Protecting Travelers from Hotel Impersonation: A Framework for the Age of AI
Reserving a hotel room should be simple. Travelers should be able to compare hotels and prices across multiple services and choose where and how they make a reservation. But they should never be misled into believing that a third-party service is the hotel or an official hotel booking channel.
Recent advances in artificial intelligence (AI) have lowered the barriers for bad actors to create sophisticated and convincing websites, advertisements, communications, automated systems, and other digital interactions that impersonate hotels or hotel brands. These practices can deceive travelers into believing they are dealing directly with a hotel when they are transacting with a third party, even when the resulting reservation is valid. As AI makes hotel impersonation easier to carry out and potentially harder to recognize, clear federal rules prohibiting false representations of hotel identity or official status are increasingly important.
The travel technology and hospitality industries have an opportunity to work together on an approach that protects travelers from hotel impersonation while preserving competition and consumer choice.
“Protecting travelers from hotel impersonation requires staying ahead of evolving technology and the ways bad actors can misuse it. As AI lowers the barriers to creating convincing impersonations of hotels and hotel brands, the travel technology and hospitality industries have an opportunity to address these threats together.”
Laura Chadwick, President & CEO, Travel Tech Association
A Legislative Framework Focused on Stopping Impersonation
Travel Tech has developed a legislative framework for a proposed bill called the Trusted Reservations Using Seller Transparency Act (TRUST Act). The framework outlines clear, enforceable prohibitions against hotel impersonation and stronger tools for law enforcement to pursue bad actors.
In a 2017 report to Congress, the Federal Trade Commission recommended that policymakers address third-party booking services that misrepresent themselves as hotels or hotel affiliates without imposing unnecessary requirements on third-party services that do not engage in such conduct.
Travel Tech’s framework follows that approach. It identifies five practices that the proposed legislation would prohibit:
- Pretending to be the hotel. A third-party service could not state that it is the hotel, hotel operator, or hotel brand.
- Falsely claiming “official” status. A third-party service could not use terms such as “official site,” “official website,” “official booking site,” or “official reservation site,” or substantially identical terms, unless the representation is true or expressly authorized by the hotel or brand.
- Using hotel or brand names in domain names. A third-party booking service could not use a hotel or brand name, including a misspelling or confusingly similar variation, in a registered domain name or subdomain.
- Passing off its own contact information as the hotel’s. A third-party service could not falsely present its phone number, email address, messaging service, AI interface, or other contact method as belonging to the hotel.
- Operating without basic identifying information. Consumer-facing services would have to make basic information about the person or company behind the service available, helping enforcement agencies identify and pursue violators.
The proposed prohibitions against false representations of hotel identity or official status would apply regardless of the medium, including websites, advertisements, search results, social media, call centers, automated systems, AI-powered services, and conversational interfaces. The domain-name restriction would apply independently as a specific prohibition.
Stronger Enforcement
By establishing specific prohibited practices, Travel Tech’s framework would enable regulators to address hotel impersonation even as the methods used to carry it out evolve.
Rather than relying solely on case-by-case determinations that a practice is unfair or deceptive, the framework calls for bright-line prohibitions against specific impersonation practices.
Under the proposed framework, the Federal Trade Commission and state attorneys general would enforce the rules, with civil penalties of up to $10,000 per day for knowing violations. A federal court could also suspend or disable websites and domain names used to commit violations and, following a final determination of a knowing violation, permanently cancel the domain name.
A Clear Federal Standard
The framework would build on existing federal and state laws addressing mandatory fees, fraud, deceptive practices, trademark infringement, false advertising, and other unlawful conduct by establishing federal rules specifically targeting hotel impersonation and providing direct enforcement tools when violations occur.
As AI reshapes how travelers search for and reserve hotels, clear prohibitions against impersonation can protect travelers without imposing unnecessary restrictions on third-party booking services that do not engage in prohibited conduct.
Learn More
Learn more about AI, hotel impersonation, online hotel booking deception, and how travelers can be protected.
