The Ministry of Economy explicitly confirmed this in its clarification on the application of the new rules.
However, this does not mean that the entire tourism sector is exempt from the new obligations. Physical price lists, statically published prices, additional services, travel-agency fees, and the publication of price lists in CSV or XML format must be considered separately.
This is where most of the confusion arises.
From 1 October 2026, two different decisions apply. One regulates the display of an additional, or anchor, price alongside the current price. The other requires the publication of a machine-readable price list on your own website.
In this article, we separate what has been officially confirmed from what is still not sufficiently clear.
What is an anchor price?
The official term is “additional price”, while the public mostly uses the term “anchor price”.
For services, this is the regular retail price that applied on 10 September 2026. If the service was on promotion or discounted on that date, the anchor price is not the reduced amount but the regular price before the discount.
For example, if an additional service costs EUR 150 today and its regular price on 10 September was EUR 140, the display may look like this:
- Current price: EUR 150
- Price on 10 September 2026: EUR 140
If the price has not changed, both amounts are still displayed, even if they are the same.
It is important to understand that the anchor price is not a price freeze. The service provider may still change the current price. The additional price simply shows the consumer how much the same service cost on the prescribed reference date.
Two decisions that should not be confused
The first decision concerns the visible display of the additional price.
Under it, traders and service providers should clearly, visibly and legibly show, alongside the current retail price, the price that applied on 10 September 2026.
The second decision regulates the publication of price lists on websites.
A service provider that has its own website should publish the current price list in CSV or XML format suitable for automated processing.
These are two separate obligations.
Therefore, the exemption for displaying accommodation prices in a booking system cannot automatically be applied to a physical price list, additional services, or a CSV/XML file.
Where accommodation prices do not need an anchor price
The Ministry of Economy explicitly stated that the obligation to display an additional price does not apply to accommodation prices shown:
- in your own booking systems
- on intermediary platforms for renting accommodation
This means that hosts, hotels, campsites and other accommodation providers do not need to show, alongside a search result in their own booking engine, the price that applied on 10 September.
The same applies to accommodation prices on platforms such as Booking.com and Airbnb.
There is no need to change the booking process, try to display a historical price for every future date, or ask a platform to introduce data that it does not technically support.
This is also the most important confirmed information for the tourism sector.
What about physical and static price lists?
The official exemption applies to accommodation prices displayed through booking systems and intermediary platforms. It does not say that all accommodation prices are exempt regardless of where they are displayed.
If a host has a physical price list in the apartment or statically publishes a price on a website such as “Apartment A in July: EUR 150 per night”, that display is not necessarily part of a booking system.
For such situations, the Ministry has not yet published a specific tourism example. Under the general rule, the safest approach is to show, alongside the current price, a comparable price that applied on 10 September 2026.
For a seasonal price list, the same service should be compared: the same accommodation unit, season, rate, and calculation method.
It would not make sense to compare the price of an apartment in July with the price of the same apartment in November. The anchor price must relate to a genuinely comparable service.
What applies to private hosts
The decisions do not introduce separate rules for flat-rate private hosts, sole traders, and companies.
The Ministry describes the scope broadly and states that the legal form is not decisive when someone provides a service to a consumer as part of a registered activity. Therefore, it is not safe to conclude that a private host has no obligations simply because they do not operate as a sole trader or company.
For a private host, the most important practical rules are:
For a private host, the most important practical rules are:
- the accommodation price in your own booking engine does not need an anchor price
- the accommodation price on Booking.com, Airbnb and other OTA channels is also exempt
- for a physical or static price list, the more cautious general rule should be applied
- additional services that the host charges separately are not automatically exempt
- a Facebook or Instagram profile is not considered your own website for the CSV/XML price-list obligation
If a host does not have their own website, they do not need to create one solely to publish a digital price list.
Hotels, campsites and hostels
The booking-system exemption also applies to hotels, campsites, hostels and other registered accommodation providers.
However, larger properties often sell more than just overnight stays. Parking, transfers, spa treatments, equipment rental, late checkout, additional cleaning and other services may have separate prices.
If a property directly provides and charges the guest for such a service, the exemption for the accommodation price does not automatically cover it.
Similarly, a restaurant, bar, wellness centre, shop or another point of sale within a hotel may have its own price lists and separate obligations.
For food, beverages, cosmetics and other products already covered by earlier rules, it should be checked whether the reference price from 2 May 2025 applies instead of the price from 10 September 2026.
Travel agencies and intermediaries
For travel agencies, the answer depends on the business model.
It is not enough to know that a business is an agency. You need to determine whose service is being sold, who sets the price, who issues the invoice, and whether the agency charges the traveller its own fee.
| Situation |
What applies |
|---|---|
| When the agency only intermediates |
If an agency or platform acts as an intermediary and displays accommodation from a third-party provider, it does not show an anchor price next to that accommodation price. The Ministry confirmed that the obligation does not apply to intermediary channels when they display or sell products and services of other entities. |
| When the agency charges its own fee |
A booking fee, service fee, administrative fee or another service that the agency charges directly to the traveller is not the price of someone else’s accommodation. Such a fee is the agency’s own service. The general rules on the current and additional price apply to it. |
| What about commission paid by the host? |
Commission paid by the host to the agency in a business relationship is not a price displayed to the end consumer. It is a B2B relationship, while the new decisions are aimed at retail prices and consumer protection. Such an internal commission is therefore not anchored as a consumer price. |
Package holidays and merchant models
The situation is more complex when an agency sells a package in its own name, sets the final price itself, or operates under a merchant or net-rate model.
In that case, the package may represent the organiser’s own service rather than merely intermediation in the sale of someone else’s accommodation.
For such business models, the exemption that applies to pure intermediaries should not be applied automatically. An answer must take into account the contract, the invoice issuer, how the price is formed, and responsibility towards the traveller.
Must a CSV or XML price list be published?
This is a separate obligation and currently the biggest open question for the tourism sector.
The decision on publishing price lists requires a service provider with its own website to publicly publish the current price list for its services in CSV or XML format.
The Ministry clarified that the obligation also applies to websites used only to present a property or business. It does not matter whether prices are already visibly displayed on the site.
A social-media profile is not considered a website for this obligation.
The service price list should contain:
- service name
- current retail price
- information on a special form of sale, if applicable
- the additional, or anchor, price
The service provider updates the price list when a price changes, no later than 8:00 on the day the change takes effect. Previous versions must remain publicly available for 30 days.
The official clarification does not contain an explicit exemption for accommodation from this obligation. Therefore, the wording of the Decision indicates that an accommodation provider with its own website should have a machine-readable price list.
What is still not sufficiently clear is how dynamic and seasonal accommodation prices should be represented in such a file.
How to anchor dynamic and seasonal prices
Accommodation prices often depend on dates, number of guests, length of stay, occupancy, cancellation terms and other rules.
The Ministry states that for services whose final price depends on demand, an algorithm or other parameters, the additional price refers to the individual elements of the final price that applied on 10 September 2026.
For services that do not have a predetermined final price, the digital price list publishes the calculation elements rather than every calculation prepared for an individual guest.
This provides direction, but it still does not provide a complete technical answer for tourism.
It has not been officially determined whether a CSV or XML file should contain:
- the price of each accommodation unit for each future date
- the base price by season
- a price range
- percentage adjustments
- minimum-stay rules
- the complete dynamic-pricing formula
For that reason, a proprietary technical model should not be presented as an officially confirmed solution.
Accommodation providers should retain evidence of the situation on the reference date: base and seasonal prices, additional-person charges, final-cleaning charges and other items, as well as relevant parameters that affected the calculation.
What to do before 1 October
The first step is not to change the booking engine. The first step is to list every place where prices are displayed.
Check:
Check:
- the physical price list at the property
- static prices on your own website
- your own booking system
- Booking.com, Airbnb and other platforms
- social media and advertising
- additional services and fees
- your own website and the ability to publish a CSV or XML file
Then separate the accommodation price from other services.
Do not add an anchor accommodation price to booking-engine results and do not try to change OTA channels. The exemption for those displays has been officially confirmed.
Keep records of the prices and parameters that applied on 10 September 2026. If you introduced a new service after that date, keep the price and the date when it was first introduced.
If you have a physical or static public price list, apply the general rule and prepare a comparable additional price.
If you have your own website, check the obligation to publish a CSV or XML price list and how previous versions must be retained.
What we still do not know
We still do not have a sufficiently precise official answer to several important questions:
- which elements of a dynamic accommodation price should be published in the CSV or XML file
- whether the price of each unit should be published for each date
- how to proceed when a static price is technically part of a booking widget
- how exactly to treat merchant, net-rate and package models used by travel agencies
- when a personalised offer is considered price advertising
- how to apply the rules to social media when a post states a specific price
This is not an area for guessing.
Uncertainty does not mean that an obligation definitely does not exist. It means that major changes to the booking process or pricing model should be based on a written and verifiable interpretation.
Conclusion
The most important news for hosts, hotels and travel agencies is that the anchor price for accommodation is not displayed in their own booking system or on intermediary platforms.
Booking engines and OTA channels therefore do not need to be changed in order to display a historical accommodation price.
On the other hand, physical and static price lists, additional services, own fees, and the CSV or XML price list require separate review.
The most reasonable step now is to list all channels and services, preserve the data from the reference date, and make only those changes that have a clear basis in the Decisions or the official clarification.
For dynamic prices and complex business models, more precise answers are still needed. Until they are available, it is more accurate to say “not confirmed” than to present an assumption as an obligation.
This article is for information purposes and does not constitute legal advice. For applying the rules to a specific business model, check the latest official guidance or seek advice from a qualified professional.
Talk to the MyRent team about your operating model
Sources
Decision on displaying the additional price, NN 101/2026
Decision on publishing price lists for products and services, NN 101/2026
Ministry of Economy clarification for application from 1 October
RRiF: clarification from the Ministry of Economy
Croatian Chamber of Trades and Crafts: notice on anchor prices
