[Edaily Kang Gyeong-rok Travel Reporter] When booking a hotel or travel package, adding fees that must be paid on top of the initially quoted price during the payment process may constitute a violation of the Electronic Commerce Act. In principle, costs that consumers cannot avoid must be included in the initially displayed price. This regulation applies not only to lodging but also to online travel products such as package tours and local tours.

On the 6th, the Fair Trade Commission released the “Guidelines for Operating Online Interfaces to Prevent Dark Patterns,” which contain these provisions. The guidelines specify the criteria for determining violations of dark pattern regulations under the E-Commerce Act—which has been in effect since February of last year—and outline major examples of violations.
The key provision is the prohibition of “sequential price disclosure.” This refers to the practice of showing only a portion of the price during the product search stage and then adding costs that consumers must bear during the payment process. Hotel rooms, package tours, and local tours and activities sold by domestic and international online travel agencies (OTAs) may also be subject to these regulations during the online transaction process.
Fees, resort charges, and lodging taxes that must be paid in addition to hotel room rates are included in the price display requirements depending on whether they are mandatory. However, if there is a valid reason making it difficult to determine the total amount at the time of booking, the business must inform the consumer of the excluded cost items and the reason for their exclusion.
“Pre-selection of specific options”—where paid add-on services that consumers have not chosen are preselected—may also constitute a prohibited practice. A typical example is offering travel insurance or room upgrades as the default selection. Intentionally making the reservation cancellation or membership withdrawal process difficult is also subject to regulation.
Issues with price display on lodging reservation platforms have been identified in past investigations as well. A 2023 investigation by the Korea Consumer Agency into five global accommodation booking platforms revealed discrepancies between the initially displayed prices and the final payment amounts on some platforms. At the time, the same accommodation package at a hotel in Jeju was initially displayed as 363,000 won, but the final payment amount was 399,300 won. However, since this investigation took place before the current regulations went into effect, it should be distinguished from the current state of price display practices.
In these guidelines, the Fair Trade Commission has categorized online dark patterns into four categories and 13 types. It has consolidated the existing self-regulatory guidelines and regulatory Q&A documents and added examples of law enforcement cases. The Commission plans to monitor changes in the online transaction environment and types of consumer harm, and to respond to violations of the law.