Online travel agency eDreams has paid $59,400 in penalties and signed a three-year court-enforceable undertaking with Australia's competition regulator, admitting it told consumers a subscription trial was free while quietly charging some of them anyway, and that it advertised monthly instalments without ever showing the full annual price a customer actually owed.

The Australian Competition and Consumer Commission accepted the undertaking from Vacaciones eDreams, S.L. on 24 June 2026, following an investigation into pricing claims made through the eDreams Prime subscription service between November 2021 and July 2025. Two separate patterns of conduct were at issue, and the company has admitted to both.

The first concerned the so-called "free trial" of Prime, a membership program bundled into eDreams flight and hotel bookings that promises discounted airfares and accommodation rates. From at least November 2021, the company displayed the trial price as "$0.00" or "FREE" at checkout. What it did not adequately disclose, according to the ACCC, was that the trial was only ever available to first-time subscribers. Anyone who had previously held a Prime membership, whether through eDreams itself or one of its sister brands, was not eligible. Yet the checkout screen gave no indication of that condition. The consequence was structural: eDreams began running eligibility checks after the checkout process, not before it, and consumers who failed those checks were charged the Prime membership fee during what they had been told was a cost-free period.

That detail matters because it shifts the failure from a labelling oversight into something closer to a sequencing problem baked into the transaction flow itself. A consumer could complete a booking, see a "$0.00" trial price, confirm payment details, and only then discover - via a charge on their statement rather than a warning on the page - that they never qualified for the free period at all.

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A second, separate pricing gap

The undertaking also covers a distinct issue involving how eDreams presented the ongoing cost of Prime membership once the trial period ended. From approximately 29 January 2025, the company's website listed monthly instalment prices for the annual Prime subscription: $13.99 a month for the standard Prime tier, or $16.99 for Prime Plus. Nowhere alongside those monthly figures, however, did the site prominently display the actual total a consumer was committing to pay. That total, according to the ACCC's published undertaking, came to $167.88 for the Prime membership or $203.88 for Prime Plus - the true minimum cost of the twelve-month term a customer was signing up for when they clicked to join.

Under the Australian Consumer Law, a business that states part of the price for a subscription must also specify, in a single figure and in a prominent way, the total minimum amount payable across the full commitment period. Advertising $13.99 "per month" without also showing $167.88 as the number that would actually leave a customer's account over the year is precisely the kind of partial disclosure the law was written to prevent.

"Businesses should be clear about any eligibility criteria when offering consumers a free trial. Consumers may have been misled into subscribing to a membership they might not have signed up for, had they known they were ineligible for the free trial," ACCC Commissioner Luke Woodward said, according to the regulator.

On the separate instalment pricing issue, Woodward added: "The law requires businesses to be upfront about the total price consumers have to pay for goods or services. Businesses must be clear about the minimum total amount consumers must pay for a subscription."

What eDreams admitted and what it will pay

eDreams has operated in Australia since 2009 and is a subsidiary of eDreams ODIGEO, S.A., an entity registered in Spain whose broader portfolio includes Opodo, GOVoyages, liligo and Travellink. It provides comparison, search and booking services for flights and hotels through its website and app.

The $59,400 in penalties arrived through three separate infringement notices issued by the ACCC before the undertaking was finalised. An infringement notice is a mechanism the regulator can use when it has reasonable grounds to believe a business has contravened specific provisions of the Australian Consumer Law; paying the specified penalty does not, in legal terms, constitute an admission of contravention. The undertaking accepted on 24 June 2026 goes further than that administrative step. In it, eDreams formally admits that its free trial conduct contravened or was likely to contravene sections 18 and 29(1)(i) of the Australian Consumer Law, covering misleading or deceptive conduct and false representations about price. Separately, it admits that its instalment pricing conduct contravened or was likely to contravene section 48, which governs the disclosure of total minimum prices for services sold in parts.

The signed document, executed on 12 June 2026 on behalf of Vacaciones eDreams and accepted by the ACCC's Deputy Chair on 24 June 2026, runs for a three-year term. Under its terms, eDreams has already taken several corrective steps, effective from July 2025. The company added the phrase "for first-time subscribers only" to the Prime information displayed on its search results page and to the embedded Prime selection widget shown to consumers at checkout. It amended the wording on key pages, including its "What is Prime" page, to clarify that the Prime term is a full annual membership into which consumers are automatically enrolled once the trial period ends. And wherever a monthly instalment figure now appears for the Prime subscription, the website must also display the total yearly price in a clear and prominent manner.

Refunds for affected consumers

Beyond the corrective website changes, the undertaking sets out a formal remediation program covering every consumer who signed up for a Prime trial between 1 November 2021 and the date the undertaking took effect, and who was subsequently charged the Prime fee during that trial period. Under the program's terms, eDreams must publish a secure online portal within six weeks of the undertaking's commencement date, accessible via a link on its Australian homepage, through which eligible consumers can confirm their details and receive a refund equal to the Prime fee they were incorrectly charged.

The remediation process differs slightly depending on a consumer's current status. Customers who no longer hold an active Prime account will receive an email notification directing them to the portal, followed by a further notice if they do not respond within 21 days, and a text message attempt if a second notice also goes unanswered. Customers who still hold an active Prime account, but who have not already had a refund applied, will likewise be notified by email; if 21 days pass without a response, eDreams must automatically credit the refund amount to that customer's Prime account. Consumers whose Prime membership carried on into a subsequent term following their initial trial will have the refund credited automatically, with a confirmation email to follow. Any consumer who disputes eDreams' handling of a refund claim can have the matter referred to an independent reviewer nominated by eDreams and approved by the ACCC, who must issue a determination within 14 days.

Separately from the refund mechanism, eDreams has committed to implementing what the ACCC's public register describes as a Level 3 Compliance Program, one of the more substantial tiers of compliance commitment the regulator uses in section 87B undertakings. Under its terms, the company must appoint a dedicated compliance officer and an internal or external compliance advisor within three months of the undertaking's commencement, commission a formal risk assessment of where its practices could breach the Australian Consumer Law, issue a company-wide compliance policy, build a complaints-handling system consistent with the Australian and New Zealand standard for complaint management, and conduct staff training and induction on consumer law obligations at least once a year. An independent reviewer must examine the program annually for the full three-year term and report findings to eDreams' governing body, with any material failures reported directly to the ACCC.

Why this case matters for the marketing community

For performance marketers and subscription businesses operating in Australia, the eDreams undertaking lands inside a pattern the ACCC has been building for more than a year and one that PPC Land has tracked closely across the travel, retail and software sectors. The regulator named subscription traps and dark patterns as an explicit 2026-27 enforcement priority, and eDreams becomes the latest company to test that stated focus against a real business model. The mechanics of the case, particularly the eligibility check running after checkout rather than before it, echo a structural theme that has surfaced in several unrelated actions this year: liability rarely stops at the advertisement or the landing page. It follows the consumer through to the point where money actually changes hands.

That theme was visible in the ACCC's Federal Court case against JustAnswer, where a chat widget promised a single AU$2 joining fee while enrolling consumers in recurring monthly charges of between $50 and $90. It was present too in the HSK United enforcement action, which addressed a different pricing mechanism, strikethrough discounts, but rested on the same underlying legal principle: a reference point shown to a consumer must reflect reality, not a marketing convenience.

The instalment pricing half of the eDreams case carries its own significance for subscription-based businesses generally. Displaying $13.99 "per month" is not, by itself, a violation. The violation arises when that monthly figure is not accompanied, with equal prominence, by the total amount a consumer must actually commit to paying. This is a design decision as much as a legal one. Checkout flows, pricing widgets and promotional banners are built by product and marketing teams working from conversion data, and a monthly price will almost always look more attractive than an annual total displayed alongside it. The ACCC's position is that attractiveness cannot come at the expense of accuracy.

The case also arrives against a backdrop of continued regulatory attention to how subscription businesses price and market their services more broadly. The ACCC's February 2026 enforcement priorities announcement cited findings from its Digital Platform Services Inquiry showing that 72 percent of Australian consumers surveyed had encountered potentially unfair practices across digital marketplaces in a twelve-month window. Commissioner Woodward's comments in the eDreams matter mirror language he used in a separate case earlier this year, when the ACCC fined PhotobookShop $39,600 over undisclosed influencer partnerships, reinforcing that this enforcement effort spans multiple categories of digital marketing conduct, not a single sector or business type.

For travel-sector marketers specifically, the eDreams case is a reminder that subscription add-ons layered onto a core booking product, a common monetisation strategy across online travel agencies, carry the same disclosure obligations as any standalone subscription service. A free trial offer embedded inside a flight or hotel checkout flow is still a free trial offer, and the eligibility conditions attached to it still need to be shown to the consumer before they commit, not discovered afterward on a bank statement.

Timeline

  • 1 November 2009: eDreams begins operating in Australia.
  • 1 November 2021: eDreams introduces a "free trial" of its Prime Subscription Service during the online booking process, typically for 15 days.
  • May 2024: eDreams begins conducting eligibility checks after the checkout process, immediately charging consumers identified as ineligible for the trial.
  • 29 January 2025: eDreams begins publishing monthly instalment prices for its annual Prime subscription without also displaying the total minimum annual cost.
  • July 2025: eDreams ceases the conduct at issue, updating its website to disclose trial eligibility conditions and total annual prices.
  • 12 June 2026: The section 87B undertaking is executed on behalf of Vacaciones eDreams, S.L.
  • 24 June 2026: The ACCC's Deputy Chair accepts the undertaking, which takes effect for a three-year term ending 24 June 2029.
  • 29 June 2026: The ACCC publishes its media release confirming eDreams paid $59,400 in penalties across three infringement notices.

Summary

Who: The Australian Competition and Consumer Commission (ACCC) and Vacaciones eDreams, S.L., trading as eDreams, an online travel agency operating in Australia since 2009 and a subsidiary of eDreams ODIGEO, S.A. of Spain.

What: The ACCC accepted a court-enforceable undertaking from eDreams after the company admitted its conduct contravened or was likely to contravene the Australian Consumer Law in two respects: representing its Prime subscription trial as free without disclosing that only first-time subscribers were eligible, and publishing monthly instalment prices for annual Prime subscriptions without displaying the total minimum cost. eDreams separately paid $59,400 in penalties across three infringement notices and has committed to refunding affected consumers and running a three-year compliance program.

When: The conduct at issue occurred between November 2021 and July 2025. eDreams ceased the practices in July 2025. The undertaking was executed on 12 June 2026 and accepted by the ACCC on 24 June 2026, running for a three-year term to 24 June 2029. The ACCC published its media release on 29 June 2026.

Where: The conduct occurred on eDreams' Australian website and app, and the undertaking was accepted by the Australian Competition and Consumer Commission in Australia.

Why: The ACCC found that eDreams' checkout process misled consumers into believing a Prime subscription trial was free when undisclosed eligibility conditions meant some were charged immediately, and that its pricing displays failed to show consumers the true total cost of a subscription commitment they were entering into, both practices the regulator has identified as recurring risks across Australia's subscription economy.