On 13 February 2025, the Montenegrin Agency for Protection of Competition ruled that three travel agencies: Marco Polo Travel Agency, Inter Travel Club, and Zinza Group, all based in Podgorica, engaged in a restrictive agreement during a public procurement process. The case was initiated following a request from the Parliament of Montenegro which acted as a contracting authority.
The investigation revealed that these agencies submitted independent bids with identical pricing, effectively eliminating competition. The tender concerned hotel booking services for official travel. Instead of competing on price or service quality, the three agencies apparently coordinated their offers, each quoting EUR 500 (excl. VAT) for hotel bookings within Montenegro and EUR 500 (excl. VAT) for hotel bookings abroad.
The Agency found that the practice had the aim or effect of restricting, preventing, or distorting competition on the relevant market. Details on the relevant market and the Agency’s competitive analysis are not available, as the Agency publishes only the operative parts of its decisions.
As a result, the agreement was declared null and void, and the Agency prohibited further implementation of the agreement. Additionally, the travel agencies now face potential fines ranging from 1% to 10% of their annual revenue, with the final amount to be determined by the Misdemeanour Court.
This is not the first time the Agency for the Protection of Competition has intervened in the tourism sector. In 2023, the it ruled against the Association of Travel Agencies of Montenegro for fixing service prices across the industry. The association had adopted a uniform price list, which limited competition and violated the Competition Protection Act. The Agency declared the price list prohibited and void, prohibiting its further application. The association was also ordered to submit a clear methodology for determining service prices within 30 days.
Cases like these highlight a potential recurring issue of anti-competitive practices in Montenegro’s travel industry, while simultaneously showing the Agency’s determination to take swift action and scrutinise such anticompetitive agreements. With the Agency adopting a stricter approach to restrictive agreements and upcoming legislative changes set to expand its fining powers, travel agencies and other businesses must ensure their pricing strategies fully comply with the law.
