These practices were facilitated by Delivery Hero’s minority shareholding in Glovo, which created a channel for coordination and later culminated in full ownership in July 2022. The EU Commission found that this relationship enabled sustained collusion, reducing consumer choice, limiting employment mobility and undermining innovation in a fast-growing digital sector.

Both companies acknowledged their involvement and opted to settle the case, receiving a 10% reduction in fines. The Commission highlighted this decision as a landmark case:

  • the first cartel finding in the EU’s labour market context; and
  • the first time a company was fined for using a minority shareholding to facilitate anti-competitive conduct.

The EU Commission noted that it will ensure fair competition in digital markets and warned that similar scrutiny may follow in other sectors where platform dominance and cross-ownership raise competition concerns.

Please here see for further details.

In June the French competition authority adopted a decision imposing fines on Alten, Expleo, Bertrandt and Ausy for mutual agreements not to hire each other’s employees. This is likely to impact crew and key employee employment terms and poaching practices. Please see further details.

On the radar

The Transport, Telecommunications and Energy Council has submitted to the EU Parliament a proposal to reform EU Regulation 261/2004. This regulation governs compensation for delayed and cancelled flights and the key proposed changes include:

  • revised mandatory compensation for delayed flights;
  • 14-day payment period for compensation;
  • reimbursement of up to 400% for rerouted flights;
  • a definition of ‘exceptional circumstances’; and
  • tarmac delays expressly included in the scope of the regulation.

The EU Parliament will now consider the proposed reforms and has the power to accept, reject or amend them.

Japan

In July 2025, Japanese police arrested a 28-year-old man on charges of fraudulent obstruction of business and intent to harass. He is alleged to have made 580 reservations at a hotel near Haneda Airport using several false names. This included making 258 bookings in a single night from a computer at his then employer. This has resulted in losses for the hotel of JPY17m (approximately US$113,787). This appears to be related to issues which arose during a stay at the hotel in November. The hotel, which has not been publicly identified, does not appear to require a credit card for bookings. While this is not unusual in the Japanese domestic hotel sector, requiring a credit card would have made it more difficult for this individual to make these bookings without the prospect of being charged for the bookings or at least a no-show fee. It is also likely that the credit card issuer would have suspended the card for suspected fraud where 258 bookings were made at the same hotel in one night.

What to watch

This is a timely reminder that online platforms should be vigilant for fraud and misuse in all markets and to ensure that their fraud detection systems could identify these transactions and suspend or cancel them as quickly as possible.

Thailand

Passenger rights for delayed and cancelled flights now in force.

On 20 May 2025, the Thai Civil Aviation Authority (“CAAT”) Regulation 101 came into force and provides passengers with rights in relation to delayed and cancelled flights and in respect of downgrades, upgrades and tarmac delays. These follow a similar structure to the compensation available in the European Union under EC Regulation No. 261/2004. The CAAT introduced these regulations to ensure passengers on international flights have rights where their flights are delayed or cancelled. This was prompted, in part, by complaints from passengers on delayed and cancelled international flights departing Thailand. Thailand had existing regulations for passenger rights and compensation for delayed and cancelled flights, but this only applied to domestic flights. Regulation 101 increases compensation for domestic flights under this existing regime. A key aspect of payment of compensation for cancelled or delayed flights is that compensation must be paid in cash immediately in case of domestic flights, and within 14 days of the affected flight in case of international flights. Where a passenger has booked and paid for the flight on a third-party platform, such as an online travel agent (“OTA”), the airline may not have the passenger’s payment details and must then be requested from the passenger. Passengers can also agree to be paid in the form of a credit or voucher for future travel, frequent flyer miles and other non-cash compensation. Whilst this should be dealt with between the airline and affected passengers, OTAs and other intermediaries should be prepared to receive and respond to claims from affected passengers for compensation and attempts by passengers to seek to book flights on that airline through an OTA platform using airline credits or vouchers.

On the radar

Regulation 101 requires airlines to have in place arrangements for hotels and meals for affected passengers by May 2024 rather than allowing airlines to deal with the need for accommodation as and when this becomes necessary. Airlines and airport hotels who have agreed terms and rates in May 2024 for passengers on delayed and cancelled flights will need to address changes in rates and availability as and when airlines require accommodation for affected passengers, particularly where the affected flight is several months after these rates were agreed. A key issue may be whether unavailability of rooms would constitute a breach of such agreements.

On 5 July, Thailand issued the Notification of the Electronic Transactions Commission on Measures to Prevent Technological Crimes for Social Media Service Providers. This requires social media platforms to remove false or falsified content which could result in a cybercrime within 24 hours of notice to do so from the Prevention and Suppression Division of the Ministry of Digital Economy and Society. The power of government agencies to do so results from an April 2025 amendment to the Cybercrime Prevention and Suppression Measures Emergency Decree 2023.