What hotels can do now: a practical direct-channel action plan
Hotels do not need to wait for Google’s final implementation or the Commission’s assessment before preparing.
Whatever design is ultimately adopted, the strongest response remains a well-managed direct channel supported by reliable data, sound SEO, competitive offers, effective technology and clear measurement.
The immediate objective is not to predict every regulatory or technological outcome. It is to make the hotel’s official information, website, rates and booking journey as accurate, competitive and machine-readable as possible.
The next 30 days: establish the baseline
Monitor the search results travellers actually see
Hotels should begin by documenting their current visibility across the searches that matter commercially.
Monitoring should include:
- Generic destination searches.
- Hotel-category and amenity searches.
- Specific property searches.
- Hotel-brand searches.
- Navigational searches clearly seeking the official website.
- Searches in priority languages and source markets.
- Desktop and mobile results.
- Logged-in and Incognito or logged-out states.
Record:
- Which hotel modules appear.
- Their position and approximate pixel depth.
- Which OTAs and comparison services are present.
- Whether the official website appears.
- Which prices and providers are shown.
- Whether results are labelled as paid or organic.
- Whether AI Overviews or AI Mode affect the journey.
The objective is to create a documented baseline against which future changes can be measured.
Suggested owners: SEO, digital marketing or ecommerce team.
Suggested indicators: official-site visibility, module presence, intermediary visibility, SERP changes by market and query type.
Audit Google Hotel Ads and Free Booking Links
Google Hotel Ads and Free Booking Links remain important parts of the hotel-booking journey. Their configuration should be checked immediately.
Review:
- Feed connectivity.
- Rate and availability accuracy.
- Landing-page functionality.
- Eligibility and participation status.
- Market and device coverage.
- Currency and tax presentation.
- Booking-engine tracking.
- Differences between direct and OTA rates.
Free Booking Link trends can act as an early indicator of changes in unpaid hotel-search visibility. Sustained declines in impressions, clicks, displayed rates or booking value should be investigated rather than treated as ordinary fluctuations.
Suggested owners: ecommerce, revenue management and metasearch provider.
Suggested indicators: eligible impression share, price accuracy, clicks, conversion rate, booking value and cost per direct booking.
Protect the competitiveness of the direct offer
Visibility will not produce direct bookings if an OTA presents a lower price or more attractive conditions beside the official website.
Hotels should compare:
- Public and member rates.
- Cancellation and payment conditions.
- OTA-funded discounts.
- Loyalty-programme benefits.
- Mobile and geographically targeted promotions.
- Room names and inclusions.
- Availability by room type.
- Benefits exclusive to direct booking.
The comparison should cover the full customer proposition—not only the headline nightly rate.
Hotels should also investigate where intermediaries obtain inventory used to undercut the direct offer. It may originate from contracted OTA rates, wholesale distribution, affiliates, resellers or platform-funded promotions.
Suggested owners: revenue management, distribution and ecommerce teams.
Suggested indicators: direct-price competitiveness, undercutting frequency, source of discrepancies and direct conversion rate.
Review measurement before the interface changes further
Traditional organic rankings do not describe the complete journey when travellers interact with hotel modules, metasearch results or AI-generated answers before reaching the website.
Hotels should establish a current measurement baseline covering:
- Organic and paid referral sources.
- Landing pages.
- Branded and generic search performance.
- Google Hotel Ads.
- Free Booking Links.
- Assisted and multi-session conversions.
- Direct-booking volume and value.
- Customer-acquisition cost.
- Paid-versus-organic traffic mix.
- OTA-versus-direct booking share.
- Hotel-brand advertising by intermediaries.
Google Analytics and other reporting systems should be reviewed so that identifiable AI referrals are classified appropriately. However, not every AI-influenced journey will produce a traceable referral. Attribution will remain incomplete and should not be presented as a complete measurement of AI’s effect.
Suggested owners: analytics, SEO, paid media and ecommerce teams.
Suggested indicators: channel attribution coverage, direct-booking cost, assisted conversions and unexplained changes in direct traffic.
The next 90 days: strengthen the direct-channel foundation
Make the official website unmistakable
Search engines and AI systems should be able to identify the hotel’s official domain, booking engine, brand and property relationship without ambiguity.
This requires:
- Clear and consistent hotel identity.
- Strong links between the website and booking engine.
- Verified business profiles.
- Accessible rate and offer pages.
- Accurate contact and location information.
- Clear organisation and property ownership relationships.
- Technically crawlable and indexable content.
- Consistent canonicalisation and international targeting.
The objective is to make the official source recognisable to travellers, search engines and AI systems.
Continue improving technical SEO and local SEO
Established SEO principles remain essential.
Hotels should continue improving:
- Crawlability and indexation.
- Site architecture and internal linking.
- Page performance.
- Mobile usability.
- International and multilingual targeting.
- JavaScript accessibility.
- Canonical tags and duplicate-content management.
- Booking-engine integration.
- Accessibility.
- Security and reliability.
Local SEO also requires continuous attention. Google Business Profile, Apple Business Connect, Bing Places and other relevant profiles should contain complete, verified and consistent information.
Emerging AI interfaces make these foundations more important because machines must be able to identify, interpret and trust the hotel’s information.
Suggested owners: SEO, web development and local-marketing teams.
Suggested indicators: indexed pages, technical errors, Core Web Vitals, local-profile completeness, organic visibility and direct-site engagement.
Build a reliable hotel knowledge base
Hotels should maintain a structured source of truth covering:
- Property identity and brand.
- Address, coordinates and contact details.
- Room types and occupancy.
- Amenities and services.
- Restaurants, spas and other facilities.
- Policies.
- Accessibility information.
- Sustainability information.
- Images and usage rights.
- Rates, packages and direct benefits.
- Destination and transport information.
- Frequently asked questions.
This information should be consistent across the official website, booking engine, business profiles, distribution feeds and relevant OTA profiles.
The knowledge base should support both content production and structured machine access. Changes should have clear owners, approval processes and update dates.
Suggested owners: marketing, operations, revenue management and technology teams.
Suggested indicators: data completeness, cross-platform consistency, correction time and content freshness.
Improve structured data and machine readability
Structured data should accurately represent the hotel rather than merely satisfy a validation tool.
Review:
- Hotel and lodging-business schemas.
- Organisation and brand relationships.
- Postal address and geographical data.
- Amenities.
- Images.
- Offers and prices where technically appropriate.
- Reviews and ratings where eligible.
- Breadcrumbs.
- FAQs where useful and compliant.
- Language and regional relationships.
Structured data cannot guarantee visibility or an AI citation. It can reduce ambiguity and improve the ability of machines to interpret the official source.
Audit OTA and downstream distribution profiles
OTA profiles should be accurate, complete and aligned with the hotel’s commercial strategy.
Hotels should review:
- Property descriptions and categorisation.
- Room names and amenities.
- Images.
- Rate plans.
- Cancellation conditions.
- Loyalty and promotional participation.
- Mobile or geographically targeted discounts.
- Payment handling.
- Wholesale and affiliate distribution.
- The presentation of the hotel’s brand.
- Links or claims that could imply an official relationship.
Hotels may not control every downstream reseller, but they should be able to identify discrepancies, trace inventory sources where possible and enforce applicable contractual conditions.
Suggested owners: distribution, revenue management, legal or commercial teams.
Suggested indicators: content consistency, unauthorised distribution cases, rate leakage and resolution time.
Require more from technology and distribution providers
Hotels should press booking engines, channel managers, property-management systems, CMS providers, metasearch partners and agencies to accelerate technical improvements and responsible automation.
Providers should support:
- Faster and more reliable data updates.
- Accurate rate and availability feeds.
- Improved structured-data implementation.
- Better API connectivity.
- Clearer reporting and attribution.
- AI-compatible content and data access.
- Automated discrepancy alerts.
- Secure integrations.
- Exportable hotel-owned data.
- Transparent product roadmaps.
The hotel should not be required to compensate manually for avoidable limitations in its technology stack.
Suggested owners: C-suite sponsor, technology lead, ecommerce and procurement.
Suggested indicators: integration reliability, update latency, feed errors, reporting coverage and provider delivery against agreed milestones.
The next 12 months: prepare for AI-assisted and agentic booking
Hotel websites will increasingly serve both people and machine-led discovery systems.
Hotels should prepare for journeys in which AI systems:
- Research destinations.
- Recommend properties.
- Compare rates and conditions.
- Answer detailed hotel questions.
- Select booking providers.
- Initiate or complete transactions.
- Manage parts of the pre-arrival journey.
Preparation should include:
- Strong SEO and generative-engine-optimisation foundations.
- Machine-readable property information.
- Accessible rates, policies and availability.
- A maintained hotel knowledge base.
- Secure and governed APIs or integrations.
- Responsible AI functionality within the CMS.
- Automation for content, data-quality and operational workflows.
- Fast, accessible and conversion-focused websites.
- Booking processes that machines can interpret without compromising security or customer choice.
Hotels should not adopt every emerging AI integration indiscriminately. Each connection should be assessed according to:
- Data ownership.
- Customer ownership.
- Commercial terms.
- Security.
- Brand control.
- Attribution.
- Cancellation and servicing responsibilities.
- Its incremental value to the direct channel.
The objective is to participate in new booking journeys without creating another uncontrolled source of dependency.
Review dependence on paid acquisition
Paid search, Hotel Ads and metasearch remain valuable tools. They should support the hotel’s commercial strategy rather than compensate indefinitely for weaknesses in organic visibility, rate competitiveness or the booking experience.
Hotels should evaluate:
- How much is spent defending hotel-brand searches.
- Which paid bookings are genuinely incremental.
- Whether OTA visibility is increasing on branded queries.
- How paid acquisition costs compare with OTA commission.
- Whether direct customers repeat without paid reacquisition.
- Whether changes in organic modules increase paid-media dependence.
This analysis should consider customer lifetime value and ownership of the relationship—not only the cost of the first transaction.
Make the direct channel a C-suite responsibility
These changes cannot be treated solely as an SEO or digital-marketing issue.
They affect:
- Distribution costs.
- Commercial independence.
- Technology investment.
- Customer ownership.
- Data access.
- Brand protection.
- Long-term profitability.
Senior leaders should establish clear ownership of the direct-channel strategy and ensure that revenue, marketing, distribution, technology and operations work from the same priorities.
A well-informed C-suite can allocate resources, challenge providers, approve necessary technical changes and make decisions that individual operational teams cannot implement alone.
At minimum, senior management should regularly review:
- Direct-versus-intermediated revenue.
- Total direct-acquisition cost.
- Branded paid-search expenditure.
- OTA undercutting.
- Free Booking Link and Hotel Ads performance.
- Organic and AI visibility.
- Technology dependencies.
- Progress against the direct-channel roadmap.
Participate in the regulatory and industry debate
Hotels and hotel groups should document changes in:
- Visibility.
- Acquisition costs.
- Brand bidding.
- Rate presentation.
- Data access.
- Customer ownership.
- Direct-booking performance.
This evidence should be shared through HOTREC, national and regional hotel associations and other representative bodies.
Regulators need evidence from direct suppliers—not only arguments from Google and large intermediaries—to understand how each proposed remedy affects competition.
Hotels should report specific, documented practices rather than making general accusations. Consistent evidence will be more influential than isolated complaints.
A practical priority matrix
| Period | Priority | Principal owner | Evidence of progress |
| Next 30 days | Establish the SERP, rate and measurement baseline | SEO, ecommerce and revenue management | Recorded visibility, rate comparisons and complete baseline reporting |
| Next 30 days | Audit Hotel Ads and Free Booking Links | Ecommerce and metasearch provider | Eligibility, rate accuracy, traffic and conversion trends |
| Next 90 days | Strengthen official-site identification and technical SEO | SEO and web-development teams | Improved crawlability, profile consistency and structured-data accuracy |
| Next 90 days | Build the hotel knowledge base | Marketing, operations and technology | Complete, governed and consistently distributed hotel information |
| Next 90 days | Audit OTA profiles and downstream distribution | Revenue and distribution teams | Fewer discrepancies, identified rate leakage and faster resolution |
| Next 12 months | Prepare for AI-assisted and agentic discovery | C-suite, ecommerce and technology | Governed integrations, machine-readable data and measurable AI visibility |
| Continuous | Reduce avoidable platform dependency | C-suite and commercial leadership | Competitive direct-acquisition costs and sustainable channel mix |
| Continuous | Contribute evidence to the regulatory debate | Leadership and hotel associations | Documented submissions based on measurable market effects |
The strategic principle
Hotels cannot control Google’s final interface or the Commission’s enforcement timetable.
They can control the quality of their official information, the competitiveness of their direct offer, the technical strength of their websites, the accountability of their providers and the evidence used to make commercial decisions.
The appropriate response is therefore consistent and long-term: protect the fundamentals, measure what changes, demand better technology and transparency, and continue innovating around the direct customer relationship.
