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The EU Digital Markets Act and hotels: what changed in 2024–2026

How the DMA's designation of Booking.com reshaped European hotel distribution — and what independent hotels should be doing differently in 2026.

Bowerbird Research
Distribution-protection desk
7 min read

What the DMA actually says

The EU Digital Markets Act came into force in 2023 with the first gatekeeper designations in 2024. A 'gatekeeper' is a platform that meets size and market-power thresholds. Once designated, the platform is prohibited from a list of specific anti-competitive behaviours.

Booking.com was designated in May 2024. For hotels, the most consequential prohibition is Article 5(3): a gatekeeper cannot prevent business users (hotels) from offering different conditions or prices via other distribution channels.

Practical implications for hotels

Both wide parity (you must match Booking.com's rate everywhere) and narrow parity (you can't undercut Booking.com on your own website) are unenforceable in the EU for Booking.com bookings.

Hotels can now lawfully offer a lower rate on their own direct site, on other contracted OTAs and on offline channels — without violating any enforceable Booking.com contractual obligation in the EU.

Expedia and other major OTAs have not been DMA-designated (yet). For non-designated OTAs, narrow parity often still applies depending on contract.

What independent hotels should change

Audit your published rate strategy in EU markets. Many independents are still operating as if narrow parity were enforceable — leaving 8–15% pricing flexibility on the table.

Update your direct-website rate plan to lead with a 'best rate guarantee — lowest direct price' message, backed by an actual lower price than your Booking.com rate.

Refresh loyalty messaging to emphasise the post-DMA pricing freedom: 'Always cheapest direct. New for 2026 in the EU.'

What the DMA does NOT change

Rogue OTA activity is untouched by the DMA. Rogue OTAs aren't contracted gatekeepers — they're unauthorised resellers operating outside any contract. Enforcement against rogues is a copyright matter, not a competition matter.

Brand-defence Google Ads pressure from rogues continues regardless of DMA. Image scraping continues. Sponsored bidding on your brand continues. The DMA reshapes contracted-OTA dynamics; rogue enforcement remains the lever for the third-party tier.

Frequently asked

Does the DMA apply outside the EU?

No. The DMA applies to bookings made by EU consumers or transacted in the EU. For non-EU markets, traditional parity contract terms still apply.

Will Expedia be designated next?

Expedia has not been designated as of 2026, but the Commission reviews designations annually. If designated, the same parity unenforceability will apply.

Can I cancel my Booking.com contract because of the DMA?

The DMA doesn't void existing contracts; it makes specific clauses unenforceable. Most hotels keep the Booking.com partnership and exercise the new pricing flexibility selectively.

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