There comes a point at which a commercial strategy crosses the line into anti-competitive conduct. In Ryanair’s case, the Italian Competition Authority (ICA) determined that this threshold was exceeded for a two-year period – from April 2023 to April 2025 – and that the infringement warranted a fine worth €255 million. ICA Decision No. 31774, adopted on 19 December 2025 at the conclusion of proceedings A568, stands out as one of the most significant interventions in recent years in the online distribution of air transport services. The Authority found that the conduct implemented by Ryanair DAC and Ryanair Holdings plc constituted an abuse of a dominant position under Article 102 TFEU and Article 3 of Law No. 287/1990, imposing a total fine exceeding €255 million.
At the core of the proceedings was a set of systematic practices adopted by the Irish carrier to hinder the activity of travel agencies – both traditional and online – in selling and combining Ryanair flights with other travel services. According to the Authority, the objective was clear: to concentrate sales exclusively through the airline’s direct channels, thereby compressing the role of intermediaries and restricting competition in downstream markets.
The silent war against OTAs
Online Travel Agencies (OTAs), played a central role in the investigation. As parties directly affected by the contested conduct, they actively participated by providing information and technical input regarding market function, emphasising in particular that access to airline flight content is essential to agencies’ ability to offer comprehensive and competitive travel services. OTA platforms do not merely act as intermediaries between carrier and passenger; they enable consumers to compare flight options, combine routes across different carriers, and integrate ancillary services – such as hotels, insurance, and car rentals – into a single solution. Removing this layer does not simply penalize competitors—it impoverishes the market as a whole.
When obstruction becomes abuse
The Authority expressly acknowledged that, up to 2023, the sale of Ryanair flights through OTAs was significant and contributed to a dynamic and competitive market, with tangible benefits for consumers in terms of variety and price competitiveness. The practices introduced thereafter – technical obstacles to bookings, additional verification procedures, and measures designed to complicate intermediaries’ activity – progressively limited the ability of intermediaries to offer integrated services, thereby eroding the competitive balance previously achieved. This erosion is particularly serious given the carrier’s market weight: very high market shares on domestic routes and European routes to and from Italy, combined with a widespread presence across nearly all national airports. When an operator of that scale forecloses distribution channels, it does not merely pursue a defensive tactic—it can reshape the structure of competition.
In this context, the ability of OTAs to access and distribute Ryanair flights is a structural condition for effective competition in downstream markets for the booking and sale of travel services. The Authority emphasized that preventing or limiting such access may reduce market contestability and undermining intermediaries’ capacity to offer innovative and integrated services, with direct consequences for end consumers.
Not intermediaries, but infrastructures
The investigation helped bring into sharper focus these structural features of the digital travel market. OTA platforms do not perform a purely intermediary role; they operate as competitive infrastructures that ensure price transparency, comparison across offers, and access to customized travel solutions. Limiting their activity weakens not only intermediaries, but the market as a whole.
From this perspective, the ICA’s decision should be read as more than an isolated outcome. It reaffirms a principle long established in antitrust law, yet increasingly tested in digital markets: vertically integrated operators must comply with competition rules when their strategies affect access to downstream markets. Practices that hinder intermediaries’ operations can generate exclusionary effects and slow innovation in the digital sector.
The line has already been drawn
For OTAs, the decision represents recognition of the role digital platforms play in promoting a more competitive and consumer-oriented travel market. Allowing intermediaries to combine flights from different carriers with ancillary travel services expands user choice and fosters the development of new integrated travel solutions.
Moreover, the decision provides operational guidance for carriers, OTAs and aggregators. Access to content, the technical conditions imposed on intermediaries, and multichannel distribution models are now areas of potential antitrust risk that require ongoing monitoring and ex ante legal assessment. The Ryanair case demonstrates that waiting for regulatory intervention to understand where the boundary lies can be costly in terms of fines, reputation, and competitive positioning.
For further reading, here are a selection of articles published on the subject:
