Fair competition in digital tourism

One of the most important topics on the tourism agenda this week has been the legislative proposal aimed at re-regulating the operations of foreign digital platforms in Turkey. The regulation, which was approved by the Grand National Assembly of Turkey (TBMM) Committee on Public Works, Reconstruction, Transportation, and Tourism, brings with it a broader debate not only regarding the operations of global platforms such as Booking, Airbnb, and similar entities, but also concerning how competition will be defined in the digitalization process of Turkish tourism.

One of the most significant transformations in the tourism sector over the last twenty years has occurred not in travel itself, but in the way travel is purchased. From hotel reservations to flight tickets, and from transfers to the sale of experiences, it is often no longer a direct travel agency that the consumer encounters, but rather digital platforms operating on a global scale.

This transformation has undoubtedly provided significant conveniences. Consumers can access more options, price comparisons, and tourism products from different parts of the world within minutes. However, this efficiency brought about by digitalization also raises a fundamental question: Are all actors operating in the digital economy subject to the same rules?

The regulation on the parliamentary agenda is shaped precisely around this question. The proposal introduces various obligations for foreign digital platforms, such as obtaining an authorization certificate, maintaining a representative in Turkey, and paying taxes and tourism contributions, while also stipulating that certain services falling under the scope of travel agency activities must be provided through authorized travel agencies.

It would be incomplete to evaluate this regulation solely from the perspective of "protecting local agencies." The essence of the matter is ensuring that competition takes place under fair conditions.

A travel agency operating in Turkey functions within a broad regulatory framework, ranging from consumer legislation to tax obligations, and from professional responsibilities to certification and audit mechanisms. When a digital platform enters the same market with different obligations, the issue that arises becomes not only an economic one but also a legal and structural problem.

The point to be noted here should not be to prevent the existence or growth of digital platforms. Just as it is impossible to reverse digitalization, it is also not desirable. The real issue is to strike the right balance between the innovation brought by digital platforms and the protection of the local economic ecosystem.

Because tourism is not just a sector where rooms and flight tickets are sold. A destination's tourism economy forms a vast value chain, from guides to travel agencies, restaurants to transfer companies, and museums to local producers. As the share of digital platforms in this chain grows, it is necessary to ask not only about the volume of reservations but also where value is created and where the revenue remains.

The main objection that has come to the fore in TÜRSAB's recent statements gains meaning here. It is argued that foreign platforms operating without establishing a company in Turkey or being subject to the same obligations as local agencies could create inequality in terms of competition. This approach has an important aspect that needs to be considered: The obligations required of local companies should not disappear entirely when it comes to global companies.

On the other hand, it would not be right for the regulation to turn into a purely protectionist approach. The technology, user experience, access, and international marketing power offered by global platforms also create significant opportunities for Turkish tourism. What Turkey needs is not to fight against digital platforms, but to determine under what conditions and within what framework of rules they will work with them.

In the longer term, there is a need for a Turkey that not only regulates the activities of foreign platforms in Turkey but also develops its own travel technology ecosystem. It is not possible to create a lasting competitive advantage solely through legislation without supporting the digitalization of local travel companies, their use of data analytics and artificial intelligence, their capacity to reach consumers directly, and their access to international markets.

Therefore, the question that should be discussed in the coming period should not be "platforms or agencies?"

The real question is this:

Within what rules and among whom will the economic value created by digitalization in tourism be shared?

A well-prepared regulation should neither block the path of digital platforms nor allow the local sector to be left in unequal competitive conditions. While protecting the consumer's freedom of choice, tax justice, consumer safety, transparency, and equality of competition must also be guaranteed.

Because the future of tourism does not depend solely on becoming more digitalized.

The real issue is to remain fair while digitalizing.