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ERA position paper consultation CRS.pdf



The competitive dynamics of the airline market and the airline ticket distribution market are evolving rapidly and are being increasingly affected by new developments. Traditionally the neutral distribution channel has been powered by travel agencies and global distribution systems (GDS) and for decades, Regulation 80/2009 on the Code of Conduct for Computerised Reservation Systems (CRS) has provided regulations on how airline content should be displayed in the GDS.

Over the last years, however, airline distribution has changed immensely. New channels, such as metasearch engines, aggregators and online travel agencies, have entered the market with new players disregarding the established Code of Conduct, using a biased advertising model. Consequently, the traditional distribution channel has significantly shrunk over the years and now only represents approximately 30 per cent of the total tickets distributed, causing the distribution of airline content to be more costly and complex for small and medium-sized airlines.


ERA is in favour of an updated CRS Code of Conduct regulation that applies to all distribution channels and reflects the new competitive environment of the airline ticket distribution market. A revised Code of Conduct is a critical instrument for the European Commission to ensure the aviation market remains competitive, thus providing small to medium-sized airlines with the opportunity to compete on the merits of their offer and services with larger airline groups.

ERA calls on the Commission to establish clear rules and obligations for all market players to correct market failures resulting from advantageous competitive positions such as discriminatory practices.

For ERA’s detailed position please refer to the downloads section above. 


DG MOVE is currently evaluating the regulation on the Code of Conduct for CRS; this ongoing work paves the way for a potential revision of the regulation. ERA believes it is a unique opportunity for the Commission to ensure that fair competition and consumer choice continues to be protected in the airline distribution marketplace, and that the capacity of European regional airlines to compete is not eroded. In September 2020, ERA responded to the Commission's Inception Impact Assessment for a possible revision of the CRS Code of Conduct with its position paper and comments. See ERA's position paper in the downloads section above.


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