China online travel agency regulation Report Interpretation

Overview

This quick note examines Beijing SAMR’s formal investigations of four OTA platforms and concludes that the cases are likely to have limited consequences for the companies involved and for the industry’s competitive structure.

Core views

On 19 September, Beijing’s municipal branch of the State Administration for Market Regulation announced formal investigations into the travel-booking services operated by Meituan and Alibaba, as well as independent OTAs Tongcheng and Tujia. The stated legal basis is China’s Anti-Unfair Competition Law and E-Commerce Law. Trip.com, which had recently been investigated by the central SAMR over alleged monopolistic practices, was not included in this Beijing municipal investigation. Nomura considers the latest cases less significant than the central SAMR investigation of Trip.com. The firm’s reasoning is that the current investigations are led by a local regulator rather than the central authority, while the applicable laws differ from the Anti-Monopoly Law. Nomura also notes that each of the four platforms has a substantially smaller market share than Trip.com, which in its view makes a monopolistic-practices finding less likely. Major anti-monopoly enforcement can involve substantial fines and mandated business-practice changes; by contrast, Nomura expects any financial penalties in the current cases, if misconduct is established, to be materially smaller. The report believes the regulator is likely concentrating on merchant-facing practices and may be seeking a fairer operating environment for travel merchants. It points to Trip.com’s recent changes in China hotel bookings—removing exclusivity requirements for certain hotel partners and reducing the role of commission rates in hotel-listing rankings—as a possible reference point. Beijing SAMR could seek similar changes from other OTA platforms, particularly in their traffic-allocation mechanisms. Nomura expects the latest cases to have a more limited effect on competition than the earlier Trip.com action. It says Trip.com’s policy changes have given certain hotel partners more flexibility to work with competing platforms, potentially intensifying hotel-booking competition. In contrast, the Beijing investigations appear directed at merchant-facing conduct across several smaller platforms and, based on currently available information, are less likely to materially reshape the OTA industry.

Analysis framework

Nomura compares the regulator, legal basis, apparent scope and market positions of the investigated platforms with the earlier central SAMR case involving Trip.com. It then considers likely merchant-practice remedies and their potential effect on industry competition.

Methodology notes

• Industry AnalysisIndustry Concentration Analysis

  Comparison of OTA market shares and market power

  Nomura uses the smaller market shares of the newly investigated platforms relative to Trip.com to argue that a monopolistic-practices finding is less likely.

• Event-Driven and Behavioral FinanceEvent-driven analysis

  Regulatory-event comparison

  The report assesses the likely consequences of the Beijing investigations by comparing their regulator and legal basis with Trip.com’s earlier central anti-monopoly investigation.

Asset mapping & comparison

Structured mapping from thesis to named assets (strengths, weaknesses, peers, risks).

• Meituan (3690 HK)

  Its travel-booking services are among the OTA platforms under Beijing SAMR investigation.

  Weaknesses

  Potential merchant-practice rectification.

  Comparison

  Smaller market share than Trip.com in Nomura’s view.

  Risks

  Administrative penalties or required business-practice changes if misconduct is established.

• Alibaba Group Holding (BABA US)

  Its travel-booking services are among the OTA platforms under Beijing SAMR investigation.

  Weaknesses

  Potential merchant-practice rectification.

  Comparison

  Smaller market share than Trip.com in Nomura’s view.

  Risks

  Administrative penalties or required business-practice changes if misconduct is established.

• Tongcheng (780 HK)

  An independent OTA under investigation.

  Weaknesses

  Potential merchant-practice rectification.

  Comparison

  Smaller market share than Trip.com in Nomura’s view.

  Risks

  Administrative penalties or required business-practice changes if misconduct is established.

• Trip.com (TCOM US)

  Comparable regulatory reference point; not implicated in the latest Beijing investigation.

  Strengths

  Certain hotel partners have gained greater flexibility to work with competing platforms.

  Weaknesses

  Its prior policy changes could intensify hotel-booking competition.

  Comparison

  Its earlier central SAMR anti-monopoly case is viewed as more consequential than the current Beijing cases.

Key data

• Investigation announcement19 September 2026Beijing SAMR announced formal investigations into four OTA platforms.
• Investigated platforms4Meituan travel services, Alibaba travel services, Tongcheng and Tujia.
• Applicable lawsAnti-Unfair Competition Law and E-Commerce LawThe legal basis cited for the Beijing investigations.
• Trip.com statusNot implicatedTrip.com was excluded from this latest Beijing municipal investigation despite its recent central SAMR case.

Impact & implications

Nomura expects possible merchant-facing rectification, including changes to traffic allocation, but sees limited likelihood of major penalties or a material industry-structure shift based on the currently available information.

Risks

• The eventual findings and remedies of the Beijing investigations remain uncertain.
• Administrative penalties could be imposed if misconduct is established.

What to watch

• Specific conduct cited by Beijing SAMR as the investigations develop.
• Whether regulators require changes to OTA merchant terms or traffic-allocation mechanisms.
• Whether remedies mirror Trip.com’s changes to hotel-partner exclusivity and ranking practices.