Implementation tracker - Digital Markets Act - Google (Article 6.5)

Current position papers and docuemnts are available in the sidebar.

The documents in this section are confidential. Please reach out to HOTREC team if you would like to share them with further.

Update - November 2024 - New Google Proposal - Google

You can find the latest proposal from Google on Google Search under related documents (Google -- HOTREC -- Additional changes to Search compliance solution (November 2024).pdf. Please note the document is confidential.

Update November 2024 - HOTREC follow-up paper - Google

HOTREC follow up paper on Google Search can be found under related documents.

Update  - 4 July - HOTREC follow-up paper on Google search compliance solution - Google

HOTREC follow-up paper on Google search compliance solution is available under related documents.

Update - 17 May - HOTREC follow-up paper on Google search compliance solution - Google

Following the exchange during the last HOTREC Distribution Working Group and General Assembly in Budapest, please find here the draft HOTREC follow-up paper on Google search compliance solution.

The paper serves as a follow up to the position paper from December 2023 (here). It proposes concrete and balanced compliance solutions on various aspects of new Google Search product which has a paradigm shifting impact on almost 2 million hotels, restaurants and other hospitality establishments across the EU and their online distribution.

We would invite you to provide feedback and comments by 27 May 2024 COB at the latest.

Update - 25 March - Workshop on DMA - Google

On 21 March, HOTREC attended a Google compliance workshop organized by the European Commission. During the event, Google presented its compliance solutions concerning various parts of its ecosystem, including Google Search.

HOTREC underlined that the current solution results in a web result page which features only the accumulation of offers from various OTA and metasearch providers. We also asked Google what more it will do for SMEs and underlined the importance of keeping the prices overview function, renaming the ‘’lodging’’ chip and welcoming the link to direct hotel websites.

The European Commission only moderated the discussions and did not provide any views.

Update - 6 March 2024 - Joint industry statement on Google Search and Article 6.5 (self preferencing) - Google

Together with Airlines for Europe (A4E), Ecommerce Europe, The European Hotel Forum, EuroCommerce, and Independent Retail Europe, we have issued a joint industry statement on Google search and Article 6.5 of the Digital Markets Act.

The statement has the following key messages:

• The changes on Google’s verticals (retail, airlines, hotels/restaurants) should not redirect traffic to online search services (OSSs).
• The changes on Google’s verticals should not lead to a reduced visibility of organic results of direct suppliers/merchants websites.
• The process through which stakeholders are consulted and informed of changes by Google should also be improved in the future.
• Signatories encourage the European Commission to ensure compliance, closely monitor the implementation and set up an independent system which will measure the impact on business users from 6 March 2024, with the view to identify and correct any harmful unintended effect on business users

We have published the statement on our social media channels (LinkedIn, Twitter).

Update - 9 February 2024- Meeting with Cabinet of VP of the European Commission Margarethe Vestager - Google/Booking

On 07 February 2024 HOTREC met with the cabinet members of Margrethe Vestager, the European Commissioner for Competition (DG COMP) to discuss the interests and concerns of the hospitality sector regarding the implementation of the Digital Markets Act (DMA). 

• The Commission thanked HOTREC for its active involvement in the consultation process.
• Business-user engagement should be at the centre of the DMA framework. So far, the Commission does not have any information to provide.
• As of 6 March, the deadline for compliance for the designated gatekeepers, the Commission will start examining the level of compliance of all the gatekeepers. They anticipate that not all gatekeepers will comply with all the criteria so adjustments will be needed.
• Moreover, it was emphasized that some points in the DMA are not as straightforward to investigate.
• For example, further discussion will be needed to decide how much weight should go to independent hotels or intermediaries on Google’s search pages. Therefore, even after the compliance deadline on 6 March, the Commission will continue to be in dialogue with the gatekeepers.
• Regarding the designation of potential new gatekeepers, among which Booking.com, the Commission assured that similar consultation procedures will take place. HOTREC underlined the importance of designating Booking.com as a gatekeeper. 
• The Commission noted that in case Booking reached thresholds on 31 December 2023, they are required to communicate this to the Commission within 2 months.
• The Commission asked for feedback on the Platform-to-Business Regulation. HOTREC explained that there is a large lack of awareness among hotels about the Regulation. 

Update - 5 December 2023 - Google

On Friday, HOTREC organised a one-hour session with Google to present changes to Google Search. Please find below a brief summary.

• Google is trying to find an alignment between its core principles and the law.
• Their solution must ensure that Google services are no longer favoured compared to other services.
• Consumers will also see reviews from other online search services.
• Similar principles in search display are also envisaged for restaurants/bars. HOTREC is in touch with Google concerning these changes and will keep members updated.
• Compared to the previous version that HOTREC saw in September, Google added a specific filter titled ‘’lodgings’’ which featured next to ‘’comparison sites’’ filter. The word lodgings also includes STRs.  Google is open to listening to alternative suggestions for the wording of the filter.
• Lodging filter will only include hotels and similar accommodations and exclude comparison sites, including OTAs. The same is true for the opposite – Hotels and similar accommodations will not be visible under the ‘’comparison sites’’ filter.
• While the map of a location will be visible, it will not be possible to click on it and be redirected to the maps page.
• Google again reiterated that they are noticing a drop in clicks to direct websites of suppliers.
• The presentation did not include ads however Google confirmed these will remain visible.
• Other information from the initial email below remains relevant.

Yesterday, HOTREC also attended stakeholder event organised by Google where we also discussed the DMA. We were informed that larger-scale tests will begin soon and that we will be informed. Google also promised to provide more updates and information about the changes in the coming weeks.

Update - 3 October - Google

At the beginning of September 2023, Alphabet (i.e. Google) was designated as a gatekeeper platform under the Digital Markets Act. One of their services, Google Search will be required to comply with the obligations envisaged in the law.

Last week, HOTREC was invited to a workshop organised by Google, to present how they are planning to rearrange its search results page in order to be compliant with the DMA, more specifically Article 6(5) on self-preferencing.

The meeting involved different stakeholders from the hotel ecosystem from various EU locations (Spain, Netherlands, Paris, Germany), mostly from hotel chains and professional organisations. Google also informed us that they will hold separate discussions with OTAs. The European Commission (DMA implementation team) was present but did not react during the meeting.

We have prepared for you a brief overview of key points from the meeting

• Google is differentiating its users into three different categories - People, businesses, virtual search services. Hotels fall under business category.
• Google only presented a mobile version of the new search product. The desktop version is not ready to be presented.
• Google underlined that there will be a difference when a user searches for a specific hotel or hotels in a city. More on this below under ‘’ Main visible changes that we noticed’’.
• Organic ranking mechanism will determine which hotel will show up on the website. This algorithm will not be disclosed.
• Changes will go live on 6 March 2024 in the EU as gatekeepers have 6 months to comply.
• They do not have a full data set yet as they are only starting to test the new solution/product. However, the early number shows that there is a bit of a drop in clicks for the websites of suppliers (10%). Google also noticed more clicks going towards OTAs and they understand that there will be changes in traffic.
• For Google there is one key point in their understanding of the DMA and self-preferencing Article 6(5) - When users come to the search page there will be no preferential links to Google search pages.  Google team seems very confident that this is in line with their obligations under the DMA.
• In terms of the timeline, they are currently doing product tests and they will share the results with the European Commission during the meeting in the coming weeks. They will start the rollout in Q1 2024.

Main visible changes that we noticed (you can find a visual illustration below)

• Changes in the toolbar – The toolbar could be used by users to filter their preferred options.
• First option would be called ‘’spaces’’, followed by ‘’comparison sites’’, etc.
• Some comments from attendees were directed towards the incorrect expression calling hotels ‘’spaces’’.
• Searching for specific hotel
• We did not notice many visible changes.
• The hotel website would remain the first result.
• The demo did not include any ads.
• Searching for hotels in city
• The demo did not include ads which will feature on the top of search results.
• On the mobile version, an OTA website was listed first followed by Google Hotels.
• When clicking on a specific hotel, the landing page would be the same as when searching for a specific hotel.
• Other features
• Google also presented a new preview screen for hotels which included photos, reviews, and links to different offers from virtual search engines, OTAs and hotels (sponsored options were listed ahead of the non-sponsored).

HOTREC preliminary evaluation – The new product would negatively impact hotels, especially SMEs and favour OTAs. The position on the new search page would be even more dependent on the advertising expenses and could push small independent hotels even further down the order of results.

We would kindly ask you to let us know if you were also contacted by Google and please do let us know of your views concerning the above issue.

Suggested next steps:

• Schedule a meeting with the European Commission – ASAP – Please note that HOTREC has a meeting scheduled with the European Commissioner for Internal Market, Thierry Breton.
• Request a follow-up meeting with Google - TBC
• Reach out to associations in other sectors (airline, retail, etc.) – Ongoing