Being transparent with your customers: a short guide for online accommodation booking sites
Published 26 February 2019
漏 Crown copyright 2019
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The CMA has identified serious concerns about certain practices commonly used in the online accommodation booking sector after an investigation into Expedia, Booking.com, Agoda, Hotels.com, ebookers and trivago who have given commitments to change their practices.
Following this investigation we have published principles to help your business comply with consumer law. If your business is using any of the practices highlighted, you need to make changes by 1st September 2019. We have set out our expectations on what you should and shouldn鈥檛 do below.
Why consumer law compliance matters
Using sales tactics like misleading pressure selling, misleading discount claims, not disclosing the role that money your business earns plays in search results鈥� rankings, and hidden charges can harm customers and the reputation of your industry. It also puts you at risk of breaking consumer protection law.
Who these principles apply to
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all online accommodation booking sites which offer services to UK consumers, including online travel agencies, search engines, big hotel groups and short-stay apartment rentals, as well as smaller businesses selling travel accommodation online, should make necessary changes by 1 September 2019
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online retailers who operate in other markets where similar marketing practices are prevalent should also consider reviewing their practices to ensure compliance with the law
Sales practices you must assess:
Search rankings
- prominently tell customers if the money you earn on bookings or 鈥渃licks鈥� affects the order of results the customer sees
- clearly label 鈥榩aid for鈥� search results 鈥� for example, if a hotel has paid for a pre-determined or prominent position, say so
- clearly differentiate 鈥榩aid for鈥� listings with those that aren鈥檛 鈥榩aid for鈥�
Reference prices
- don鈥檛 present something as a discount 鈥� by using 鈥渟trikethrough鈥� prices or savings claims 鈥� unless the offer gives a real saving on a 鈥渓ike for like鈥� basis
- if you鈥檙e making a 鈥渨as/now鈥� discount claim, make it clear what the 鈥渨as鈥� price relates to 鈥� was it for different stay dates or different occupancy?
Hidden charges
- be upfront about unavoidable fees, charges and taxes and always give the total price
- never try to hide unavoidable costs - revealing them towards the end of a purchase can be misleading and unfair
Pressure selling
- don鈥檛 use false or misleading messages about popularity and availability
- when making statements about availability, make sure you tell the whole story, for example 鈥榅X people have viewed this property in the last 30 minutes for different dates鈥�, 鈥楧estination Y is XX% booked on this site for your dates鈥� and 鈥極nly X rooms left at this price on this site鈥�
Businesses in the online accommodation booking sector must be fully compliant with the principles and consumer protection law by 1 September 2019.
Those who aren鈥檛 risk facing CMA enforcement action, which could lead to the CMA seeking a court order.
To find out more, see the CMA鈥檚 Consumer law: principles for online accommodation booking platforms.
If you are unsure whether a marketing practice complies with consumer protection law always seek legal advice.
This document is not legal advice and should not be relied upon as such.