Preferred fares and surcharges
Airlines increasingly prevent their best fares from being distributed by means other than their own website, and this by restricting access to content. Alternatively, they charge special fees for independent distributors to gain access to some of their content. In the long term this will have a negative impact on the functioning of the distribution value chain and, ultimately, on price transparency for consumers.
Fragmentation of the offering and its effect on price transparency
Airlines often add surcharges during the booking process on their own website as part of an increased trend of unbundling. This means that the ultimate amount charged to the consumer is significantly higher than the advertised fare. While independent distributors, including ETTSA's members, only advertise fares that include all surcharges, the lack of transparency on the part of such airlines misleads consumers, prevents them from comparing prices, and thus creates competitive distortion.
EU investigation into airline alliances and consolidation
With EU regulators applying increased scrutiny to airline alliances, it is important that they start looking at the impact alliances, and other forms of airline consolidation, have on the distribution channel. Alliances will become more powerful sales and marketing tools in the future, which means that they will have a tighter grip on the entire value chain and much more dominant positions than their individual airline members. There is a risk that this may have adverse effects on fares, and on the end consumer.
Revision of the EU's Package Travel Directive
As the European Commission is revising its aged package travel rules, it must look at the disparity between the high levels of protection offered to buyers of travel packages and the almost non-existent consumer protection in case of airline bankruptcy. With airline failure being a significantly higher risk than travel agent failure these days, it is in the interest of consumers that EU protection rules should be the same across the board, regardless of who is the distributor of a travel product.
Revision of the EU's Consumer Rights Directive
We welcome the revision of the consumer rights legislation at EU level and call on regulators to work towards equal protection of consumers, regardless of whether they purchase travel products from vendors directly, or via independent distribution intermediaries.
VAT treatment of hotel reservation services
With the implementation of VAT rules for hotel reservation services in the process of being finalised, it is important that Member States agree on a harmonised application of these rules across the EU. Our industry operates in multiple countries and levying VAT where the immoveable property is located creates substantial complications in terms of compliance, while not providing national governments with any additional VAT revenues.
