The European Commission has officially started the consultation for review of the GDS Code of Conduct, with a 55-question survey sent to the industry today.
The review (or "health check", as some are trying to call it) is the first major look at the framework regulating the role of GDSs in Europe for many years and some are expecting - indeed, hoping - it will trigger some fundamental changes by the time the process ends in early-2012.
Some are calling for a vast re-examination of the Code given the recent entry of Google into the distribution marketplace, at least on the periphery, alongside the development of so-called Direct-Connect technology by airlines.
Where there appears to be more wider agreement is that the Code should remain in place in some form or other (some have previously suggested that the marketplace is actually far too complicated to regulate, so the current Code should be scrapped).
So-called stakeholders received the questionnaire this morning - Tnooz has managed to get hold of a copy.
The survey is split into eleven sections:
1. Regulation 80/2009 [previous amendment]
- To what extent are some regulatory measures of Regulation 80/2009 redundant, overlapping, ineffective or inconsistent?
- Are there any short-comings in Regulation 80/2009 that should be addressed?
- Is Regulation 80/2009 still appropriate, and if so are there any necessary changes?
- Would self-regulation (i.e. CRS full deregulation) in the EU be more effective?
- What has been the impact for your business of the introduction of greater pricing freedom in Regulation 80/2009?
2. CRS [Computer Reservation System]
relationship- To what extent do you think CRSs are important to end users (i.e. consumers) and travel agents?
- How has this changed in the last 5 years?
- How do you see this changing in the future?
- Is it true to say that travel agents have an incentive to use the CRS provider that offers the highest booking fee?
- To what extent do CRS market shares (in terms of booking volume) vary between EU Member States?
- To what extent do CRS market shares vary between categories of customers (leisure/business travellers, local/foreign travellers, etc)?
- To what extent do you see the role of the travel agents changing in the future?
- Could you please clarify how the fare agreement between Amadeus and Sabre works, and how it may affect the market?
- Has the ability of airlines in Europe to control access to their content changed the market?
3. CRS ownership- How has your ownership structure changed since 2005?
- To what extent do you think the specific obligations imposed on parent carriers are still needed?
- Should airlines remain free to invest in CRS providers and control them or should there be rules that restrict the possibility for airlines or other sectors to control CRSs?
- Do you feel there is a correlation between CRS ownership and airline market share in some particular countries or markets?
- To what extent are transparency requirements needed for CRS providers that are not publicly listed on a stock exchange?
4. Neutral display- Do you have any issues with regard to how fares and services are displayed on CRSs?
- To what extent are the prescriptions in Annex 1 of Regulation 80/2009 on principal display still pertinent?
5. Unbundling and ancillary services- To what extent do CRSs allow full flexibility for optional extras such as baggage allowance, allocated seating, priority check-in, etc?
- To what extent do you feel that CRSs should change their capabilities regarding unbundling/ancillary services?
6. Technological developments- What is the impact on your business of the development of "connection portals" or "metasearch engines" such as Kayak, Dohop, or Skyscanner?
- To what extent do you think there is a risk of display bias in connection portals?
- From a passenger point of view, what are the implications of using a connection portal rather than a CRS in areas such as non-guaranteed connections for example, or connections between/within low cost carriers?
- What is the impact for your business of the development of Direct Connect portals?
- To what extent do you think there is a risk of display bias in Direct Connect portals?
- Should Direct Connect portals be treated as a CRS under Regulation 80/2009? If so, should the airline owning the Direct Connect portal be treated as a parent carrier?
- To what extent is software that integrate CRS, internet and Direct Connect information on one screen being used?
7. MIDT [Marketing Information Data Transfer]
- Should provisions on grouped sales of MIDT data be included in the regulation? Why?
- Do you feel the provisions of the Regulation requiring agreement on conditions for the use of data in MIDT are applied and/or work in practice?
- Do you have any other concerns regarding the implementation of Article 7 (regarding MIDT) in the Regulation?
- Have you considered including fare and/or revenue data in your MIDT product? Please explain
- Do you see any market developments such as the possible launch of competing products (e.g. IATA DDS) that may have an effect on the necessity of the regulation on MIDT? Please explain.
- What would be the effect of this development on your MIDT product?
8. Protection of personal data- To what extent are the provisions on the processing, access and storage of personal data effective and relevant?
9. Developments outside the EU- To what extent do you feel there is a competitive advantage/disadvantage for the EU airlines vis-à-vis their US counterparts from Regulation 80/2009?
- What has been the impact of the US deregulation on the competitive situation for the EU airlines in the US?
- To what extent has the US deregulation affected your business?
- What is the regulatory situation regarding CRS operation in Canada?
- What is the regulatory situation regarding CRS operation in China?
- What is the regulatory situation regarding CRS operation in Japan?
- What is the regulatory situation regarding CRS operation in Brazil?
10. Intermodality- What is your involvement in end-to-end transport provisions for your customers (rather than the flight component alone) and how do you see this evolving in the future?
- Has greater pricing freedom with regard to booking fees allowed more rail services to be offered on the CRS displays?
- Are there any problems encountered with the display of this information on CRSs?
- Are additional measures needed to promote the sale of rail tickets via CRSs?
11. Market information- Please provide us with a segmentation of your sales by brick and mortar travel agent (off-line) and online, in total and broken down by Member State.
- How have these figures evolved over the past five years?
- How do you expect these figures to evolve over the next 5 years?
- Please provide us with an indicative cost of participation in your CRS, and whether this differs amongst your subscribers.
- How have these figures evolved over the past five years?
- Please provide us with the market share of your CRS by ticket volume and revenue disaggregated by seller type (brick and mortar travel agents vs online sales) and then traveller type (leisure vs. business travellers), across the EU27 in total, and for each EU-27 country. Which factors explain the differences by country?
- Please provide us with the average booking fee per segment since 2007 in real terms.