The Italian Competition Authority (Autorità Garante della Concorrenza e del Mercato – AGCM) has imposed a fine of €255,761,692 on Ryanair DAC, jointly and severally with its parent company Ryanair Holdings plc, for abuse of a dominant position. The infringement was found to have occurred from April 2023 until at least April 2025.
According to the Authority, Ryanair holds a dominant position in the upstream market for scheduled passenger air transport services, both domestic and intra-European, to and from Italy. These services constitute a key input for the activities of online and offline travel agencies (OTAs and traditional travel agents). Ryanair’s dominance is based not only on its very high and steadily increasing market shares—accounting for approximately 38–40% of passengers carried on routes to and from Italy—but also on a range of additional indicators demonstrating substantial market power and the ability to behave independently of competitors and consumers. This assessment also reflects the significant gap between Ryanair’s performance and that of its main airline competitors.
Following an extensive and complex investigation, the AGCM found that Ryanair had implemented a systematic and multifaceted exclusionary strategy aimed at preventing, restricting, or making economically or technically more burdensome the purchase of Ryanair flights by travel agencies through the website ryanair.com, where such flights were combined with flights operated by other carriers and/or with additional tourism and insurance services.
Specifically, the Authority reconstructed a strategy developed in successive stages. From late 2022, Ryanair began assessing various measures intended to hinder the activities of travel agencies. These measures materialised from mid-April 2023 through progressively more stringent interventions. In an initial phase, Ryanair introduced facial recognition procedures applicable to passengers holding tickets purchased through travel agencies via its website. In a second phase, towards the end of 2023—when the investigation was already underway—Ryanair totally or intermittently blocked booking attempts by travel agencies, including through the blocking of payment methods and the mass cancellation of user accounts linked to OTA bookings.
In a third phase, at the beginning of 2024, Ryanair imposed partnership agreements on OTAs and subsequently Travel Agent Direct agreements on offline travel agencies. These agreements contained conditions limiting the agencies’ ability to offer Ryanair flights in combination with other tourism services. Compliance was allegedly enforced through intermittent booking blocks and an aggressive communication campaign targeting non-signatory OTAs, publicly labelled as “pirate OTAs”. Only in April 2025 did Ryanair make available to OTAs a full whitelabel iFrame solution, providing application programming interface (API) integration which, if properly implemented, allows for the restoration of effective competitive conditions in the downstream market for tourism services.
The AGCM therefore concluded that the conduct in question—at least until the integration of Ryanair’s APIs—was capable of and did in fact restrict the sales activities of travel agencies, also affecting their ability to attract online traffic. Ultimately, the practices identified prevented agencies from purchasing Ryanair flights for combination with flights operated by other airlines and/or with additional tourism services, thereby reducing competition, both direct and indirect, and adversely affecting the quality and variety of tourism services available to consumers.