Few things are more tempting than the tease of a dirt-cheap flight to Italy when it comes to booking (another) trip to one of the boot-shaped country’s main travel hubs.
Ryanair operates a large share of those routes and accounts for up to 40% of passenger traffic to and from Italy.
Yet on Tuesday, Italy’s antitrust authority fined Ryanair €255 million for abusing its dominant position, saying the airline used technical barriers and booking restrictions to squeeze travel agencies out of the market.
"Following a complex investigation, the Authority found that Ryanair put in place an elaborate strategy affecting the ability of online and traditional travel agencies to purchase Ryanair flights on ryanair.com," according to a statement by the Authority.
In particular, the company’s strategy "blocked, hindered or made such purchases more difficult and/or economically or technically burdensome when combined with flights operated by other carriers and/or other tourism and insurance services."
In a market where one company offering a service is dominant — which in and of itself is not something competition authorities would penalise — it is important that a buffer or control exists between the consumer and the company.
Particularly in digital markets, search results, booking platforms, comparison tools and price aggregators are a key part of your interaction with any commercial service provider.
If those intermediaries disappear or are weakened, consumers see fewer options and fewer comparisons — and subsequently, there are fewer reasons for dominant companies to behave well.
First, the airline introduced technical friction aimed specifically at customers booking through travel agencies. From April 2023, Ryanair applied facial-recognition checks and other verification steps to agency-linked bookings, while direct customers were largely unaffected.
These measures made agency sales slower, less reliable and more costly, discouraging consumers from booking through intermediaries and weakening the ability of these agencies to compete.
Second, Ryanair directly obstructed access to its flights by intermittently or entirely blocking travel agencies from booking on its website. According to the Authority, this included disabling payment methods and mass-deleting accounts associated with online travel agencies.
Because Ryanair flights are an essential input for agencies selling travel packages to and from Italy, these actions effectively prevented agencies from operating normally. The Authority concluded that Ryanair was no longer merely competing with intermediaries, but actively denying them access to the market.
Third, Ryanair used this pressure to force agencies into restrictive partnership agreements. Agencies were required to sign contracts that limited their ability to bundle Ryanair flights with other airlines, accommodation, insurance or tourism services — a core part of how agencies compete.
To push compliance, Ryanair periodically reinstated booking blocks and led “aggressive communication campaigns” directed at non-signatory platforms, branding them “pirate OTAs”. This, the Authority said, further distorted competition by reducing agencies’ commercial freedom and narrowing consumer choice.
A pirate OTA is an online travel agency that sells airline tickets without a formal partnership agreement — a practice airlines criticise but regulators often view as legitimate competition.
Under competition law, dominance itself is not illegal. What is illegal is abuse — using market power to exclude competitors, impose unfair conditions or restrict how others operate in related markets.
The Authority concluded that Ryanair leveraged its dominance in the upstream air transport market to undermine competition in the downstream market for travel and tourism services.
By making it economically and technically burdensome for agencies to sell Ryanair flights — especially in combination with other services — the airline weakened competition, reduced the range and quality of offers available to consumers and distorted the market structure.
That combination is what ultimately justified the €255 million fine.
Digital markets concentrate power very fast. If one company becomes the default — the cheapest, the biggest, the most recognisable — everyone else has to build around it.
Over time, access to that company’s product becomes essential. At that point, any decision the dominant firm makes about who can sell, how they can sell or what combinations are allowed stops being a private choice and starts shaping the whole market.
Competition agencies step in precisely at that moment — not because something dramatic has happened yet, but because they recognise the early signs of structural lock-in.
Intermediaries are the only actors that can still introduce friction, comparison and choice into that system. Remove them, and the market stops being competitive.