Italy: The Italian Competition Authority has sanctioned Ryanair for abuse of dominant position

In a decision dated 19 December 2025, the Italian Competition Authority ("AGCM") found that Ryanair DAC and Ryanair Holdings plc had abused their dominant position in Italian Air Transport. The abuse was identified in a series of conducts, implemented from April 2023 to April 2025, aimed at blocking, hindering, or increasing the cost for travel agencies to offer Ryanair flights, including in combination with flights from other airline companies and tourist services.

The AGCM fined Ryanair EUR 255 million.

Background: cross-border investigation 

The investigation was characterised by a complex series of events. During the inquiry, the AGCM requested investigative assistance from the Irish Competition and Consumer Protection Commission ("CCPC") pursuant to Article 22(1) of Regulation (EC) No. 1/2003 and Article 24 of Directive (EU) No. 1/2019 to conduct inspections at the premises of Ryanair Holdings plc and Ryanair DAC in Dublin. Ryanair appealed against the inspection request sent by the AGCM to the CCPC before the Italian Administrative Court (TAR Lazio) on the ground that it was procedurally unlawful, and sought  to prohibit the AGCM from using the seized material. Initially, TAR Lazio granted Ryanair's request, suspending the use of the acquired documentation. However, the AGCM subsequently appealed against this decision to the Council of State (Italian Court of Appeal), which rejected Ryanair's request, thereby allowing the AGCM to access the acquired documentation. Concurrently, on the basis of the same grounds, Ryanair brought proceedings against the CCPC and the AGCM before the Irish High Court and then before the Irish Court of Appeal, but its requests were rejected in both instances.

Relevant market: Ryanair's position in Italian air transport

The AGCM established that Ryanair holds a dominant position in the market for scheduled domestic and European air transport services to/from Italy, as an input for Online Travel Agencies ("OTAs") or physical travel agencies. It was established that in the three-year period 2022-2024, Ryanair carried 38–39% of all domestic and European passengers to/from Italy and 44–50% of domestic passengers, with a gap of more than 20 percentage points between it and the second-largest operator. In assessing dominance, the AGCM rejected Ryanair's objections, which argued that its dominant position should be ruled out on the basis of the findings of the previous stand-alone litigation before the Court of Milan and the Court of Appeal of Milan (Lastminute/Ryanair), relating to the period 2005-2021. The AGCM explained that the findings of that litigation were not relevant in the present case as they concerned a period prior to the conduct of Ryanair in the case in question (2023-2025).

Abusive practices identified by the AGCM

The AGCM  identified a series of abusive practices carried out by Ryanair:

• Face verification: introduction of a systematic block on bookings made through OTAs, requiring passengers to create an account on the Ryanair website, provide personal data, and pass a biometric or document verification, under penalty of additional charges.
• “Shield” system: implementation of a technical system, called “Shield,” to identify and block Ryanair flight bookings made by OTAs that did not have a partnership agreement with Ryanair.
• Contractual pressure: exerting strong pressure on OTAs to push them to sign partnership agreements with Ryanair, resorting not only to blocking bookings, but also to a massive smear campaign in the press.
• Travel Agent Direct (TAD) agreements: imposition of TAD agreements on physical travel agencies, through which travel agents could sell Ryanair flights, without access to promotional rates.

Impact on travel agencies and consumers

The AGCM found that Ryanair's conduct between 2023 and 2025 led to a sharp drop in bookings for Ryanair flights, including in combination with flights from other airlines, purchased through travel agencies. This data was counter to the trend not only in terms of the significant increase in demand for tourism services, but above all in terms of the significant increase in user traffic on the Ryanair website and the revenues obtained by the latter, including for non-aviation services.

Essentially, the AGCM found that Ryanair abused its dominant position not simply by refusing to sell its flights to travel agencies, but through a complex exclusionary strategy aimed at degrading the supply channel of intermediaries, represented by travel agencies, in the market for flight bookings and combined tourist services. 

In fact, Ryanair's strategy made it impossible or extremely costly for agencies to continue offering its flights, with the effect of drastically reducing their competitive capacity in the downstream markets of flight and combined tourist services. Accordingly, the AGCM classified the behaviour as an exclusionary abuse, given that Ryanair used means not based on merit to hinder the maintenance and development of competition in the market for the sale of flights and tourist services, in which it competes with OTAs both directly and indirectly.

Ryanair's conduct had a twofold impact: on the one hand, it reduced the competitive ability of travel agencies to offer complete tourist packages, forcing customers to purchase services directly through its website; on the other hand, it limited consumers' ability to compare offers through independent channels, based on price, quality, and choice. 

AGCM's findings: Exclusionary abuse and harm to competition

The case gave the Authority the opportunity to reaffirm that the protection of competition necessarily involves the preservation of distribution channels that allow intermediaries to perform their function of aggregating and comparing offers. When a dominant company uses its position to degrade such channels through technical, contractual, or communication means, this constitutes an exclusionary abuse that harms not only competitors but also end consumers.

For more information or further guidance in this area, please contact Federico Marini Balestra, Lucia Antonazzi and Jacopo M. Orsi.

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