Suspected deception of ticket buyers and psychological pressure

Budapest, August 5, 2025 – The Hungarian Competition Authority (GVH) has opened a competition supervision proceeding against Ryanair. The GVH suspects that the Irish-based discount airline is engaging in unfair commercial practices in several respects when it comes to online flight bookings. The company may have misled consumers and employed psychological pressure, known as 'dark patterns', to encourage ticket buyers to opt for more expensive service packages.

The GVH has found that Ryanair DAC (Ryanair) provides consumers with misleading and untimely information in several respects during the online ticket purchase process on its Hungarian-language website. The GVH suspects that the company does not adequately inform ticket purchasers about fare package options and certain optional services when tickets are purchased for a round trip (return tickets) and when booking for multiple passengers at the same time, does not adequately inform ticket purchasers that the fare package options and certain optional services must be paid for separately for each leg of the journey and for each passenger individually.

In this context, Ryanair displays the prices of the "Regular", "Plus" and "FlexiPlus" fare package options, as well as the fees for the optional services "Priority Boarding and 2 Cabin Bags", "10 kg Checked Baggage", "20 kg checked baggage" and "Security Fast Track" optional services. Ryanair is likely engaging in unfair commercial practices, thereby inducing consumers to make transactional decisions that they would not otherwise make.

The GVH also noted that Ryanair, on its Hungarian-language website, during the online ticket purchase process, is likely to be engaging in practices that may distort consumers' transactional decisions by exerting psychological pressure and confusing consumers. In this context, the company uses eye-catching colours, images, and captions to give the impression that the "Regular" fare package option and its additional services are more favourable than the "Basic" fare option. However, the GVH noted that the final fee payable may be lower if consumers add the same additional services that are otherwise included in the "Regular" fare package option to the "Basic" fare option individually and manually during the purchase process. Furthermore, through manipulative practices related to the promotion of the optional "Security Fast Track" service (e.g., pop-up windows, urgent messages). Ryanair is likely to significantly restrict consumers' freedom of choice and behaviour in relation to the product, thereby also engaging in unfair commercial practices.

The initiation of these proceedings does not imply that the companies have committed the suspected infringements. The procedures aim to establish the facts and, where appropriate, confirm the alleged unlawful conduct. The statutory timeframe for each proceeding is three months, which may be extended twice, each time by up to two months, if justified. As required by the Competition Act, the period between the GVH’s request for information and its fulfilment by the parties does not count towards the procedural time limit.

In recent years, the Hungarian Competition Authority has paid particular attention to the domestic air transport market. In October 2022, the GVH conducted a thorough investigation to determine whether airlines operating in Hungary, including low-cost/discount carriers, utilise so-called dark patterns in their ticket sales and advertising practices.

In recent years, the GVH has received an increasing number of complaints and reports concerning the practices of airlines. In view of the increased number of consumer reports and market anomalies related to the functioning of the air transport market, in the summer of 2024, Csaba Balázs Rigó, President of the GVH, exercised his authority and sent a warning to the heads of several airlines operating on the Hungarian market.

The official registration number of the case is VJ/28/2025.

GVH Press

Further information:

Bálint Horváth, Head of Communication +36 20 238 6939

Katalin Gondolovics, Spokesperson +36 30 603 1170

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