Trip.com (TCOM US & 9961 HK): Regulation changes the form, not the earning power

Research evidence excerpt

Trip.com (TCOM US & 9961 HK): Regulation changes the form, not the earning power

Alex Yao Asia Pacific Equity Research

(86 21) 6106 6505 28 July 2026

alex.yao@jpmorgan.com

Market is likely to price in structural damage; we see a

manageable transition

Trip.com's public conference call on 27 Jul 2026 clarified the scope of the

rectification plan and confirmed that the financial penalty will be fully recognized in

2Q26. Management outlined five initiatives: discontinuing the tier-one and tier-two

delegated distribution programs under a new multi-tier partnership framework;

refining the pricing ecosystem, with the automated pricing tool already

decommissioned earlier this year; improving rule transparency; enhancing consumer

protection; and establishing normalized antitrust self-assessment procedures.

The financial impact is also clearer. Management stated that the penalty will enter

2Q26 results as a RMB5.18bn expense plus RMB122mn of contra revenue, while

capital allocation priorities remain unchanged. The pricing tool impact is already

reflected in the 2Q outlook, and management did not provide 2H26 guidance due to

macro uncertainty and limited visibility.

In our view, the remedy is narrow and consistent with prior platform economy

precedents. Similar to the Alibaba (2021) and Meituan (2021) cases in our

framework, the focus is on prohibited commercial practices rather than structural

intervention into traffic allocation, marketplace operations, or monetization. There is

no fee cap and no evidence of broader restrictions on Trip.com's business model.

The key investor debate is therefore not the penalty itself, but whether the remedy

permanently damages Trip.com's hotel monetization capability. We believe the

market will likely overestimate this risk.