ECTAA calls for broader access to tariffs and content: EU Passenger Package opens a new battle over distribution
The European Commission wants to make it easier for travellers to compare and book multimodal journeys. ECTAA supports this objective, but warns of a problem which well known to travel agencies and TMCs: the comparison is only valid if the distributor has access to the offers to be compared.
In May, the European Commission presented the Passenger Package, a set of new rules aimed at simplifying the booking of journeys involving multiple operators and different modes of transport. The ambition is quite clear – a passenger should find it easier to find, compare and book an entire journey, especially when it involves several rail operators or a combination of different modes of transport.
The problem is that today's market is still nowhere near such a model. The Commission's analysis of 100 representative routes in the European Union showed that a multimodal option existed in 76 percent of cases. However, very few digital platforms displayed offers of different modes of transport together, and even fewer enabled them to be actually combined.
It was precisely at that point that he got involved ECTAA, which represents around 80,000 European travel agencies and tour operators. The association is calling on the European Parliament and the Council to amend the proposal before the new regulatory framework takes its final shape.
Agencies can only compare what they have access to
ECTAA's main argument is simple and very practical. If a travel agency, OTA or other booking platform does not have access to a specific fare, availability, ancillary service or post-booking servicing function, then it cannot show the traveller the complete offer.
Because of this, the association is demanding that fair, reasonable and non-discriminatory—that is, FRAND—conditions are applied more consistently where carriers control content without which it is difficult to make a genuine comparison. This should not apply only to rail transport. According to ECTAA, the same logic should apply regardless of whether the user travels by train, plane, bus or combines several modes of transport.
That is actually the core of the debate. European regulation can mandate a more transparent interface and better result ranking, but if an individual distribution channel only receives a fraction of the content, the user is still not comparing the entire market.
NDC shows why this is not just a railway matter
Aviation is of particular interest to agencies and TMCs. In recent years, airline ticket distribution has gradually moved away from the model where almost all relevant content was available through the same systems.
NDC and direct connections with airlines have given carriers much greater control over how they distribute fares, branded fares, seats, baggage and other ancillaries. At the same time, the offer available through one channel does not always have to be identical to the one the traveller sees on the carrier's website or through another distribution system. ECTAA has also warned about this difference in access to content.
That does not mean that NDC in itself is a problem. For many airlines, NDC is precisely what has enabled a richer product offering and more modern retailing. However, from an agency perspective, another question arises: how transparent is the market really if products, prices and servicing functions differ depending on the distribution channel?
The Commission's proposal already tries to regulate part of that space. The new rules for multimodal digital mobility services provide, among other things, for a more neutral display of offers and rules on ranking criteria. The proposal also restricts the possibility of a paid position simply becoming the default ranking criterion.
ECTAA does not want Brussels to dictate what every search must look like
Here ECTAA partly diverges from the Commission's approach. The association supports transparency: a traveller should know why an offer is shown to them first and whether a better position is the result of a commercial arrangement.
No believes that the regulator should not be too prescriptive about how the specified presentation of results must look.
The reasoning makes sense from a travel industry perspective. The cheapest option is not always the best. For a business traveller, the duration of the journey, the reliability of the connection or the flexibility of the ticket may be more important. A leisure guest might give priority to price. Someone else might want fewer changes. If all distributors are forced to use almost the same ranking model, the scope for developing different booking products becomes smaller.
ECTAA therefore wants mandatory transparency of the criteria, but more freedom in how each platform will use them.
Who will control the relationship with the passenger?
The second sensitive part of the proposal relates to the railway platforms.
The Commission wants to make it easier for passengers to book journeys involving multiple operators and to be able to buy such a ticket through a platform of their own choosing. This could remove one of the biggest barriers to the development of international rail travel in Europe.
ECTAA, however, warns that this should not further strengthen the position of dominant platforms belonging to large rail companies. If their platforms were to become the main place where competitor products are also sold, they would gain even greater access to customers, data and the sales funnel.
The association therefore advocates a different logic: opening up content to various platforms and independent distributors, instead of concentrating an even greater share of sales on the platforms of existing major operators.
For travel agencies, this is not a technical detail of European regulation. It is about who will have access to the product in the future, who will be able to combine it with other services and, ultimately, who will have the relationship with the traveller.
That is precisely why the Passenger Package is a broader story than just train tickets. If Brussels succeeds in creating a model where carriers open up their content, and independent distributors can genuinely compare and combine offers, agencies and TMCs could take on a new role in selling more complex multimodal journeys.
If access to content remains fragmented, a traveller may end up with more booking platforms than they do today, but they will not necessarily have a better overview of the market.
