eu travel tech Position Paper – Single Digital Booking and Ticketing Regulation

Objectives

The Single Digital Booking and Ticketing Regulation (SDBTR) presents a critical opportunity to address long-standing market failures in transport distribution by promoting fair, open access to content across modes. eu travel tech supports the Commission’s ambition to enable seamless, multimodal journeys, but underscores that this goal cannot be achieved without comprehensive regulatory obligations extending beyond rail to include air travel.

The European Commission has correctly identified a significant problem when it comes to digital ticketing: independent distributors play a vital role in enhancing consumer choice and transparency, yet they are increasingly hindered by exclusionary practices by dominant transport operators. These operators leverage their market power to restrict access, impose unfair terms, and self-preference their own sales channels, undermining competition and limiting passengers’ ability to compare and combine offers across providers and modes. The SDBTR proposal includes measures that address this problem efficiently, i.e. the obligation for dominant transport operators to negotiate with independent vendors based on FRAND terms. Fair, reasonable and non-discriminatory terms are especially important when it comes to remuneration and data access, both of which we understand the European Commission aims to address in the proposal.

Need to extend scope

Because the SDBTR proposes the right obligations for incumbent operators, the exclusion of air carriers would be a missed opportunity. Given air travel’s essential role in long-distance and cross-border mobility, its integration into the framework is indispensable. The regulation must enshrine content access under fair, reasonable, and non-discriminatory terms to ensure a level playing field.

Only with consistent, mode-neutral content access rules can the SDBTR deliver on its promise to support sustainable, competitive, and consumer-centric multimodal mobility across Europe.

Key recommendations

• Address access of independent ticketing platforms to the content of indispensable rail operators, ensuring an end to exclusionary practices and more consumer choice.
• Extend the scope of obligations for indispensable transport operators to modes beyond rail, most notably air, thereby facilitating modal shift and integration and addressing equally anti-competitive and anti-consumer practices by indispensable (air) carriers.
• Proposes clear and comprehensive FRAND obligation, providing a flexible for solid legal standards for issues including content access and remuneration, supported by a strong enforcement framework.