Analysis of Ctrip's Response Strategies to Antitrust Investigation

Based on the latest market information, I have systematically organized the situation of Ctrip’s response to the antitrust investigation by the State Administration for Market Regulation (SAMR).

On January 14, 2026, the State Administration for Market Regulation (SAMR), in accordance with the Anti-Monopoly Law of the People’s Republic of China, officially initiated an investigation into Ctrip Group Limited on suspicion of abusing its dominant market position to engage in monopolistic practices[1]. This investigation is not a sudden move; the regulatory authorities have conducted sufficient preliminary verification, fact-finding investigations, and evidence collection[2].

1. Controversy over the “Price Adjustment Assistant” function
   : Ctrip uses technical means to directly modify the room pricing of partner hotels in the background. Hotel merchants have reported that they cannot independently disable this function, with price adjustments reaching up to 5 times a day, which seriously erodes merchants’ profit margins[3]

2. Exclusive Dealing (Choose-One-From-Two) Clause
   : Ctrip is accused of requiring contracted hotels not to list their products on other competing platforms, otherwise they will face traffic restrictions or commission increases[4]

3. High Commission System
   : Ctrip’s publicly stated basic commission ratio is 10%-15%, but merchants need to pay various additional fees to obtain better exposure positions, and the actual comprehensive cost may be close to 40%[5]

4. Controversy over Big Data-Enabled Price Discrimination Against Regular Users
   : Consumers have complained about price discrimination against long-term customers on the platform. As of January 2026, the number of complaints involving Ctrip on the Black Cat Complaint Platform has exceeded 160,000[6]

In response to the regulatory investigation, Ctrip quickly issued an official statement, with the core points as follows[7][8]:

• Actively cooperate with the investigation
  : Clearly stated that it will cooperate with the regulatory authorities’ investigation and fully implement regulatory requirements
• Statement on stable operations
  : Emphasized that all of the company’s businesses are currently operating normally
• Service commitment
  : Stated that it will continue to provide high-quality services to users and partners
• Industry co-construction
  : Committed to working with all parties in the industry to build a sustainable market environment

After being interviewed by local market supervision authorities, Ctrip made the following rectification commitments[9]:

• Carry out thorough rectification of issues such as “mandatory activation and inability to opt out”
• Correct all types of unreasonable restrictive behaviors
• Fully respect the independent operation rights of merchants
• Strictly prohibit using technical means to manipulate prices or restrict transactions in disguised forms
• Truly respect the independent pricing rights of merchants

After the news of the investigation was announced, Ctrip was immediately hit significantly in the capital market[10]:

Market	Stock Performance
Hong Kong Stock Exchange Closing Price	Dropped 6.49%
US Pre-market Trading	Once fell by over 15.70%
Hong Kong Stock Exchange Opening Price the Next Day	Fell by over 20% during intraday trading

According to Article 57 of the Anti-Monopoly Law of the People’s Republic of China[11]:

Where an operator abuses its dominant market position, the anti-monopoly law enforcement agency shall order it to stop the illegal acts, confiscate its illegal gains, and impose a fine of not less than 1% but not more than 10% of its sales revenue in the previous year.

• In 2021, Alibaba was fined CNY 18.228 billion for exclusive dealing (choose-one-from-two)
• Meituan was fined CNY 3.442 billion for the same reason
• CNKI (China National Knowledge Infrastructure) was fined CNY 87.6 million

Considering that Ctrip’s net profit in the third quarter of 2025 reached CNY 19.9 billion, the potential fine may amount to billions of yuan.

This antitrust investigation may have far-reaching impacts[12]:

1. Reshaping of Industry Competitive Landscape
   : Small and medium-sized merchants are expected to gain more development space
2. Improvement of Consumer Rights and Interests
   : Users may face a more fair and transparent consumption environment
3. Normalization of Platform Economy Supervision
   : Marks the expansion of antitrust supervision from the consumer side to the supply side
4. Algorithm Governance Becomes a Focus
   : Compliance reviews of platform technical means will be more stringent

Ctrip’s current response strategy generally presents a posture of

, mainly adopting the following measures:

1. Proactive cooperation posture
   : Demonstrates sincerity in cooperating with regulatory authorities
2. Stabilize market confidence
   : Emphasizes normal operations to reassure investors
3. Await specific charges
   : Does not make substantive rectification commitments before the regulatory authorities officially confirm the illegal acts

A research report from Huatai Securities pointed out that the antitrust investigation and compliance rectification faced by Ctrip may put pressure on its profit growth in the next 1-2 years, and intensified industry competition may trigger price wars that further erode profit margins.

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[1] SAMR Launches Antitrust Investigation into Ctrip - Eastmoney
[2] Ctrip Faces Regulatory Crackdown - Wall Street CN
[3] Ctrip Investigated for Abusing Dominant Market Position - Yicai Global
[4] Ctrip Under Antitrust Investigation: Is It Good to Have No Rivals in Sight? - OFweek Digital Economy Channel
[5] Ctrip Group Investigated, Antitrust Enforcement Resurges - Economic Observer Online
[6] Ctrip Group Investigated, Antitrust Enforcement Resurges - Economic Observer Online
[7] SAMR Launches Antitrust Investigation into Ctrip - Southern Metropolis Daily
[8] Ctrip Investigated by China’s SAMR for Suspected Monopolistic Practices - Lianhe Zaobao
[9] Ctrip Group Investigated, Antitrust Enforcement Resurges - Economic Observer Online
[10] Ctrip Faces Regulatory Crackdown - Wall Street CN
[11] Ctrip Investigated for Abusing Dominant Market Position - Yicai Global
[12] Ctrip Group Investigated, Antitrust Enforcement Resurges - Economic Observer Online