content online, P2B relations, collaborative economy

Response to Measures to further improve the effectiveness of the fight against illegal content online

30 Mar 2018

Please see our feedback in the attached document.
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Response to Common rules for the operation of air services in the EU

22 Mar 2018

The European Technology and Travel Services Association (“ETTSA”) and its members welcome the opportunity to offer comments on the Inception Impact Assessment of Regulation EC 1008/2008, published by the European Commission on 22 February 2018. Our full comments are to be found in the attached document.
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Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen) and Booking.com B.V.

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

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

13 Dec 2017 · Platforms-to-Business relations, DSM general

Response to Fairness in platform-to-business relations

21 Nov 2017

ETTSA agrees that online platforms drive innovation and growth in the digital economy and play an important role in opening new market opportunities, notably for SMEs. The use of online platforms empowers small businesses. Access to data (particularly to the market reports provided by P2B) tends to empower small businesses, as big players have their own data analysis tools. ETTSA’s members ensure a high level of transparency is provided on their platforms. They give clear information to business users on search ranking and factors influencing their algorithms. They're also transparent about advertisement placements – genuine advertising is clearly labelled and different from the recommended sort resulting from algorithms. Furthermore, ETTSA signed the Key Principles for Comparison Tools and its members work tirelessly to implement each key principle. Yet OTAs face a difficult challenge given that some businesses for example airlines withhold information from platforms, i.e. accurate information on costs of ancillary services, or refundable fees, which in turn prevents platforms from presenting these fees and related information clearly to consumers. In addition, some businesses discriminate against platforms vs their own direct channels by withholding data or making certain content available on platforms artificially more expensive in order to make platforms less competitive and avoid comparison shopping. OTAs make every effort to increase transparency for consumers as this makes prices more competitive for them. They do this by using technology to empower consumers to be able to search and identify the best value deal. The interest of some providers such as airlines and hotels is ultimately to reduce transparency as that keeps prices at a higher level. Policymakers should therefore be wary of regulatory solutions that would reduce transparency for consumers. We call on the Commission to take an evidence-based approach and ensure that clear definition of a problem precedes any intervention. We take note of the problem of business users’ perceived lack of access to data, such as contact details of their customers whom they serve via platforms, which has been identified in the Inception Impact Assessment. OTAs don't prevent their business users from contacting customers. They facilitate communication between their business users and customers involved in the booking for many purposes, e.g. facilitating check-in, communicating reception closing times or conveying special requests. Hotels can also obtain contact details of their guests as soon as they check in at their premises and they are free to use that data for any purposes they wish, subject to the appropriate consumer consent. ETTSA’s metasearch members also enable for free or not businesses to upload their contact details to be directly contacted by users. There is no need for greater portability given that there's competition in the travel sector, multi-homing is prevalent and, moreover, portability of reputations doesn’t make sense as it's based on different criteria per platform. Further portability imposed on OTAs would encourage capture of the data by big players. When addressing P2B relations, the Commission should take into account the evolution of the platform environment. Today, major hotel chains are pursuing asset light franchise strategies, meaning they are now effectively single brand platforms funded by the fees paid by franchisees and they compete directly with OTAs for the business of independent hotels. Customer services of our members also provide internal escalation mechanisms to address questions raised by businesses. ETTSA believes, therefore, that in order to ensure a fair and innovation-friendly platform economy, the optimal response would be EU soft law action to spur industry-led intervention to promote industry action on transparency and tackle certain unfair practices imposed on platforms(such as access to data and discrimination).
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Response to Targeted revision of EU consumer law directives

27 Jul 2017

ETTSA generally supports the direction taken by the European Commission as outlined in the Inception Impact Assessment of the targeted revision of EU consumer law directives. ETTSA welcomes the fact that B2B relations are not covered by the present initiative. We also welcome the removal of any unnecessary administrative burdens (e.g. cutting overlapping information requirements in the UCPD and CRD) as long as the consumer still receives transparent information to be able to effectively compare prices and other conditions. We recommend that this be achieved without legislative action, as envisaged in the policy options in the IIA.
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Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici) and Expedia Group

22 Jun 2017 · New taxation in Italy of short term real estate leases

Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)

20 Feb 2017 · Digital Single Market

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

13 Oct 2016 · the role of the travel technology sector in EU transport

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

13 Oct 2016 · Aviation

Meeting with Elżbieta Bieńkowska (Commissioner) and

13 Oct 2016 · travel technology sector in the EU’s Internal Market

Meeting with Andrus Ansip (Vice-President) and

13 Oct 2016 · e-commerce, geoblocking, competition policy

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and Inline Policy Srl

14 Jun 2016 · Digital single market

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

2 Jun 2016 · Aviation

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

25 May 2016 · Code of Conduct for computerised reservation systems

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

20 May 2016 · platforms, eCommerce, DSM

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Markus Schulte (Digital Economy)

22 Sept 2015 · PDT Directive