Hotel impersonation occurs when a third-party service falsely presents itself as a hotel, hotel brand, or official hotel booking channel. These misrepresentations can mislead travelers about who they are dealing with when making a reservation.
Recent advances in artificial intelligence (AI) have lowered the barriers to creating sophisticated and convincing websites, advertisements, communications, and digital interactions that falsely appear to originate from hotels or hotel brands. As AI capabilities continue to evolve, these impersonations could become even more difficult for travelers to recognize.
What is hotel impersonation?
Hotel impersonation occurs when a third-party service falsely presents itself as the hotel, hotel operator, hotel brand, or an official hotel booking channel.
This can include falsely claiming “official” status or presenting a third party’s phone number, email address, messaging service, AI interface, or other contact method as belonging to the hotel. Travel Tech’s legislative framework would also prohibit third-party booking services from using hotel or brand names, including misspellings or confusingly similar variations, in registered domain names or subdomains.
Does hotel impersonation mean the reservation is fraudulent?
No. Hotel impersonation concerns how a third-party service represents its identity or official status, not whether it can make a valid hotel reservation. A service may successfully reserve a room for a traveler while falsely claiming to be the hotel or its official booking channel.
This differs from a scam in which a traveler pays for a reservation that does not exist. Such fraudulent activity is already prohibited by criminal law.
Congress has previously considered legislation titled the Stop Online Booking Scams Act, sometimes referred to as “SOBS,” addressing deceptive practices in the online hotel reservation market. In a 2017 report to Congress, the Federal Trade Commission raised concerns that proposed legislation could impose unnecessary burdens on legitimate third-party booking services. The FTC recommended a more targeted approach focused on prohibiting misrepresentations of hotel identity or affiliation, rather than requiring all third-party sellers to disclose that they were not the hotel.
Travel Tech uses the more precise term “hotel impersonation” to describe the conduct addressed by its framework: falsely presenting a third-party service as a hotel or official hotel booking channel.
How could AI be used for hotel impersonation?
Recent advances in AI have lowered the barriers for bad actors to create sophisticated and convincing websites, advertisements, communications, automated systems, and conversational interactions that deceive travelers into believing they are dealing directly with a hotel or hotel brand when they are actually interacting with a third party.
As agentic AI becomes more widely used in travel, impersonation could also occur through conversational interfaces that allow travelers to search for accommodations and authorize an AI agent to make reservations on their behalf. An AI-powered interface could falsely present itself as a hotel or its official booking channel, leading travelers to believe they are interacting directly with the hotel when they are actually using a third-party service.
The concern is not that an AI agent or interface facilitates a hotel reservation, but that it falsely represents its identity or official status to consumers in doing so.
Could AI make hotel impersonation harder to recognize?
Yes. AI could make false representations of hotel identity or official status more convincing and therefore more difficult for travelers to recognize.
Conversational AI interfaces may make these misrepresentations particularly persuasive because travelers can interact with an AI agent, ask questions, receive personalized responses, and complete a reservation within the same experience.
Under Travel Tech’s framework, an AI-powered service would be prohibited from falsely representing itself as a hotel or official hotel booking channel, including when an AI agent facilitates a reservation on a traveler’s behalf.
How can travelers be protected from hotel impersonation?
Clear prohibitions against false claims of hotel identity or official status can help protect travelers from impersonation across websites, advertisements, search results, social media, call centers, automated systems, AI-powered services, and conversational interfaces.
Travel Tech’s framework also calls for a specific prohibition against third-party booking services using hotel or brand names, including misspellings or confusingly similar variations, in registered domain names or subdomains.
Establishing these prohibited practices would give enforcement agencies more direct tools to pursue violators.
What is Travel Tech Proposing to Address Hotel Impersonation?
Travel Tech Association has developed a legislative framework for a proposed bill called the Trusted Reservations Using Seller Transparency Act (TRUST Act). The framework would establish clear, enforceable prohibitions against hotel impersonation while preserving legitimate third-party booking services and consumer choice.
The framework identifies five specific practices that the proposed legislation would prohibit:
- Pretending to be a 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 contact methods 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.
Why does Travel Tech favor an impersonation-focused approach?
Travel Tech believes consumer protection rules should target hotel impersonation directly, rather than imposing blanket disclosure requirements on third-party booking services who are not engaging in such practices.
Travel intermediaries obtain access to hotel inventory through a variety of distribution arrangements, including direct and indirect contracts with hotels and relationships with other travel companies. The absence of a direct contract with a hotel does not mean that a service is automatically impersonating the hotel or falsely claiming official status.
In its 2017 report to Congress, the Federal Trade Commission recommended modifying proposed Stop Online Booking Scams legislation to avoid imposing undue burdens on legitimate businesses. Rather than requiring all third-party sellers to affirmatively disclose that they were not the hotel, the FTC recommended prohibiting sellers from misrepresenting themselves as the hotel or an affiliated entity.
Travel Tech’s framework follows that targeted approach by establishing clear prohibitions against false representations of hotel identity or official status, along with a specific domain-name restriction, while preserving competition and consumer choice.
How would Travel Tech’s framework apply to AI agents that make hotel reservations?
As AI agents increasingly help travelers search for accommodations and make reservations, they may access hotel inventory through hotels, online travel agencies, and other distribution partners.
Under Travel Tech’s framework, an AI agent or other third-party service would be prohibited from falsely representing itself as a hotel or its official booking channel.
The distinction is important as new AI-powered booking services emerge. Travelers should be protected from hotel impersonation regardless of how they make reservations, without imposing unnecessary restrictions on the intermediaries and technologies that enable travel booking.
Why should the travel technology and hospitality industries work together?
Hotel impersonation is a shared concern for travelers, hotels, and travel technology companies. As AI lowers the barriers for bad actors to impersonate hotels and hotel brands, both industries have an interest in preventing false representations of hotel identity or official status.
By working together to advance the proposed TRUST Act, the travel technology and hospitality industries can strengthen protections against hotel impersonation while preserving competition and consumer choice in how travelers search for and reserve hotels.
How would hotel impersonation rules be enforced?
Travel Tech’s framework proposes enforcement by the Federal Trade Commission and state attorneys general, with civil penalties of up to $10,000 per day for knowing violations.
It also proposes authorizing a federal court to 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.
Learn More
Read Travel Tech Association’s policy statement, “Protecting Travelers from Hotel Impersonation: A Framework for the Age of AI.”
