07 December 2021
This Chapter considers the use of parity provisions, otherwise known as most favoured nation (MFN) clauses, in agreements between suppliers and price comparison tools, and between retailers and online marketplaces.
Two main types of MFN clauses have been considered by competition authorities across Europe:
MFN clauses can also be distinguished according to the factor regulated – price being the most common. Non-price MFN clauses may require the supplier and retailer to offer the same product range, availability, conditions and customer services.
The use of MFNs by price comparison tools and online marketplaces has been the target of a number of antitrust enforcement cases and market studies in Europe:
MFN clauses have largely been analysed as potentially anticompetitive agreements under Article 101 of the Treaty on the Functioning of the European Union (TFEU) and national equivalents (see below for an overview of Article 102 of the TFEU analysis to date).
Two theories of harm have been advanced by European competition authorities in respect of wide MFNs: that they soften competition between platforms, and impede innovation, entry and expansion by new platforms.
Wide MFNs have been alleged to reduce the incentive for platforms to compete on the basis of commission levels by creating ‘price floors’. According to this theory, a platform can increase the commission charged to a supplier who is subject to a wide MFN without the constraint that this supplier could retaliate by setting a higher price and less advantageous conditions on the platform compared with other channels. Instead, short of delisting themselves, suppliers are faced with two options: pass on the commission increase by raising prices across all their distribution channels or maintain current prices and absorb the loss.
In addition, wide MFNs typically spread across a market: competing platforms will have a strong incentive to implement similarly wide MFNs to protect themselves against the risk of rates on their websites exceeding those listed elsewhere. This can result in low levels of price differentiation (i.e., suppliers displaying the same price across all platforms).
Wide MFNs have also been alleged to constitute a barrier to entry, on the basis that online platforms are prevented from entering the market or expanding through a strategy based on offering low commission rates in exchange for better prices and conditions from suppliers (who are constrained by the wide MFNs agreed with other platforms). Platforms can still differentiate themselves based on factors such as quality and brand image; however, these typically require significant upfront investments. As above, these effects are said to be strengthened when MFN clauses spread and become industry standard.
While narrow MFNs have largely been treated positively by NCAs on the basis of associated efficiencies, these potential concerns have been explored: the potential for narrow MFNs to replicate the effects of the wide MFN and restrictions on competition from the direct channel.
Competition authorities have noted that narrow MFNs could have anticompetitive effects if suppliers are not willing to undercut their direct channel (possibly to avoid the cannibalisation of their direct sales). Faced with an increase in commission, these suppliers might opt to raise prices not only on the platform with a narrow MFN and their own website, but also across other channels – thereby replicating the price floor effects of a wide MFN. In particular where competition for the supply of online intermediation services is limited, narrow MFNs may allow platforms to maintain a higher price for their services, leading to higher retail prices for the intermediated goods or services on all sales channels.
Narrow MFNs also have the potential to produce anticompetitive effects by limiting the competitiveness of suppliers’ direct sale channels. However, the extent to which direct channels have the potential to exercise a constraint on platforms varies greatly across markets, as it will depend on factors such as the extent to which consumers shop around between platforms and the visibility of direct channels. Narrow MFNs are likely to have a greater anticompetitive effect if a significant share of sales takes place through the direct channel and narrow MFNs are imposed by multiple platforms.
The Commission’s Vertical Agreements Block Exemption Regulation (VABER) provides a safe harbour for agreements that would otherwise fall under the Article 101(1) prohibition, provided certain conditions are satisfied – including a 30 per cent market share threshold on both the upstream and downstream markets.
It has so far been unclear whether wide MFNs could be exempted under the VABER, and NCAs have previously rejected this notion on the basis that these clauses do not relate to conditions of sale or resale. The UK NCA dismissed the possibility of applying VABER during its PMI market investigation into wide MFNs on the basis that PMI providers and PCWs were competing undertakings that both provide PMI quotes on their websites and compete for customers through advertising. This point can now, however, be considered settled as in its proposed revisions to the VABER (currently under consultation and expected to come into force from June 2022), the Commission explicitly removes the benefit of the safe harbour for across platform parity agreements (wide MFNs) albeit it is still open to parties to individually assess the legal compatibility of wide MFNs – these are not considered ‘hardcore’ restrictions.
Narrow MFNs, however, explicitly benefit from the safe harbour under VABER provided neither of the parties’ market share exceeds the 30 per cent threshold.
Article 101(3) of the TFEU provides for an individual exemption for otherwise anticompetitive agreements on the basis of associated efficiencies. Four specific conditions must be met for an agreement or concerted practice to be exempted from Article 101(1) in this way. In particular, it must: ‘contribute to improving the production or distribution of goods or to promoting technical or economic progress’; allow consumers ‘a fair share of the resulting benefit’; not impose restrictions ‘which are not indispensable to the attainment of these objectives’; and not ‘eliminate competition in respect of a substantial part of the products in question’.
The Commission’s Guidelines on the Application of Article 101(3) provide that an assessment of efficiencies involves a balancing act: taking into account the extent of relevant restrictions of competition and balancing them against the efficiencies that flow from these restrictions, to determine whether the efficiencies outweigh the harm caused by the arrangement. This provides a framework within which to apply the specific conditions of Article 101(3).
In the context of wide and narrow MFNs, given narrow MFNs are contractually less restrictive than wide MFNs, the Article 101(3) threshold should consequently generally be lower.
There has been divergence within Europe as to how NCAs have assessed the efficiency benefits of narrow MFNs.
The UK NCA undertook a detailed analysis of narrow MFNs in its PMI market investigation, and found that such clauses did meet the requirements of Article 101(3). In particular, the UK NCA found that:
As set out above, in the online hotel bookings investigations, several NCAs did recognise the efficiency benefits associated with narrow MFNs and their decisions leave the impression that the decision to accept Booking.com’s commitments was driven by efficiency considerations. For example, the Swedish NCA stated that OTAs can attract customers that the hotels themselves have difficulty reaching, and ‘offer consumers a search and comparison function that individual hotels are unable to offer’. The Swedish NCA found this contributed to ‘price transparency on the market and to increased competition between hotels’ and that, without the narrow MFN, these efficiency benefits would be put at risk through free-riding. The French and Italian NCAs also recognised that hotel booking OTAs give rise to important efficiencies, which would be protected through the narrow MFN commitments.
The German NCA, by contrast, has been unconvinced by the benefits of the narrow MFN – finding instead that the narrow MFN restricts competition and that harm is not outweighed by efficiency gains. In particular, the German NCA found in its decision against Booking.com that none of the conditions of Article 101(3) were met, noting that:
In May 2021, the German Federal Court of Justice in substance endorsed the above position of the German NCA.
Support studies commissioned by the European Commission for its ongoing evaluation of the VABER, published in May 2020, carried out a detailed review of the potential pro-competitive and anticompetitive effects of both wide and narrow MFNs. The study again noted the well-documented efficiencies of narrow MFNs such as protecting platform investments against free-riding, reducing consumer search costs, strengthening inter-brand competition, preventing ‘rent-seeking’ behaviours from suppliers and protecting both platforms and suppliers against demand uncertainty. However, it also noted a risk that these pro-competitive effects could be replaced by negative effects in more concentrated markets or where the parties have high market shares.
The UK NCA considered whether the wide MFN had any incremental benefits over the narrow MFN in its PMI investigation. In particular, it considered efficiency arguments that consumers would not trust PCWs unless they had the best prices across all providers; a wide MFN provides a ‘one stop shop’ further reducing search costs for consumers; and wide MFNs prevent other distribution channels free-riding on the advertising investments of PCWs.
The UK NCA found that these claimed efficiency benefits were not supported by evidence. In particular, it found that many consumers searched across multiple PCWs, ‘suggesting that they did not expect the prices returned through each PCW to be the same’ and that PCWs did not currently operate as a ‘one-stop shop’. With respect to free-riding, the UK NCA drew a distinction between the narrow and wide MFN stating that:
Ultimately, the UK NCA found that even if there were some incremental benefits of wide MFNs ‘such incremental benefits would be unlikely to outweigh the anticompetitive effects of wide MFNs’.
The UK NCA reaffirmed its assessment that wide MFNs were not necessary to deliver any potential benefits to consumers over and above those of narrow MFNs in its DCT market study. Other authorities have also found that the wide MFN does not meet the requirements of Article 101(3).
Another potential approach to justifying MFNs is under the ancillary restraints doctrine. There are arguments that the narrow MFN could be justified as an ancillary restraint, which is a clause that is objectively necessary and proportionate for the implementation of a competitively neutral transaction. Therefore, the same arguments that have been used by PCWs to justify the narrow MFN under an Article 101(3) analysis – namely, that narrow MFNs are necessary to prevent free-riding and ensure credible search and comparison – could also be argued to be a necessary and proportionate restriction for the provision of services by PCWs.
This position was also taken by the Higher Regional Court of Düsseldorf in the Booking.com case on narrow MFNs. It found narrow parity clauses compatible with competition law on the basis that they are a necessary ‘ancillary agreement’ in the contracts with hotels that enable performance of the (pro-competitive) overall contract, and thus considered them exempt from Article 101. Without specifically mentioning efficiencies, the court noted that Booking.com is obliged to perform its part of the contract in advance, and must therefore be able to prevent the ‘evident and serious risk’ that hotels disloyally divert customers to their own sales channels to make the final booking – depriving Booking.com of its commission and disrupting the ‘fair and balanced exchange of services’. The court considered it irrelevant whether Booking.com would be able to prevent the occurrence of free-riding through a different remuneration agreement such as a usage fee, as had been suggested by the German NCA; the starting point is that the disputed price parity clause is a necessary ancillary agreement to implement the contract, and the clause does not go beyond what is proportionate in doing so.
The German Federal Court however overturned this decision in May 2021 on the grounds that the Court did not consider Booking.com’s narrow MFN to be ‘objectively necessary’ for the performance of the main contract which is the provision of online intermediary services. The Court considered that the balancing of pro-competitive aspects of narrow MFNs, such as securing an appropriate remuneration for the platform by solving the free-rider problem or increased market transparency for consumers against their anticompetitive aspects should only happen within the framework of Article 101(3). The interesting legal quirk here is that the burden of proof under Article 101(3) is on the parties to show that the pro-competitive gains of the agreements outweigh the anticompetitive effects, whereas the burden of establishing a restriction of competition in an ancillary restraints analysis rests with the regulator. It remains to be seen how other courts and regulators will approach narrow MFNs in the future and which framework of analysis they seem most persuaded by.
Although MFNs have largely been considered under Article 101, the use of wide MFNs in standard contracts with suppliers by dominant companies could also be found to constitute abuse under Article 102 TFEU, because of concerns around associated exclusionary effects.
In particular, the Commission analysed MFNs under Article 102 in the Amazon e-books MFN investigation. The Commission took the preliminary view that Amazon may have abused its dominant position through a number of MFN clauses requiring e-book publishers and suppliers to inform Amazon about more favourable or alternative terms given to competing platforms (relating to price, promotions and e-book features) and to offer Amazon similar (or better) terms. The Commission considered that such clauses could strengthen Amazon’s position by reducing the ability and incentive of e-book suppliers and competing platforms to develop new business models.
The relevance of Article 102 was also raised in the online hotel bookings cases. In particular, the French NCA noted that the imposition of wide MFNs by one or multiple platforms could be deemed to constitute individual or collective abuse of a dominant position. More recently, pursuant to a complaint from a hotels association, the Spanish NCA has launched an investigation into whether Booking.com has abused its dominant position by imposing narrow MFNs. The current draft of the European Commission’s Digital Markets Act also envisages that ‘gatekeepers’ designated under that Act would not be able to impose wide MFNs.
In the online hotel bookings sector, an ECN working group conducted a year-long monitoring exercise with a view to assessing and comparing the impact of the switch from wide to narrow MFNs across Europe on the one hand, and the prohibition of MFNs in Germany and France on the other. The working group carried out a difference-in-differences analysis of room price data obtained from metasearch websites, and found that ‘the switch from wide to narrow parity clauses by Booking.com and Expedia led to an increase in room price differentiation between OTAs by hotels in eight of the 10 participating Member States.’ The ECN indicated that it would continue to monitor the online hotel sector and ‘re-assess the competitive situation in due course’. Subsequently, in July 2020, the European Commission announced a call for tenders for a second market study into the marketing and sale of hotel accommodation in Austria, Belgium, Cyprus, Poland, Spain and Sweden. The market study is intended to provide up-to-date information on how hotels market and sell their rooms, including whether (1) distribution arrangements differ between Member States, (2) there have been changes relative to the findings of the monitoring exercise carried out by the ECN in 2016 and (3) national laws banning MFNs have led to changes in distribution arrangements. The methodology for the study is not yet clear, although the official statement notes that the Member States under investigation have been chosen to provide a sample that is representative in terms of geographic location, population size, degree of concentration of the hotel sector and antitrust or legislative interventions.
The UK NCA also reviewed the impact of the switch from a wide to a narrow MFN by PCWs in agreements with PMI providers as part of its DCT market study in 2017. The econometric analysis carried out showed that ‘commissions have been lower than they would have been since the removal of the wide MFNs . . . this suggest[s] that the impact of narrow MFNs has not (or not fully) replicated that of wide MFNs.’
As noted above, in May 2020, the European Commission published support studies it had commissioned as part of its ongoing review of the VABER. These studies found that while the VABER and Vertical Guidelines remain relevant, they do not adequately address the new issues raised by the development of the digital economy and online sales. In their assessment of MFNs (analysed in detail along with other types of vertical restraints), the studies’ authors undertook an analysis of the hotel sector. The studies, which also relied on a qualitative assessment of stakeholder interviews, ultimately concluded that it was not possible to draw general conclusions as to the effect of narrow as compared to wide MFNs, with the effects varying depending on the characteristics of the market. Nonetheless, the studies’ authors posited that the empirical analysis carried out on the hotel sector suggested that a ban on narrow MFN clauses may decrease prices in that sector, although they acknowledged that such clauses do have important welfare effects for consumers (as discussed in the above section on Article 101(3) efficiencies) and give rise to fewer competition concerns than wide MFNs.
The UK NCA has provided guidance on the scope of narrow MFN clauses as part of its DCT market study. In the NCA’s view, narrow MFNs should not go beyond the scope of what is strictly necessary to achieve related efficiencies. In particular, the UK NCA noted that narrow MFNs should not apply to existing customers (those customers with whom the supplier already has a contract or who participate in a supplier’s loyalty programme) on the basis that free-riding efficiencies are less likely to apply to these customers.
MFN clauses will undoubtedly remain a hot topic in Europe:
1 Philippe Chappatte and Kerry O’Connell are partners at Slaughter and May. The authors would like to thank Sarah de Morant, former associate at Slaughter and May, and Shweta Vasani and Katie Hudson, associates at Slaughter and May, for their contributions.
2 French Competition Authority, Decision 15-D-06 dated 21 April 2015; Italian Competition Authority, Decision dated 21 April 2015; and Swedish Competition Authority Decision 596/2013 dated 15 April 2015.
3 ECN, Report on the monitoring exercise carried out in the online hotel booking sector dated 6 April 2017.
4 German Competition Authority, Decisions B 9 – 66/10 dated 20 December 2013 and B 9 – 121/13 dated 22 December 2015; Press release, Ministry of Justice of Nordrhein-Westfalen, ‘Higher Regional Court of Düsseldorf: Online Hotel Bookings: “Narrow” MFNs are Permitted’ (19 June 2019) www.justiz.nrw.de/JM/Presse/presse_weitere/PresseOLGs/archiv/2019_01_Archiv/04_06_2019_/index.php [Ger.].
5 German Federal Court of Justice, 18 May 2021, https://www.bundesgerichtshof.de/SharedDocs/Pressemitteilungen/DE/2021/2021099.html (Full text decision yet to be published).
6 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013.
7 UK Competition and Markets Authority, Digital comparison tools market study, Final Report dated 26 September 2017; UK Competition and Markets Authority, price comparison website: use of most favoured nation clauses (opened 26 September 2017).
8 Decision of the UK Competition and Markets Authority, Price comparison website: use of most favoured nation clauses (Case 50505) (dated 19 November 2020).
9 German Competition Authority, Decisions B 6 – 46/12 dated 26 November 2013 and B 9 – 121/13 dated 22 December 2015; Office of Fair Trading, Case CE/9692/12 (closed November 2013).
10 AT.39847 E-books, Decision dated 12 December 2012.
11 AT.40153 E-book MFNs and related matters (Amazon), Decision dated 4 May 2017.
12 COM(2017) 229, Final Report on the E-commerce Sector Inquiry dated 10 May 2017.
13 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Para. 8.40-43.
14 ibid., Para. 8.35-39.
15 UK Competition and Markets Authority, Digital comparison tools market study, ‘Paper E: Competitive landscape and effectiveness of competition’ dated 26 September 2017, Para. 3.34-37.
16 Draft Guidelines on Vertical Restraints issued by the European Commission on 9 July 2021, Para. 346 (subject to final consultation and adoption); https://ec.europa.eu/competition-policy/public-consultations/2021-vber_en.
17 See, for example, UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Para. 8.55.
18 Draft Guidelines on Vertical Restraints issued by the European Commission on 9 July 2021, Para. 347 (subject to final consultation and adoption); https://ec.europa.eu/competition-policy/public-consultations/2021-vber_en.
19 Commission Regulation 330/2010 of 20 April 2010 on the application of Article 101(3) of the Treaty on the Functioning of the European Union to categories of vertical agreements and concerted practices (OJ 2010 L102/1, 23 April 2010). This is currently under revision and an updated draft was published by the European Commission on 9 July 2021 (subject to final consultation and adoption).
20 Higher Regional Court of Düsseldorf Administrative proceedings VI-Kart 1/14 [V], Decision dated 9 January 2014, Para. 164–165.
21 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Annex 12.1 Para. 38.
22 Article 5(1)(d) of draft revised VABER.
23 Draft Guidelines on Vertical Restraints, Para. 239 and 336, published on 9 July 2021 (subject to final consultation and adoption).
24 Commission Guidelines on the Application of Article 81(3) of the Treaty (101(3)) (OJ C101/97, 27.4.2004), Paras. 11–12.
25 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Para. 8.82-83.
26 ibid., Para. 8.82.
27 ibid., Para. 8.89-107.
28 ibid., Para. 8.7.
29 ibid., Para. 8.118.
30 ibid., Para. 8.100.
31 ibid., Para. 8.102.
32 Swedish Competition Authority Decision 596/2013 dated 15 April 2015 (English version), Para. 16.
33 ibid., Para. 27.
34 ibid., Para. 30: ‘The Competition Authority’s assessment, which is supported by analysis . . . is in view of the above that the vertical price parity substantially reduces the risk that hotels free-ride on investments made by Booking.com. This in turn allows Booking.com to receive remuneration for its search and compare services so that the services continue to be offered on the market for the benefit of consumers.’
35 See, for example, French Competition Authority, Decision 15-D-06 dated 21 April 2015 (English translation), Para. 289: ‘The commitments allow restoring a balance in the sector, and ensure efficient competition likely to lead to a decrease in the amount of commissions of OTAs while respecting the positive contribution that the latter bring to the sector in terms of economic efficiency’; and Italian Competition Authority, Decision dated 21 April 2015 (English translation), Para. 67: ‘the said commitments are able to remove the anti-competitive concerns that had been identified in the notice of commencement of the investigation. At the same time, we believe that they are able to ensure that consumers have the opportunity to keep using the comparison, research and booking services that it offers for free’.
36 German Competition Authority, Decision B 9 – 121/13 dated 22 December 2015, Paras. 261–267.
37 ibid., Paras. 268–281.
38 ibid., Paras. 283–285.
39 ibid., Paras. 286–298.
40 ibid., Para. 300-302.
41 DG Comp, Support Studies for the evaluation of the VABER – Final Report, Para. 18.104.22.168.1
43 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Annex 12(1)-7, Para. 30.
44 UK Competition and Markets Authority, Private motor insurance market investigation, Final Report dated 24 September 2013, Para. 8.104.
45 ibid., Para. 8.106.
46 ibid., Para. 8.116.
47 UK Competition and Markets Authority, Digital comparison tools market study, ‘Paper E: Competitive landscape and effectiveness of competition’ dated 26 September 2017, Para. 3.16.
48 See, for example, French Competition Authority, Decision 15-D-06 dated 21 April 2015 (English translation), Paras. 134–141.
49 See, for instance, ECJ, Remia, Decision dated 11 July 1985 (C-42/84), Para. 20; ECJ, Oude Luttikhuis, Decision dated 12 December 1995 (C-399/93) Para. 14; and ECJ, MasterCard, Decision dated 11 September 2014 (C-382/12 P), Para. 89.
50 Higher Regional Court of Düsseldorf Administrative proceedings VI-Kart 2/16 [V], Decision dated 4 June 2019, p. 6.
51 ibid., pp. 15–16.
52 ibid., p. 24.
53 German Federal Court of Justice, Decision of 18 May 2021 – KVR 54/20, https://www.bundeskartellamt.de/SharedDocs/Publikation/EN/Pressemitteilungen/2021/18_05_2021_BGH_KVR_54-20_Booking.com.pdf?__blob=publicationFile&v=3.
54 AT.40153 E-book MFNs and related matters (Amazon), Decision dated 4 May 2017.
55 French Competition Authority, Decision 15-D-06 dated 21 April 2015, Paras. 142–146.
56 See the Madrid Hotel Business Association’s press release dated 22 June 2020, available at: https://aehm.es/aehm-denuncia-a-booking-ante-la-cnmc-por-practicas-detrimento-hoteles-asociados/.
58 Article 5 (Obligations for Gatekeepers), Proposal for a Regulation of the European Parliament and of the Council on contestable and fair markets in the digital sector (Digital Markets Act), published 15 December 2020 (subject to consultation and adoption).
59 ECN, Report on the monitoring exercise carried out in the online hotel booking sector dated 6 April 2017, Para. 11.
60 ECN, Outcome of the ECN DGs on 17 February 2017.
61 See the European Commission’s press release dated 9 July 2020, available at: https://ec.europa.eu/cyprus/news/20200709_4_en.
62 UK Competition and Markets Authority, Digital comparison tools market study, ‘Paper E: Competitive landscape and effectiveness of competition’ dated 26 September 2017, Para. 3.48.
63 DG Comp, Support Studies for the evaluation of the VABER – Final Report.
64 ibid., dated 26 September 2017, Para. 3.88.
65 UK Competition and Markets Authority, Price comparison website: use of most favoured nation clauses (opened 26 September 2017).
66 Decision of the UK Competition and Markets Authority, Price comparison website: use of most favoured nation clauses (Case 50505) (dated 19 November 2020).
67 See the Notice of Appeal dated 15 February 2021, available at: https://www.catribunal.org.uk/sites/default/files/2021-02/1380_BGL__Summary_of_claim_150221_0.pdf.
68 Law No. 2015-990 for Growth, Activity and Equal Economic Chances, adopted on 10 July 2015.
69 Draft Federal Act amending the Federal Act Against Unfair Competition 1984 and the Federal Act on Price Marking, adopted on 17 November 2016.
70 Annual Bill for Market and Competition, adopted on 2 August 2017.
71 Act on pricing freedom for tourist accommodation operators in contracts concluded with online reservation platform operators, adopted on 19 July 2018.
72 DG Comp, Support Studies for the evaluation of the VABER – Final Report, Para. 22.214.171.124.
73 ECN, Outcome of the ECN DGs on 17 February 2017.
74 See the European Commission’s press release dated 9 July 2020, available at: https://ec.europa.eu/cyprus/news/20200709_4_en.
75 Regulation (EU) 2019/1150 of the European Parliament and of the Council of 20 June 2019 on promoting fairness and transparency for business users of online intermediation services (OJ 2019 L 186/57) (11 July 2019), Article 10.
76 Proposal for a Regulation of the European Parliament and of the Council on contestable and fair markets in the digital sector (Digital Markets Act) (COM/2020/842 final), available at: https://eur-lex.europa.eu/legal-content/en/TXT/?qid=1608116887159&uri=COM%3A2020%3A842%3AFIN.
77 Article 5(B) of the draft Digital Markets Act.
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