Trip.com Group (TCOM): Conclusion of anti-trust investigation; Buy

Research evidence excerpt

Trip.com Group (TCOM): Conclusion of anti-trust investigation; Buy

Equity Research

27 July 2026 | 12:06AM HKT

Simon Cheung, CFA

+852-2978-6102 |

simon.cheung@gs.com

Goldman Sachs (Asia) L.L.C.

Alpha Wang

+852-2978-1984 | alpha.wang@gs.com

On July 25th, China’s State Administration for Market Regulation (SAMR) Zhaoheng Chen

announced (link) that it has completed a 6-month anti-trust investigation into +852-2978-0901zhaoheng.chen@gs.com|

TCOM, charging the company Rmb5.179bn in one-off penalties for “abusing its Goldman Sachs (Asia) L.L.C.

dominant position” in China’s online hotel booking market since 2020, Leah+852-2978-6972Pan | leah.pan@gs.com

representing close to half of its online travel booking GMV over this period (see Goldman Sachs (Asia) L.L.C.

our prior reports on Jan 15, Jan 19). The penalties include (1) a fine of

Rmb3.521bn calculated based on 7.5% of TCOM’s 2025 domestic revenue - we

note this was above the 4%/3% charged on Alibaba/Meituan previously

(Apr-21, Oct-21); (2) confiscation of Rmb1.658bn in gains from practices

deemed in breach; and (3) a full refund of Rmb122mn in deposits withheld from

hotel operators.

The regulator identified two practices that breach the Anti-monopolistic Law of the

PRC: (1) TCOM required operators of “Premium Category” hotels (特牌酒店) to

engage in exclusive partnership or cooperation. By offering incentives such as

maximum traffic tilt and benefit support, hotel operators with high transaction

volumes, better service quality and strong user appeal were encouraged to join its

platform as “Premium Category” hotels and were restricted from working with other

platforms; and (2) TCOM forced “Golden Category” (金牌酒店) and other unbranded

hotels (无牌酒店) to offer on TCOM the lowest prices across all platforms. It directly