Travel Tech has filed comments with the Federal Trade Commission. It wants enforcement against travel companies that use personal data to set an individual traveller's price.
The association also told the Commission to leave the rest of the trade's pricing machinery alone. Travel Tech announced the filing on 30 September 2026.
The ask
Travel Tech backs enforcement against unfair or deceptive uses of personal data to set individualised prices. It asks the Commission to keep dynamic pricing, revenue optimisation tools, loyalty programmes and negotiated rates out of the policy.
Seven practices it wants outside the policy
The announcement lists seven. They are dynamic pricing based on market conditions, supply and demand; inventory management and revenue optimisation tools; promotional discounts and limited-time offers; loyalty and rewards programmes; employer, membership, government and negotiated rates; standard travel search inputs such as destination, travel dates, party size and cabin class; and algorithms and automated decision tools used for purposes other than judging an individual consumer's willingness to pay.
Travel Tech says dynamic pricing has long been a feature of travel markets. The association says those practices do not rest on judging an individual consumer's willingness to pay.
The Orlando argument
The filing puts the distinction in one line. A consumer who searches for a hotel room in Orlando is describing the product.
The filing asks the Commission to define personal data as "personally identifiable information" to match state privacy frameworks. It says standard search parameters and general market metrics are not personal data on their own.
It also asks for a carve-out. Traveller-specific information used by Travel Management Companies to run a corporate travel contract should sit outside the policy, because the purpose is to administer a managed programme.
On disclosure, the filing says the duty should attach only where using data to set an individualised price would already be unfair or deceptive under Section 5. It argues a broader framework would bury consumers in notices about routine pricing.
Chadwick on the comparison tools
"Consumers benefit from a travel marketplace that is transparent, competitive, and innovative," said Laura Chadwick, President and CEO of Travel Tech. "As policymakers examine personalized pricing, it is important to distinguish potentially harmful uses of personal data from tools and practices that help travelers compare options, access discounts, and find the best value."
The filing
The document runs seven pages. It is headed "BEFORE THE FEDERAL TRADE COMMISSION, WASHINGTON, DC," and it is signed by Chadwick as President and CEO at 1800 Diagonal Rd, Suite 600, Alexandria, VA 22314. It is dated 25 September 2026 and carries docket number FTC-2026-1057.
The filing's own list of standing practices is narrower than the announcement's. It names loyalty discounts, member-only offers, mobile application promotions, aggregate location-based incentives and contractually negotiated corporate travel rates.
Travel Tech describes itself as the voice for the travel technology ecosystem. Its members sit across online travel agencies, metasearch platforms, short-term rental platforms, Global Distribution Systems and travel management companies.