Comprehensive Analysis Report on the Market Dominance of Trip.com and Tongcheng Travel

Based on the latest market data and regulatory developments I have collected, here is a comprehensive analysis of the market dominance of Trip.com and Tongcheng Travel:

There is a significant capital link between Trip.com and Tongcheng Travel, which constitutes an important prerequisite for analyzing market dominance:

• Trip.com holds approximately
  24.07%
  of Tongcheng Travel’s equity, making it a major shareholder of Tongcheng Travel[0][1]
• Trip.com holds
  100%
  equity of Qunar (wholly-owned)[2]
• Trip.com holds approximately
  37.6%
  of eLong’s equity[3]
• In 2018, Trip.com promoted the merger of eLong and Tongcheng Network to form ‘Tongcheng eLong’ (later renamed Tongcheng Travel)[4]

Through a series of capital operations, Trip.com has built a ‘Trip.com Ecosystem’ empire covering major competitors.

According to data from multiple research institutions, China’s OTA market in 2024 showed a clear pattern of ‘one dominant player, multiple strong players’:

Platform	Market Share	Notes
Trip.com	56%	Absolute leading position
Tongcheng Travel	15%	Member of Trip.com Ecosystem
Meituan	13%	Major competitor
Fliggy	8%	Alibaba Group affiliate
Douyin	3%	New entrant

[0][1][4]

• Trip.com: 35.8%
• Meituan Travel: 22.5%
• Tongcheng Travel: 15.9%
• Qunar Travel: 13.4%
• Fliggy: 7.2%[5]

According to Article 24 of the Anti-Monopoly Law of the People’s Republic of China, an operator may be presumed to have market dominance under any of the following circumstances:

1. A
   single operator
   holds a market share of
   one-half (50%)
   or more
2. Two operators
   together hold a market share of
   two-thirds (66.7%)
   or more
3. Three operators
   together hold a market share of
   three-fourths (75%)
   or more[1]

From a legal perspective:

• Trip.com itself
  : With a 56% market share, exceeding the 50% threshold specified in the Anti-Monopoly Law, it can be
  presumed to have market dominance independently
  [1][4]
• Trip.com + Tongcheng Travel combined
  : A 71% market share, far exceeding the two-thirds presumption threshold
• Entire Trip.com Ecosystem
  (Trip.com + Tongcheng Travel + Qunar): Approximately 71% market share, also far exceeding the two-thirds threshold

Trip.com’s market dominance did not form overnight, but was achieved through the following capital integration path:

1. 2014
   : Trip.com invested USD 200 million in Tongcheng Travel, becoming its second-largest shareholder[4]
2. May 2015
   : Trip.com invested approximately USD 400 million to acquire 37.6% of eLong’s equity, becoming its largest shareholder[3][4]
3. October 2015
   : Trip.com reached a share swap deal with Baidu to obtain 45% voting rights in Qunar, achieving control over Qunar[3][4]
4. 2018
   : Trip.com promoted the merger of eLong and Tongcheng Network to form Tongcheng eLong[4]

As industry analysts put it: ‘Within less than two years, Trip.com incorporated all major competitors in China’s online travel market into the Trip.com Ecosystem’[4]

On

, the State Administration for Market Regulation (SAMR) officially initiated an investigation into Trip.com for alleged abuse of market dominance[0][1]. The main practices targeted by the investigation include:

• Requiring hotels and homestays to maintain the
  lowest price across all platforms
  on its platform
• Mandating merchants to activate the ‘Price Adjustment Assistant’, which automatically modifies room prices without permission[4][6]
• Setting exclusive dealing clauses (‘one out of two’ requirements)[0][1]

• In July 2025, Trip.com upgraded the ‘Price Adjustment Assistant’ from ‘suggesting a price reduction’ to ‘automatically reducing the price’
• Automatically scanning prices on competing platforms through the backend system, and
  automatically and forcibly lowering
  hotel room prices[4]
• Criticized by CCTV.com as ‘algorithm hegemony’[4]

• Implementing differential treatment in transaction prices for different counterparties (i.e., ‘big data price discrimination’)[1]
• Merchants report that revenue distribution is opaque and commission adjustments are arbitrary[0]

Date	Event
August 2025	Guizhou Provincial Administration for Market Regulation interviewed platforms including Trip.com, pointing out issues such as exclusive dealing and interference with merchant pricing[1][4]
September 2025	Zhengzhou Municipal Administration for Market Regulation conducted an administrative interview with Trip.com in accordance with the law, requiring rectification of issues such as ‘mandatory activation and inability to opt out’[1]
December 2025	Yunnan Provincial Tourism Homestay Industry Association ‘declared war’ on OTA platforms including Trip.com, accusing them of exclusive dealing and unilateral commission increases[0][1]
December 2025	Huizhou Homestay Association in Huangshan City, Anhui Province launched evidence collection work[1]
January 14, 2026	State Administration for Market Regulation (SAMR) officially initiated an investigation into Trip.com for alleged abuse of market dominance [0][1]

According to the Anti-Monopoly Law, if abuse of market dominance is confirmed:

• Illegal gains will be confiscated
• A fine of 1%-10% of the previous year’s sales revenue will be imposed
• Based on Trip.com’s first three quarters of 2025 revenue of RMB 47.011 billion, the potential fine could reach
  billions to tens of billions of RMB
  [0]

In addition, Trip.com may also face:

• Civil claims from harmed hotels and homestays
• Claims from competitors (similar to the JD.com v. Alibaba case)[0]

• Small and medium-sized homestay operators face the dilemma of ‘almost being unable to break away from the Trip.com platform’[4]
• To gain traffic exposure, merchants need to pay additional hidden fees, with total commission expenses possibly reaching close to
  40%
  [1]
• Merchants’ independent pricing power has been severely eroded

• Controversies over ‘big data price discrimination’ persist, with users questioning differential pricing[4]
• The platform maintains high prices using its market dominance[4]

• The Trip.com Ecosystem holds approximately 71% of the market share, forming de facto market dominance
• New entrants such as Douyin hold only 3% of the market share, making it difficult to effectively challenge the existing pattern[0]
• Industry innovation momentum may weaken due to lack of competition

1. Excessive market share
   : The total market share of the Trip.com Ecosystem is approximately 71%, far exceeding the two-thirds presumption threshold specified in the Anti-Monopoly Law
2. Obvious abusive practices
   : Practices such as mandatory price adjustments through technical means, exclusive dealing clauses, and high commissions are suspected of abusing market dominance
3. Clear regulatory stance
   : The State Administration for Market Regulation has officially initiated an investigation, indicating the regulatory authorities’ continued focus on antitrust in the platform economy
4. Severe legal consequences
   : If confirmed, Trip.com will face huge fines and potential civil claims

This antitrust investigation is not only a warning to Trip.com, but also a regulatory signal to the entire platform economy industry —

[4].

---

[0] Securities Times - “Trip.com, Earning RMB 200 Million Daily, How to Face the Dual Challenges of Regulation and Growth?” (https://wap.stockstar.com/detail/IG2026011500020350)

[1] Southern Metropolis Daily - “Trip.com Investigated for Alleged Monopoly: What Exactly is Being Investigated? Could It Face Fines of Billions of RMB?” (https://www.nfnews.com/content/n614dAMG3P.html)

[2] Wikipedia - Trip.com Group (https://zh.wikipedia.org/wiki/携程集团)

[3] Dongfang Fortune Securities Research Report - “Special Topic on the Travel Chain Industry” (https://pdf.dfcfw.com/pdf/H3_AP202507011700850361_1.pdf)

[4] Sina Technology - “Trip.com Runs Into Antitrust Scrutiny, Is It Unfairly Targeted?” (https://finance.sina.com.cn/tech/csj/2026-01-15/doc-inhhkmpx6394647.shtml)

[5] Wenkehui - “2024 Panoramic Insight into China’s Online Travel Industry Market” (https://www.fxbaogao.com/detail/4985519)

[6] Economic Observer - “Depriving Merchants of Pricing Power, Implementing Exclusive Dealing: Trip.com Investigated for Antitrust Violations” (http://www.eeo.com.cn/2026/0115/779678.shtml)