In October 2022, the Hungarian Competition Authority ("GVH") concluded a set of checks on websites associated with the air travel sector to identify breaches of consumer protection law. The GVH found that the majority of the websites of airlines operating in Hungary (including low-cost airlines) and ticket price comparison websites, distort consumers' choices through undetectable methods. The GVH provided recommendations to the operators of these websites and to consumers to comply with consumer protection regulations.

The sweep

The sweep is a relatively new tool designed to check compliance with, or to detect infringements of, consumer protection law. During the sweep, the GVH particularly focused on the issue whether these websites monitored use dark patterns. Dark patterns are digital messages and user interfaces that can pressure consumers to make undesirable choices without being noticed.

The problems identified during the GVH's sweep

The most common distortions detected by the GVH were:

  1. psychological pressure (e.g. "only 2 tickets available at this price"),
  2. manipulation of perception (i.e. some offers are highlighted in striking colours, while cheaper, simpler solutions are harder to spot),
  3. ambiguous wording,
  4. overloaded information which may confuse and distract consumers, and
  5. concealment of important information and options.

The GVH's recommendations to businesses

  1. avoid urging messages and commercial practices,
  2. present choices in a way that is equally noticeable and clearly worded, and
  3. ensure that the information is transparent and easy to understand by structuring it appropriately.

The GVH's recommendations to consumers

  1. try to resist impulse buying,
  2. do not allow to be rushed into making a decision,
  3. always take the time to compare offers and think carefully about your own needs and options, and
  4. try to filter information and consider how relevant it is to your decision.


At this stage, the GVH only made suggestions to eliminate the unlawful practices of market players. If the GVH finds that businesses do not take appropriate steps to ensure consumer protection regulations, it may initiate competition control procedures.

The press release of the GVH's sweep into the online sales of airline tickets can be found in Hungarian here.

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