Regulation (EC) N° 80/2009 on a Code of Conduct for Computerised Reservation Systems (CRS CoC) is currently being reviewed. The past months, EPF has been participating in the impact assessment study and accompanying public consultation. For EPF, this Regulation is important because it intends to safeguard consumer access to neutral and unbiased information about available travel options and prices. 

As you may have experienced yourself, it has become increasingly difficult for passengers, even experienced ones, to compare offers and prices across airlines. A search for a specific city-to-city travel through an online travel agent (e.g. Expedia, eDreams), a meta-search engine (e.g. Google Flights, Kayak) or an airline’s own website may yield very different results. Not all fares are available on all distribution channels, quoted prices for the same trip vary and there is no like-for-like comparison (sometimes ancillary services such as luggage or seat reservation are included in the basic price and sometimes they are not).

This is why we believe that the principles underlying the Regulation – transparency, fair competition, neutral display, enabling passengers to make an informed choice – should be applicable to distribution channels other than traditional CRSs as well. More and more passengers look for and buy tickets through channels other than (those served by) traditional CRSs. It would make sense to have the same rules apply to all travel distribution channels, not only from a customer’s point of view but also to stimulate fair competition and have a level playing field, between these different channels and also between operators.

Indirect distribution services can include also smaller carriers in the overview which might otherwise not get as much exposure (this is likely to become even more important in the future due to increased airline consolidation, a trend exacerbated by Covid-19). Having a neutral display helps to ensure fair competition and to create a level playing field between operators, on the condition that there is a like-for-like comparison (increased unbundling of ancillary services has unfortunately led to a decrease in price transparency – a topic that is also addressed in the review of the Air Services Regulation (EC) No 1008/2008 – see our position paper).

Regarding the final price for customers, EPF notes that:

• Firstly, the final price should be clear from the start of the booking process, including all unavoidable and foreseeable costs.
• Secondly, financial compensations for using data or making them available (on both the side of operators and the side of intermediaries) should be kept reasonable, to avoid that having a good overview of travel options (in itself desirable) would result in (significantly) higher prices for end-users.

Since the entry into force of Regulation (EU) 2019/1150 on promoting fairness and transparency for business users of online intermediation services (P2B Regulation), all online information and booking platforms need to be transparent on how the results are ranked; however a neutral display (i.e. ranking based on objective criteria, or criteria that the passengers can decide on for themselves, e.g. accessibility or environmental impact) is preferable in EPF’s view and right now this is only an obligation for CRSs. EPF therefore suggests to widen the scope of the CoC to other, similar, distribution channels and even expand it to channels covering other modes (multimodal CRS CoC).

Indeed, we feel that the multimodal potential of the CRS Code of Conduct has not yet been fully exploited. Currently the Regulation applies only to air (and air-rail) travel, but not to “rail-only” services. The Code of Conduct could serve as a model for Computerised Reservation Systems (and other online channels that enable travellers to compare and reserve their travel) for other modes as well. From a modal shift / decarbonisation perspective, it is important to encourage the participation of modes other than air (long-distance rail and coach) in CRSs.