The market regulator has imposed a massive fine on Trip.com Group (9961.HK) for abusing its dominant market position. On July 25th, the State Administration for Market Regulation (SAMR) announced a penalty totaling 5.179 billion yuan, which includes confiscating illegal gains and imposing a fine.

This 5.179 billion yuan penalty comprises a 1.222 billion yuan refund of mandatory order deposits collected from hotel operators, the confiscation of 1.658 billion yuan in illegal income, and a fine of 3.521 billion yuan. The fine is 7.5% of Trip.com's China revenue in 2025, which was 46.958 billion yuan.

The fine represents roughly one-twelfth of Trip.com's total 2025 net revenue of 62.4 billion yuan, or about one-sixth of its net profit of 33.3 billion yuan. The 7.5% fine rate is the highest ever imposed in China's platform economy for anti-monopoly violations, surpassing previous penalties on Alibaba (4%) and Meituan (3%).

While this penalty is severe, it specifically targets Trip.com's "traffic control system" for merchants. Common consumer complaints like price discrimination against loyal users, unclear refund and change rules, and airline booking irregularities are not addressed in this particular punishment.

Since the start of 2026, in just six months, seven major regulatory actions have hit Trip.com, covering anti-monopoly, merchant rights, and data security. The company, which once held a 70% share of the online travel market, is now under intense scrutiny.

Hotel Merchants Trapped in a 'Traffic Control System'

Unlike the "choose-one" policies of Alibaba and Meituan, Trip.com built a hidden control system centered on traffic allocation and algorithmic tools. The company classified its partner hotels into three tiers: Platinum Card, Gold Card, and No Card. This appeared to be a tiered service system but was actually a precise traffic control mechanism.

The administrative penalty decision reveals that "Platinum Card" hotels, considered core competitive assets, received the most traffic, including search priority and cross-district display. The cost for this was exclusive cooperation with Trip.com, meaning they could not list rooms on competing platforms like Meituan or Fliggy.

Notably, this exclusivity was not written into contracts but was communicated verbally by business managers. If a hotel listed rooms on other platforms or failed to meet pricing standards, Trip.com punished them by downgrading or restricting traffic. Some hotels reported being downgraded from Gold Card status three to five times since opening, facing a 15-day to one-month traffic penalty period each time they were reduced to "No Card" status.

For "Gold Card" and "No Card" hotels without exclusive deals, Trip.com enforced a "lowest price online" rule. The penalty decision states that "Gold Card" hotels were required to offer prices 20 yuan or 5% lower than on competing platforms, with some regions demanding even larger discounts. "No Card" hotels were required to ensure their prices were not higher than on competing platforms, effectively making Trip.com the "lowest price online" option.

If a hotel's price was found to be higher on Trip.com than on a competitor, the company used technical tools like "Price Adjustment Assistant" and "Listing Pass" to directly lower the price, often without the hotel's consent. The penalty decision notes that the "Price Adjustment Assistant" was frequently forced upon merchants, activated without their knowledge, difficult to withdraw from, and would automatically re-activate after withdrawal.

One hotel reported that when the same room type sold for 100 yuan on Meituan and 98 yuan on Trip.com, it didn't meet the 5% discount requirement (95 yuan). Trip.com then deducted 3 yuan from the hotel's "Listing Pass" account, reducing their revenue. A bed-and-breakfast owner complained that after a base commission of 10-15% and hidden promotion fees like "Pyramid" and "Cloud Ladder," the total commission rate could reach 50%, leaving them with only about 80 yuan from a 200 yuan order.

A professor from China University of Political Science and Law, quoted in the Beijing Daily, stated that the "lowest price online" rule, while seemingly benefiting consumers, actually harms them. It prevents merchants from offering lower prices on other platforms, which is a real loss for consumers on those platforms. It also encourages merchants to raise prices elsewhere to offset their profit loss on Trip.com.

To enforce these rules, Trip.com used a mechanism called "order deposits." Originally meant as a reserve for handling customer complaints, this was repurposed as a punishment tool. If a hotel violated exclusive cooperation or minimum price clauses, Trip.com would deduct the deposit. The 1.222 billion yuan refund ordered by the regulator is for these forced deductions. Trip.com also used traffic restrictions and "de-listing" as further punishments.

The penalty decision concludes that Trip.com's actions, including exclusive cooperation and the "lowest price online" rule, abused its dominant market position in China's online hotel booking platform services. This improperly consolidated its market power, restricted competition, harmed hotel operators and consumers, and intensified "involution-style" competition in the industry.

The investigation determined that these actions violated the Anti-Monopoly Law by engaging in "unjustified exclusive dealing" and "imposing unreasonable trading conditions." In response, Trip.com stated on July 15th that it "sincerely accepts and resolutely complies" with the penalty and will "resolutely abandon 'involution-style' inefficient competition." The company then announced 19 rectification measures across five areas, including fully discontinuing the "Platinum Card" and "Gold Card" cooperation models, shutting down the "AI Business Assistant" (formerly the "Price Adjustment Assistant") in March 2026, stopping all price adjustment tools like "Listing Pass," and refunding the 1.222 billion yuan in order deposits.

Merchant Penalties Handled, but Consumer Grievances Remain

While the merchant-side issues have been addressed, Trip.com's consumer-facing problems remain a major point of criticism. Issues like price discrimination against loyal users, unclear refund and change policies, and misleading "paid rush ticket" services are consistently at the top of complaint lists. Users' distrust of the platform's "algorithmic black box" has never subsided.

A consumer reported spending 15,217 yuan on a flight from Beijing to New York for the World Cup in July 2026. When their plans changed, they cancelled the ticket, only to receive a refund of just 432 yuan, losing almost the entire fare. As a Black Diamond member, the consumer felt the platform should have provided better service and risk warnings, and now wonders if their membership status simply labels them as a high-frequency, low-price-sensitivity user.

Data security is another major concern. On June 13th, the Shanghai Cyberspace Administration fined Trip.com's Shanghai subsidiary 10 million yuan for violating the Data Security Assessment Measures and the Personal Information Protection Law. It was discovered that for years, Trip.com had been sending users' most sensitive personal data—including names, ID numbers, passport details, bank card numbers, and travel history—to overseas servers without completing the required security assessments. This data was used to feed its overseas business systems and data analysis platforms. Only after the regulator intervened was this data transfer halted.

In February 2026, Trip.com was involved in a 5.55 million yuan "sky-high ticket" incident. Around the same time, many users reported and shared online that prices for the same hotel room varied significantly across different accounts and search frequencies, with some examples showing a price increase of over 200 yuan in just five minutes. This sparked widespread debate about price discrimination. The platform has never provided a clear explanation for its pricing algorithm.

A brand strategy expert commented that the deep-rooted consumer problems at Trip.com are largely due to its industry monopoly. The platform leverages its massive user base to gain pricing power, its algorithms are opaque, and the cost of violating regulations is far lower than the profits gained. Consumers find it difficult to gather evidence and costly to seek redress, allowing problems like price discrimination and misleading advertising to persist. The expert believes that Trip.com's data violations, anti-monopoly investigations, and multiple regulatory meetings are not isolated events, but rather symptoms of a systemic failure in corporate governance that prioritizes rapid expansion over compliance.

Interestingly, while Trip.com was not fined specifically for price discrimination, its announced rectification measures include a commitment to "prevent the risk of price discrimination," promising to use algorithms ethically and fully protect consumer rights.

How Should the Platform Develop Properly?

The 5.179 billion yuan fine is the seventh major regulatory action against Trip.com in 2026 alone. This year has seen actions ranging from an anti-monopoly investigation in January to joint regulatory meetings in February, March, April, and June, covering data security, monopoly concerns, and consumer rights. These actions have created a comprehensive compliance framework that covers every major aspect of the company's operations.

A financial expert noted that the new regulations implemented in 2026, such as the "Rules for the Supervision and Management of Online Trading Platform Rules" and the "Rules on Price Behavior of Internet Platforms," have moved from general principles to specific, traceable technical details regarding algorithm pricing and traffic allocation. Multi-agency coordinated enforcement has also become the norm.

The "Rules on Price Behavior of Internet Platforms," which took effect on April 10, 2026, clearly prohibit platforms from improperly restricting merchants' pricing. They ban practices like forcing or indirectly forcing merchants to offer lower prices on a specific platform than elsewhere, and explicitly prohibit price discrimination against consumers. The rules forbid using data and algorithms to set different prices for the same product under identical transaction conditions without the consumer's knowledge.

Trip.com's repeated issues with data security, monopolistic behavior, and consumer problems reveal a systematic deviation in the company's long-term development path and governance logic. Founded in 1999 by Liang Jianzhang, Ji Qi, Neil Shen, and Fan Min, Trip.com quickly became the industry leader. Over 20 years, the founding team has gradually stepped back from daily operations. Liang remains Chairman, Neil Shen is an independent director, and Ji Qi and Fan Min resigned from the board in February 2026. The founding team's presence in management has steadily diminished.

A key driver of these problems is the company's dependence on a rapid-growth path built on traffic monopoly. Holding nearly 70% of the domestic online travel market, Trip.com has long controlled traffic distribution and pricing, creating a profit loop based on commission income. To maintain growth and strengthen its competitive barriers, it tightened constraints on merchants through exclusive deals and pricing tools, while using algorithms to implement dynamic pricing for consumers. This "size-first, growth-above-all" logic has led to merchant rights, user experience, and compliance requirements being consistently sacrificed for performance goals, eventually leading to a crisis.

The lack of priority given to compliance within the company's internal governance is a key factor. The expert believes that Trip.com's data violations and anti-monopoly investigations are not isolated incidents but a direct result of a corporate governance system that has long overlooked compliance in favor of a rapid expansion model driven by market dominance. Under a performance-oriented evaluation system, the compliance department has had little say in business decisions, and past rectification efforts have been superficial, failing to address the core issues of the profit model and business logic.

Liang Jianzhang's 'Demographer' Persona

While Trip.com has been facing these mounting operational and regulatory challenges, its founder and spiritual leader, Liang Jianzhang, has dedicated significant energy to demographic economics. He frequently speaks publicly on issues of fertility and population structure, leaving the company's daily operations to the team led by CEO Sun Jie.

As Liang's comments on population issues have become more widely circulated, his identity as a "demographer" has become more prominent. In recent years, he has increasingly presented himself as a "population expert" rather than as the chairman of Trip.com. In 2025, he personally established the "Genesis Fund" in Hong Kong, planning to invest about 500 million Hong Kong dollars over five years to explore solutions for low fertility rates from the angles of economic subsidies, cultural advocacy, and policy research.

In 2026, his column on a major news site has published several research commentaries on topics like the fertility crisis in the AI era, suggesting allowing single women to use assisted reproductive technology, and discussing the role of fathers in childcare. Liang has a separate Weibo account focused on population issues, with a disclaimer stating his views are not related to Trip.com.

Some of his public statements have been controversial. He has suggested that young people who can't find work should pursue more education or get married and have children. He has also argued that China's high female workforce participation rate leads to the world's lowest fertility rates in big cities, a claim that was directly criticized by the China Women's News. His suggestion to shorten the education system to allow girls to work and marry earlier has been interpreted by some netizens as a push to further pressure women.

A business expert believes that as a public figure and the soul of Trip.com, Liang's controversial statements on social issues inevitably affect the company. This creates a risk for Trip.com's reputation and stable operations. The expert notes that Liang must find a way to balance his role as a scholar commenting on public issues with his responsibility as a core corporate leader to avoid creating risks for his company.

Given the trend of increased regulatory oversight, a deep adjustment at Trip.com is now unavoidable. For Liang, refocusing on his core business should be a priority. As the company's spiritual leader, he needs to balance his personal interests with his professional duties, investing more energy in navigating Trip.com's current difficulties. For the company to truly overcome its compliance crisis and achieve long-term, stable development, it must learn from this painful experience. It needs to break free from its dependence on a traffic monopoly, integrate compliance requirements into all its business processes, and find a balance between commercial profits and the health of the industry ecosystem.