INTERNATIONAL JOURNAL OF TOURISM, TRAVEL AND HOSPITALITY LAW regarding transparent, clear and comprehensible information that must be directly and easily accessible, problems may arise in practice because of unclear criteria for the assessment of transparency.137 Problems may also arise when assessing whether the provider of online marketplaces has actually provided all general information, which parameters are considered to be most important, how is the relative importance of parameters determined and how is the accessibility of information assessed. Special problems may be caused by particular types of products and services offered via marketplaces, because of which the content of information, the method of presenting parameters and reviews are often completely different. Finally, some problems may also arise in connection with the protection of users of online markeplaces due to decentralised public or private enforcement of measures in the case of infringement of EU rules on information duties provided for in various EU directives and regulations. Modernisation of information requirements brought about by the Omnibus Directive is an important but only the first step towards proper consumer protection on the digital market, including the tourism services market. There are still many challenges before the European legislator involving efficient protection of consumers and all other participants on online marketplaces. We expect that in the future, the concept of information duties will remain one of the most important aspects of ensuring full transparency of the online market. However, information duties require a systematic and consistent codification. It would be very useful to consider whether, for particular sectors of the online market, special rules on information duties ought to be developed, adjusted to the specificities of these sectors (depending on the importance of particular pieces of information for the selection of products and services, as well as for the protection of online market users). For example, the ranking and the reviews play a more important role in the selection of tourism services than in some other sectors. Therefore, it would be useful to lay down some rules on providing detailed information about the ranking parameters and the way of posting reviews on the offered tourism services. Similarly, the information on a particular tourism sector should be adjusted to the circumstance that services on the online market are often offered by private persons not having the capacity of traders. Currently, the rules on information duties of providers of online marketplaces are the only European instrument to ensure a harmonised provision of information for consumers in peer-to-peer tourism services. 137 See Hiwatashi Dos Santos, G. (2020), p. 88.
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