This January, the State Administration for Market Regulation, after preliminary verification and in line with the Anti-Monopoly Law of the People's Republic of China, launched an investigation into Ctrip Group Co., Ltd. for suspected abuse of its dominant market position.

On July 25, the State Administration for Market Regulation imposed an administrative penalty on Ctrip Group Co., Ltd. for abusing its market dominance. The total fines and confiscations amounted to RMB 5.179 billion. This included the confiscation of illegal gains totaling RMB 1.658 billion, along with a fine equivalent to 7.5% of its 2025 domestic sales revenue in China (RMB 46.958 billion), totaling RMB 3.521 billion.

The investigation process, findings, and the facts and rationale behind determining Ctrip's monopolistic practices as illegal were also detailed in the Administrative Penalty Decision issued by the State Administration for Market Regulation (Guoshi Jian Chufa [2026] No. 29). Here are some key excerpts:

I. Dominant Market Position of Ctrip in China's Online Hotel Reservation Platform Service Market, as Determined by Articles 23 and 24 of the Anti-Monopoly Law

1. Ctrip holds a market share exceeding 50% in terms of both platform transaction volume (GMV) and operating revenue. In 2025, its GMV and operating revenue accounted for 58.7% and 56.8% of the market, respectively.

2. The relevant market in which Ctrip operates is highly concentrated. Based on platform transaction volume, the 2025 HHI index (Herfindahl-Hirschman Index) for China's online hotel reservation platform service market stood at 4446, with a CR3 index (market concentration index) of 95, indicating a market with few competitors and high concentration.

3. Ctrip exhibits strong market control capabilities, including the ability to influence service prices, traffic, the sales channels of hotel operators on the platform, and room inventory management.

4. Ctrip possesses robust financial and technological resources. As of the end of 2025, its total assets amounted to RMB 267.387 billion, including total current assets of RMB 121.050 billion.

5. Other operators are highly reliant on Ctrip's platform for transactions. This dependency manifests in two ways: firstly, Ctrip's platform exerts a strong locking effect on hotel operators; secondly, it serves as the primary customer acquisition channel for these operators.

6. The online hotel reservation platform service market is characterized by high barriers to entry, including significant capital costs, resource constraints, and data-related challenges.

7. Ctrip wields considerable influence over related markets. Services such as transportation ticketing and tourism vacations are closely linked to hotel reservations, with substantial overlap in consumer demographics.

II. Facts and Rationale Behind Ctrip's Abuse of Market Dominance

It was discovered that Ctrip categorized its commissioned distribution cooperation with hotel operators into various tiers, such as Tier 1 and Tier 2, and labeled hotels on its platform as 'Special Brand,' 'Gold Brand,' or 'Unbranded.' Since 2020, Ctrip has exploited its dominant position in China's online hotel reservation platform service market to enforce exclusive cooperation agreements and 'lowest price guarantee' policies.

(1) Mandating Exclusive Cooperation for 'Special Brand' Hotel Operators

1. Enticing hotel operators to opt for 'Special Brand' status through incentives like traffic prioritization and rights support (benefits and privileges).

2. Requiring 'Special Brand' hotel operators to sign exclusive cooperation agreements. It was found that over 90% of 'Special Brand' hotel operators on Ctrip's platform have consistently adhered to these exclusive cooperation requirements, thereby securing core competitive resources in the online hotel reservation platform service market for Ctrip.

3. Ensuring compliance with exclusive cooperation through various means, including verbal notifications, system reminders, and punitive measures to caution hotel operators.

4. Lack of legitimate justification for such practices. During the investigation, Ctrip contended that exclusive cooperation was commercially reasonable and that 'Special Brand' hotel operators voluntarily opted for it. However, evidence revealed that numerous hotel operators on the platform faced penalties from Ctrip for violating exclusive cooperation terms, indicating that their participation was not voluntary. Furthermore, under Ctrip's incentive schemes like traffic prioritization, the voluntariness of hotel operators does not negate the illegality of such behavior.

(2) Compelling 'Gold Brand' and 'Unbranded' Hotel Operators to Offer the 'Lowest Price Guarantee'

It was found that to gain a competitive edge and further solidify its market dominance, Ctrip required its cooperating 'Gold Brand' and 'Unbranded' hotel operators to provide the 'lowest price guarantee.' Through technological and manual interventions, Ctrip forcibly adjusted the prices of these hotel operators on its platform to ensure they were the lowest available online. It also implemented punitive measures like traffic restrictions and 'delisting' to enforce compliance.

1. Requiring hotel operators to offer the 'lowest price guarantee.' In practice, Ctrip consistently demanded that 'Gold Brand' hotel operators provide a price advantage of at least RMB 20 or more than 5% of the sales price compared to competing platforms, with some regions requiring an even greater price advantage. 'Unbranded' hotel operators were required to maintain prices no higher than those on competing platforms, ensuring the 'lowest price guarantee' on Ctrip's platform.

2. Adjusting hotel prices to be the lowest online through technological and manual means. For hotels failing to meet the 'lowest price guarantee' criteria, Ctrip would directly adjust prices using tools like the 'Price Adjustment Assistant' and 'AI Business Assistant,' as well as the 'Listing Pass' and manual price adjustments. It was found that Ctrip's commission income from transactions involving adjusted hotel prices totaled RMB 1,658,058,958.

3. Implementing various measures to enforce the 'lowest price guarantee.' This included lowering hotel rankings and visibility and forcibly deducting order reserves. It was discovered that Ctrip deducted a total of RMB 122,781,078 in order reserves from hotel operators.

III. Ctrip's Behavior Excludes and Restricts Market Competition

Ctrip's abuse of its dominant position in China's online hotel reservation platform service market, through practices like exclusive cooperation and 'lowest price guarantee' policies, has improperly consolidated and strengthened its market dominance. It has excluded and restricted relevant market competition, harmed the interests of hotel operators and consumers, intensified 'involutionary' competition within the industry, and hindered its healthy and standardized development.

IV. Basis and Decision for Administrative Penalty

In accordance with Articles 57 and 59 of the Anti-Monopoly Law, the following decisions have been made regarding Ctrip:

1. Ordering Ctrip to cease its illegal behavior. Ctrip is directed to fully refund the forcibly deducted order reserves from hotel operators, totaling RMB 122,781,078.

2. Confiscating Ctrip's illegal gains, calculated at RMB 1,658,058,958, and confiscating them in accordance with the law.

3. Imposing a fine. Considering the nature, extent, and duration of Ctrip's illegal behavior, its efforts to mitigate the consequences, and factors such as the inability to calculate some illegal gains, a fine equivalent to 7.5% of Ctrip's 2025 domestic sales revenue in China (RMB 46,957,662,489), totaling RMB 3,521,824,686, is imposed.

The combined total of fines and confiscations amounts to RMB 5,179,883,644.

In response to the penalty decision issued by the State Administration for Market Regulation, Ctrip stated that it had received the Administrative Penalty Decision. "We sincerely accept and resolutely comply with the decision. We will strictly adhere to regulatory requirements, systematically implement rectification measures one by one, and ensure full execution of all measures," Ctrip said.