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Source: State Administration for Market Regulation (SAMR) penalty decision (2026) No. 29, July 25, 2026. New Economists https://mp.weixin.qq.com/s/ECujo_6Qt_CbJanZvB6EUw

SAMR found Ctrip Group abused its dominant position in China’s online hotel booking platform market (China-only relevant market).

Market dominance evidence:

  • Market share consistently above 50% (GMV basis: 53–59% over 2020–2025)
  • Highly concentrated market: HHI ~4,100–4,575; CR3 ~94–95
  • Strong control over pricing, traffic allocation, room inventory, and hotel sales channels

The fouls:

  1. Forced exclusivity (“Special-tier”/特牌 hotels)

    Ctrip collaborate with high-value hotels and give them “Special-tier”, which rewards extra traffic and promotions. Then Ctrip required them to list all inventory exclusively on Ctrip. Over 90% of Special-tier hotels complied long-term. Non-compliance triggered escalating penalties: reduced traffic, revoked benefits, delisting.

  2. Forced “lowest price across all channels” (全网最低价)

    “Gold-tier” and “no-tier” hotels were required to give Ctrip the lowest price online — Gold-tier hotels had to offer at least ÂĄ20 or 5%+ price advantage vs. rivals. Ctrip used automated tools (“Price Adjustment Assistant,” “AI Business Assistant”) and manual intervention — sometimes changing prices without hotel consent — to enforce this.

Both practices violate Anti-Monopoly Law: restricting transactions and imposing unreasonable conditions without justification.

Ctrip is fined ~ÂĄ5.18 billion in total.

During the investigation, the party [Ctrip] argued that the “lowest price across all channels” practice was reasonable on two grounds: First, that the “lowest price across all channels” benefits consumers and prevents “free-riding,” whereby hotel operators promote themselves on the party’s platform but then sell at lower prices on other competing platforms. Second, that the “Price Adjustment Assistant” operates on a voluntary basis—hotel operators can independently activate and deactivate it, and it only adjusts prices when a hotel operator has no orders or fails to meet conversion-rate and sales-progress targets—thereby improving hotel operators’ operational efficiency and optimizing price management.

This authority holds that the party’s above arguments do not stand, and that there was no legitimate justification for the “lowest price across all channels” conduct: First, price cannot be treated as the sole measure of consumer interest. Hotel quality, service standards, and similar factors bear equally and directly on consumer interest. By requiring hotel operators to offer the “lowest price across all channels,” the party distorted the price mechanism, intensified industry “involution” (内卷), and drove a race to the bottom characterized by low prices and low quality—harming consumer interests. Over the long term in particular, the “lowest price across all channels” undermines the hotel industry’s efforts to improve quality and enhance service, working against greater consumer welfare. Moreover, the party engaged in the “lowest price across all channels” conduct to maximize its own interests, improperly interfering with hotel operators’ pricing autonomy and excluding and restricting market competition; preventing hotel operators from “free-riding” cannot serve as justification for such conduct. Second, investigative evidence shows that the “Price Adjustment Assistant” was frequently activated by force, activated without the operator’s knowledge, difficult to deactivate, and automatically re-activated after deactivation—it was not used voluntarily by hotel operators. The primary function of the “Price Adjustment Assistant” is to automatically adjust prices after comparing them against competing platforms, which infringed hotel operators’ pricing autonomy; whether or not it improved operators’ operational efficiency cannot justify the conduct.

It’s a little counterintuitive: by guaranteeing that a seller cannot undercut a dominant platform elsewhere, a lowest price policy removes the seller’s incentive to offer discounts on rival platforms at all—the floor that protects the big platform becomes a ceiling on competition. A platform charging a high commission has little to fear from a cheaper rival if no seller can pass the rival’s savings on to shoppers.

Some other interesting readings:

Rain Intelligence How Price Parity Clauses Became the Common Thread in Antitrust Cases Against Amazon, Steam, and Now Microsoft (2026) https://www.rainintelligence.com/blog/price-parity-mfn-clause-antitrust

Andrew Mercado, Price-Parity Clauses: The Good, The Bad, and the…Anticompetitive?, Truth on the Market (October 21, 2022), https://truthonthemarket.com/2022/10/21/price-parity-clauses-the-good-the-bad-and-theanticompetitive/