The Hellenic Competition Commission (HCC) is launching a market test on the commitments proposed by Booking.com B.V. (“Booking”), in order to receive the views of market participants, pursuant to Article 25C(1) of Law 3959/2011 and paragraph 18 of HCC Decision 786/2022.
Views may be submitted until July 20th , 2026.
The case concerns the investigation, following a complaint, of certain practices implemented by Booking, which is active in the market for online intermediation services for hotel-type accommodation bookings through Online Travel Agencies (OTAs), in order to assess a possible infringement of Article 2 of Law 3959/2011 and Article 102 TFEU relating to the abuse of a dominant position.
In the context of the case, investigative measures were carried out involving domestic and international OTAs and hotel accommodation providers throughout Greece. Serious concerns have arisen that Booking is exploiting its dominant position in the market for online intermediation services for hotel-type accommodation bookings through OTAs by implementing a series of practices which, taken together, are capable of excluding competing Online Travel Agencies (OTAs) from entering or expanding in Greece.
These practices consist in the combined application of the Default Ranking Mechanism, the Preferred Partner Programme and the Preferred Plus Programme (hereinafter jointly referred to as the “Preferred Partner Programmes”), together with the Booking Sponsored Benefit (“BSB”) discount programme. More specifically, it is preliminarily assessed that, through the Default Ranking Mechanism and the Preferred Partner Programmes, hotel accommodation providers are incentivised to offer more favourable prices and conditions through Booking’s platform than through competing third-party OTA platforms.
Furthermore, through the BSB programme, which operates as a complement to the Default Ranking Mechanism and the Preferred Partner Programmes, Booking unilaterally reduces accommodation prices in order to ensure that rooms are offered through its platform under the most favourable terms. Taken together, these practices are considered likely to operate to the detriment of competing OTAs and may therefore fall within the scope of Article 2 of Law 3959/2011, as in force, and Article 102 TFEU.
Against this background, and following extensive preparatory meetings with the competent HCC officials, Booking proposed a set of commitments aimed at bringing the suspected infringement to an end.
The text of the proposed commitments is available here.
The HCC is hereby launching a market test on these proposed commitments and invites market participants to contribute by submitting their views, taking into account the preliminary concerns outlined above.
Respondents are requested to include their name, full contact details (email address, postal address and telephone number), as well as the market in which they operate.
Views from interested parties must be submitted in writing and on a named basis. To facilitate the processing of the information received, electronic submission is encouraged. Views should be sent to the following email address of the Hellenic Competition Commission: This email address is being protected from spambots. You need JavaScript enabled to view it., with the subject line “Market test – Booking Commitments”.
Where submissions contain confidential information, respondents must, in accordance with the HCC Notice on the designation of confidential information and the submission of non-confidential versions of documents, submit a duly reasoned request for confidential treatment of the relevant information, together with a separate non-confidential version of their submission.
The deadline for the submission of views is July 20th 2026.
Please note that submissions after this deadline will not be considered.