Booking.com is one of the most important distribution channels for independent hotels. It can introduce a property to international guests, generate bookings that would otherwise be difficult to acquire and make the reservation process easier for people who have never heard of the hotel before.
That dependence comes with a trade-off. The hotel benefits from the platform’s reach, but it does not control every aspect of how its property is presented, how guests interact with the platform or how the commercial relationship works.
The European Commission’s decision to open formal proceedings against Booking.com under the Digital Services Act (DSA) brings several of these issues into focus. The investigation concerns three areas: fraudulent accommodation listings, phishing scams involving reservation and guest data, and paid-for boosted listings that may not be clearly identified as advertisements.
None of this means that the Commission has established that Booking.com breached the law. The proceedings are intended to determine whether the platform has complied with its obligations. Nevertheless, the issues under investigation raise questions that hotel owners should be considering regardless of the eventual outcome.
For an independent hotel, the implications extend beyond regulatory compliance. They concern the trust guests place in the booking process, the risks associated with reservation data, the cost of visibility and the degree of control a property retains over its commercial relationships.
When a guest cannot tell which booking is legitimate
The first area under investigation concerns fraudulent and non-compliant accommodation listings, including fictitious properties and impersonation fraud.
For a traveller, the immediate risk is obvious. Someone may pay for accommodation that does not exist or believe they have booked with a legitimate property when the offer is fraudulent. The consequences can include financial loss, disrupted travel and the difficulty of finding alternative accommodation at short notice.
For a legitimate hotel, the implications are less direct but potentially significant.
Imagine a traveller who encounters a fraudulent listing, loses money and subsequently becomes more cautious about booking accommodation online. That experience may affect their willingness to trust not only the platform but also the properties they discover through it. Even a hotel with impeccable practices operates in an environment where confidence in the wider booking ecosystem influences purchasing decisions.
There is also a reputational dimension. Guests do not always distinguish clearly between the platform that facilitated a transaction and the accommodation provider they believed they were dealing with. If something goes wrong, the hotel may find itself answering questions about a booking it never received or a payment it never requested.
This is one reason why the integrity of a distribution channel matters to hotels beyond the number of reservations it generates. A channel is not simply a mechanism for putting rooms in front of potential guests. It also establishes expectations about the legitimacy of the offer, the security of the transaction and the reliability of the information presented.
Hotels cannot independently police every listing on a major platform. They can, however, make sure their own identity is consistent across their official website and distribution profiles, explain clearly which payment methods and communication channels they use, and give guests a reliable way to verify suspicious requests.
These precautions do not eliminate platform-level fraud. They reduce the ambiguity that makes impersonation more convincing and give guests a reference point when something does not look right.
Phishing: the reservation does not end when the guest clicks Book
The second area concerns phishing scams that exploit reservation and guest data, including the way information is shared with accommodation providers and the design and functioning of Booking.com’s messaging service.
This issue deserves particular attention from hotel owners because a reservation contains information that can make a fraudulent message appear entirely credible.
A guest may know the property name, arrival date, room category and approximate cost of their stay. If a message refers to these details and asks them to verify a payment method or complete an additional payment, it may appear to be a legitimate part of the reservation process.
The danger is not necessarily that the message looks obviously suspicious. It is that it contains enough accurate context to make the request believable.
The Commission is investigating whether Booking.com has adequately assessed and mitigated risks associated with reservation data and messaging. The opening of proceedings does not establish how any particular incident occurred or who was responsible for it. It does, however, underline a vulnerability that accommodation providers should take seriously: information exchanged during the booking process can potentially be exploited to make fraudulent communications more convincing.
Hotels should therefore review how staff access reservation information, how account credentials are protected, who can communicate with guests and what procedures apply when a guest reports a suspicious message.
Staff need a clear process for handling payment-related questions, particularly when a guest claims to have received a request to pay through an unfamiliar link. Guests should be told how to verify a request independently rather than being encouraged to trust a message simply because it contains accurate booking details.
It is also worth examining the hotel’s own communication practices. If the property routinely sends guests payment links, requests card verification or changes payment arrangements through informal messages, it may be creating confusion that makes fraudulent requests harder to recognise.
A consistent policy is easier to explain and easier for guests to trust. Any legitimate exception should be handled through a verifiable process, not improvised by individual employees.
The hotel should also avoid assuming that a suspicious message originated with the platform, the property or a particular member of staff before the incident has been investigated. The immediate priority is to protect the guest, establish what happened and follow the appropriate reporting procedures.
The visibility problem: when a higher ranking is something you buy
The third area under investigation is particularly relevant to the commercial decisions hotels make every day.
According to the Commission, accommodation providers can increase the visibility of their listings in Booking.com’s search results by paying a higher commission. The investigation will examine whether these boosted listings are clearly identifiable as advertisements and whether the platform provides the advertising transparency required by the DSA.
The underlying question is straightforward: when a property appears prominently in search results, can the user understand whether that position reflects the relevance of the listing, a paid promotional arrangement or some combination of factors?
For the hotelier, the question is slightly different. What is the property actually buying when it pays for additional visibility?
A higher position may expose a hotel to more potential guests. That can be commercially valuable, particularly in a competitive destination or during a period when demand is weak. Yet increased exposure does not automatically translate into incremental bookings, and incremental bookings do not automatically justify the additional cost.
A hotel may receive more visibility because it has increased its commission, but the additional bookings could include guests who would have selected the property anyway. Alternatively, the higher position may help the hotel reach travellers who would otherwise have chosen a competitor. Those two outcomes can look similar in a basic booking report while producing very different commercial results.
The distinction matters because distribution costs are not just accounting details. They affect the contribution each reservation makes to the business and the resources available for other ways of attracting guests.
A hotel should therefore evaluate a visibility boost by looking at the additional business it generates, not merely the total bookings attributed to the platform while the boost is active. The relevant comparison is what happened with the additional visibility against a reasonable estimate of what would have happened without it.
That is not always easy to measure. Demand fluctuates, competitors change their pricing, seasonality affects conversion and several distribution activities may operate at the same time. Even so, the difficulty of measuring incremental performance is not a reason to assume that paying for a higher position is automatically worthwhile.
The Commission’s investigation concerns advertising transparency and platform obligations. It does not establish that Booking.com’s boosted listings are commercially ineffective or that the platform has already been found in breach of the DSA. For hotel owners, the immediate lesson is to distinguish the cost of obtaining visibility from the value of the business that visibility actually produces.
The OTA is not necessarily the problem
It would be easy to read this news as another argument against dependence on online travel agencies. That would miss the point.
OTAs can provide genuine value. They offer international reach, familiar booking processes, comparison tools, payment infrastructure and access to travellers who might never discover an independent hotel through its own marketing. For some properties and markets, that reach is commercially difficult to replicate.
The issue is not whether an OTA should be used. It is whether the hotel understands the role the channel plays, the costs attached to it and the risks it introduces.
This is the distinction explored in Your OTA Isn’t Necessarily the Problem. An OTA booking is not automatically a lost direct booking, just as a direct booking is not automatically more profitable in every circumstance. The commercial value depends on where the guest came from, what it cost to acquire the reservation and what would probably have happened without that channel.
The same reasoning applies to paid visibility. A hotel should not reject it simply because it costs more, nor should it accept the additional cost without understanding what it contributes.
The investigation does not tell hoteliers to abandon Booking.com. It is a reminder that relying on a platform makes it important to understand the relationship rather than treating the channel as a black box.
What happens when the guest compares the OTA with your own website?
The investigation also highlights a broader question about the relationship between the platform and the accommodation provider.
Booking.com controls important parts of the environment in which guests discover, compare and reserve accommodation. The hotel contributes its rooms, photographs, descriptions, policies, availability and pricing, but it does not control the entire experience.
That distinction becomes commercially relevant when a guest moves between the OTA and the hotel’s official website.
A traveller may discover a property on Booking.com, visit the official website to learn more, compare conditions and eventually complete the reservation on the platform. The hotel might interpret the final transaction as evidence that the OTA performed well. That may be true, but it does not explain why the guest preferred to book there.
Perhaps the OTA made the conditions easier to understand. Perhaps the hotel’s website did not communicate the differences between room categories clearly enough. Perhaps the cancellation terms were more reassuring, or the booking process involved fewer steps. There may also have been no meaningful advantage to booking directly.
Without examining the decision, the hotel cannot distinguish between these possibilities.
The article Why Booking.com Can Be Better at Selling Your Hotel Than You Are explores this problem in more detail. The point is not that the OTA should necessarily lose the booking. It is that the hotel should understand what makes the platform effective and whether its own commercial experience is helping or hindering the guest’s decision.
This becomes even more important when the hotel is paying additional commission to secure visibility. If the platform generates the initial interest, the guest then visits the official website, and the reservation ultimately returns to the OTA, the hotel needs to understand the entire sequence before deciding which part of its distribution strategy deserves more investment.
What hotel owners should review now
The investigation is a reason to review existing practices, not to assume that every hotel using Booking.com faces the same level of risk. The appropriate response depends on the property’s systems, payment arrangements, staffing and exposure to different types of fraud.
There are four practical areas worth examining.
First, verify the hotel’s identity across channels. Ensure that the official website, OTA listing and guest communications use consistent property information and legitimate contact details. Make it easy for guests to confirm that they are dealing with the real hotel.
Second, review payment and messaging procedures. Define how payment requests are issued, how changes are verified and how staff respond to suspicious messages. Make sure guests can verify a request independently, especially when it involves a new payment link or an unexpected change to the agreed terms.
Third, protect access to reservation information. Review account permissions, staff access, authentication and procedures for handling guest data. Employees should know how to report suspected account compromise or phishing without delaying action to protect affected guests.
Fourth, assess the commercial value of paid visibility. Record the additional cost, monitor the results and compare performance against a credible baseline. Where possible, distinguish genuinely additional business from bookings that may simply have shifted between channels.
These measures will not resolve every risk associated with a large booking platform. They do, however, give hotel owners a clearer view of the parts of the relationship they can influence.
They also help separate two conversations that are often mixed together: whether the platform is meeting its legal obligations, and whether the hotel’s own use of the platform makes commercial sense.
The wider lesson: control what you can, understand what you cannot
The European Commission’s proceedings against Booking.com are still ongoing. The investigation may lead to further enforcement steps, commitments or a finding of non-compliance, but opening formal proceedings does not prejudge the outcome.
For hoteliers, waiting for the final decision before reviewing their own practices would be unnecessary. Fraud prevention, clear payment procedures and sensible management of distribution costs are worthwhile regardless of how the investigation concludes.
There is also a strategic lesson. A hotel cannot control how a major OTA ranks every property, how the platform designs its messaging system or how it fulfils its regulatory obligations. It can control the consistency of its own information, the security of its own processes, the clarity of its communication and the way it evaluates the commercial results of each channel.
That is not an argument for eliminating intermediaries or assuming that direct bookings are always preferable. It is an argument for understanding the relationship well enough to make informed decisions.
The more a hotel depends on a platform, the more important it becomes to know what that platform contributes, what risks accompany the relationship and which parts of the guest’s decision-making process remain within the hotel’s own control.
Booking.com may remain an important part of the distribution mix. The real question is whether the hotel is using it deliberately, with a clear understanding of both the commercial benefits and the responsibilities that come with the arrangement.
