eu travel tech Position Paper – Multimodal Digital Mobility Services

Objectives

Facilitating multimodal digital mobility has long been a core objective of EU transport policy, reaffirmed through recent high-level political commitments such as the Sustainable and Smart Mobility Strategy and President von der Leyen’s 2024 Political Guidelines. Within this context, the European Commission is developing a legislative proposal on Multimodal Digital Mobility Services (MDMS), aimed at improving access to distribution channels and ensuring fair competition across digital mobility platforms.

Need for clearly defined scope

eu travel tech supports the overarching goal of enhancing multimodal travel. However, we have significant concerns regarding the current conceptual framing and assumptions underlying the MDMS initiative. Chief among these is the problematic conflation of fundamentally distinct market actors—ranging from Online Travel Agencies (OTAs) and metasearch engines to Travel Management Companies (TMCs) and Global Distribution Systems (GDSs)—under a single, ill-defined “MDMS” label, misrepresenting market dynamics and introducing regulatory misalignment.

Focus on supposed market issues arising from MDMS is misplaced

Our core concern lies in the Commission’s assertion that independent MDMS providers hold currently “significant market power” and that such market power warrants regulatory intervention. In practice, it is dominant transport operators—especially incumbent railways and airlines—that exert disproportionate control over ticket distribution, often refusing access to third-party platforms or attaching unreasonable or discriminatory conditions to access. Contrary to the initiative’s premises, independent MDMS do not restrict access or distort information; rather, they are subject to exclusionary practices that reduce consumer choice and stifle competition.

Need to consider adverse effects of blanket obligations

eu travel tech cautions against blanket obligations such as mandated “neutral display” or thresholds based on unclear user metrics. Instead, we urge for a more evidence-based regulatory approach that distinguishes between vertically integrated (such as Deutsche Bahn Navigator) and independent MDMS (such as Omio) and avoids replicating legacy regulatory models which restrict consumer choice and individualization in manner unfit for the digital age of ticket distribution.[1] Emphasis should instead be placed on ensuring fair access to content and promoting a genuinely competitive, consumer-centric distribution landscape.

Key recommendations

• Ensure that MDMS obligations are proportionate by narrowing the initiative to address the clear market issues arising from practices of MDMS with actual market power.
• Reassess the market in airline distribution to determine where the genuine market failure lies. This will show that it is airlines, and not intermediaries, who are stifling competition by making it harder for their fares to be shown beyond their own direct channels. Reconsider whether a strict regulation of independent MDMS is necessary and assess which negative effects it may produce.
• Repeal the outdated CRS CoC and refrain from extending its legacy framework, instead follow guidance by expert groups to enable real consumer choice and competition in the MDMS market, for example by facilitating choice through mandatory filter options.
• Consider the possible negative impact on consumers and competition arising from any obligations to distribute transport services for vertically integrated distribution channels