On January 14th, 2025, the UK’s Competition and Markets Authority Act (CMA) kicked off an investigation into Google’s search and search advertising. Their goal? To assess whether Google holds strategic market status (SMS) and if its practices harm competition and innovation.
If this sounds familiar, that’s because this is the latest in a long line of challenges to Google’s dominance in the market – the most widespread of which has been the EU’s Digital Markets Act (DMA), which has obvious similarities to this act being rolled out in the UK. But there have been many other clear challenges to Google’s power, including sanctions proposed by the United States department of justice back in October 2024 with the goal of stopping Google from monopolizing the search market.
For years, hotels have relied on Google's ecosystem—whether through organic search, paid advertising, or metasearch visibility—to drive direct bookings. However, as regulations tighten, Google's ability to prioritize its own services and ad placements could be restricted. This could theoretically lead to a more level playing field where smaller hotel brands and direct booking platforms gain better visibility without having to outbid major Online Travel Agents (OTAs).
In practice, it’s a bit more complicated. With new regulations potentially limiting Google’s search functionalities, hotels could face increased competition from OTAs, who are not held to the same regulations as Google and may invest further in their own marketing channels to capture displaced demand (though Booking.com – still the biggest global OTA – is facing its own DMA-related regulatory challenge).
Google’s changes in the wake of the DMA
Since being named a DMA “gatekeeper” by the European Commission back in November 2023, Google has made a number of changes to its search engine in order to satisfy all the requirements of this landmark act. These have included removing links to its own vertical search services (VSS) and changing the user experience on its EU search engine results pages (SERPs) to deprioritize its own offerings. Google (perhaps unsurprisingly) frames these changes as “removing useful features … and reducing functionality”, though there is certainly debate as to whether they’ve had the desired effect of increasing fair competition between businesses and improving options for end users.
But there may be more DMA-driven changes to come. In late 2024, Google ran a test in Germany, Belgium and Estonia that took their search results back in time, in response to criticism by some industry players that previous changes haven’t gone far enough.
What changes did Google test?
In this test Google removed many of the features that have been seen as standard on the search engine for years, including maps, reverting back to its old approach of simply showing a list of links.
This return to the “old ‘ten blue links’ format from years ago” didn’t last long and looks like a deliberately provocative move to illustrate where hard-line interpretation of the DMA could lead. After all, not every search optimization or design change warrants a dedicated blog post from a senior member of Google’s legal team (in this case no less than the Director, EMEA Competition). But nonetheless, it was an interesting sign of what the future could look like.
We had a look at the search engine results pages for the EU as a whole, and for the countries impacted by this test. When looking at specific hotel name search (i.e. “Radisson Blu Berlin”, we did not see a marked difference in the results shown. However, when looking at more general terms (ie “hotels in alexanderplatz Berlin”), the lack of additional visuals and graphics was striking. The page definitely started to look more like the Google of a decade ago - no maps, images or additional hotel creatives leading to booking options. However, this distinction was presumably a design choice by Google for the purposes of bounding the test, rather than a conceptual limitation.
EU SERP example
Test country SERP example
Did these changes impact Google’s performance in the affected regions?
When Google implemented some of its other changes in accordance with the DMA, we saw significant changes to hotels’ metasearch performance, with impressions and clicks dropping by as much as 30% in some cases. Did these changes have a similar impact?
In a blog post, Google shared the results that they saw from implementing these newest tests, including:
- Less satisfaction from users when making Google searches, and longer search journeys to find hotels – in addition to abandoned search journeys.
- More than a 10% drop in Google traffic to hotels in the impacted region
- Relatively flat traffic to intermediary sites like Booking.com
Google is inherently biased in this case, but there’s reason to think that these changes could in fact cause a drop in traffic going to direct hotel websites in the future.
Google: No longer a worldwide experience
Google’s DMA response has already led to a significant gap opening up between the experience of users looking for hotels within the US, and those in other parts of the world.
Of course, Google is famous for constantly testing, refining and optimizing all its products, so no two geographic experiences were ever quite the same. But it’s possible that this gap will get even bigger in future. It simply might not be legal to roll out design changes made in other parts of the world to users in the EU – and maybe now the UK -- no matter how effective they appear to be.
For example, last month we temporarily saw a big change to Google’s metasearch results being shown to a significant chunk of US users. This test has since ended, but if implemented on a larger and more permanent scale, it could significantly impact the way that hotels are displayed on metasearch.
Google’s DMA approach vs. Booking.com’s DMA approach
Google has been engaging with the DMA for over a year now, and is still making meaningful changes to ensure compliance with the law. Booking.com released its first compliance report in November 2024, after being named a gatekeeper back in May 2024, and the changes suggested were minimal in comparison. The wording of the law is definitely more geared towards a platform like Google, which shows its own offerings alongside those of third parties, vs. a closed system like that operated by Booking.com.
One of the main aims of the DMA was to enable smaller businesses (like independent hotels) to compete more effectively with larger players. So far, that seems to have backfired somewhat. While the DMA is enacting control on huge players like Google, Meta and Apple - it’s not being used effectively to rein in the power of other large companies like OTAs. And in fact, with Google required to not self-preference, these large OTAs are often actually gaining more visibility on its site at the expense of direct booking links - including in the case of Google’s recent test of the “return to blue links”.
We hope that the wording of the DMA doesn’t keep Booking.com from being held to the same standard as other gatekeepers as the act becomes a cornerstone of the EU’s business landscape.
What’s next for Google?
It’s hard to predict how Google will continue to be impacted by incoming rules and regulations. In the case of the UK’s CMA, we’ll likely not have any firm answers until the second half of this year, with an official October deadline for the investigation.
In the meantime, we’ll be keeping an eye on the DMA’s rollout, the CMA investigation, and any other upcoming regulations – and evaluating how these changes could impact hoteliers. When in doubt, please reach out to one of our direct booking experts for any guidance, advice, or insights.
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Genevieve is a product marketing manager at Triptease.