Italy's antitrust regulator has levied a substantial fine of €255 million against Ryanair this Tuesday, citing the airline's exploitation of its market dominance to restrict travel agencies' access to its services.
Ryanair, which handles approximately 40% of passenger traffic to and from Italy, was found to have implemented technical barriers and booking limitations that effectively marginalized travel intermediaries from the market.
"Following a complex investigation, the Authority found that Ryanair put in place an elaborate strategy affecting the ability of online and traditional travel agencies to purchase Ryanair flights on ryanair.com," according to a statement by the Authority.
The company's approach "blocked, hindered or made such purchases more difficult and/or economically or technically burdensome when combined with flights operated by other carriers and/or other tourism and insurance services."
Significance of Travel Intermediaries
In markets where a single service provider holds substantial power, intermediaries serve as crucial buffers between consumers and dominant companies. These platforms provide essential functions like search results, booking capabilities, comparison tools, and price aggregation.
When these intermediaries face restrictions or elimination, consumer choice diminishes, comparison opportunities decrease, and dominant firms face reduced pressure to maintain competitive practices.
Ryanair's Restrictive Measures
Beginning in April 2023, Ryanair introduced facial-recognition checks and additional verification requirements specifically targeting bookings made through travel agencies, while direct customers experienced minimal disruption.
These measures increased costs, reduced reliability, and slowed transaction times for agency sales, discouraging consumers from using intermediary services and undermining agencies' competitive capabilities.
Ryanair further obstructed agency access by periodically blocking travel agencies from its booking platform, disabling payment methods, and mass-deleting accounts associated with online travel agencies.
Since Ryanair flights represent essential components for agencies offering travel packages to Italy, these actions effectively prevented normal business operations. The Authority determined Ryanair had moved beyond competition to actively denying market access.
The airline also pressured agencies into restrictive partnership agreements that limited their ability to combine Ryanair flights with services from other airlines, accommodation providers, insurance companies, or tourism operators—core elements of agency competition.
To enforce compliance, Ryanair reinstated booking blocks and launched "aggressive communication campaigns" against non-compliant platforms, labeling them "pirate OTAs." This further distorted competition by reducing agencies' commercial flexibility and narrowing consumer options.
Competition Law Violations
While market dominance itself isn't prohibited under competition law, abuse of that position—through exclusionary practices, imposition of unfair conditions, or restriction of related market operations—constitutes violation.
The Authority concluded Ryanair leveraged its dominance in air transport to undermine competition in travel and tourism services. By creating economic and technical burdens for agencies selling Ryanair flights, particularly when combined with other services, the airline weakened competition, reduced consumer choice, and distorted market structure.
Digital markets tend to concentrate power rapidly. When one company becomes the default option—whether through pricing, scale, or recognition—other market participants must adapt to its framework.
As access to that company's products becomes essential, its decisions regarding sales channels, distribution methods, and service combinations cease being private business choices and begin shaping the entire market landscape.
Competition authorities intervene at this critical juncture, recognizing early indicators of structural market lock-in before significant damage occurs. Intermediaries remain vital for introducing comparison, choice, and competitive friction into such systems—their removal fundamentally undermines market competitiveness.
