Sarah Prager, Competition Law - OTAs and airlines

(3) Compared to booking with a traditional travel agent, OTB allows consumers to book the holiday of their choice quickly and efciently at any time of the day or night, without needing to visit the agent in person, or deal with the agent by phone during ofce hours or through protracted email communications. (4) Further, unlike many providers, including Ryanair: (a) OTB holds customer monies in a ring-fenced trust account; (b) OTB package holidays are also ATOL-protected (which ensures that OTB Customers would not lose money, or become stranded abroad, were OTB to collapse); (c) OTB manages customers’ holidays on their behalf. For example, if the time of a fight changes, OTB will automatically reschedule the transfer; (d) OTB vets the travel service providers with whom it works for quality, and can sometimes ofer prices not available to consumers when they book directly; (e) OTB customers are able to pay for their holidays in instalments. (5) More generally: (a) Price comparison services such as OTB increase transparency, and so increase competition among travel service providers, resulting in lower prices for consumers, as well as increased transparency and, therefore, choice; (b) Increased competition from online travel agencies such as OTB lead to greater benefts to consumers generally. For example, OTB operated a promotion whereby it arranged free Covid-19 tests for its customers.

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