Trip.com Group enters the second half of 2026 with its dominant domestic position now legally confirmed and its largest single penalty on the books already behind it, which reframes the entire debate around the stock. In January, the State Administration for Market Regulation of the People's Republic of China, or SAMR, opened an investigation into whether the company abused a dominant market position under the PRC Anti-Monopoly Law, and the market spent most of the first half pricing that threat as open-ended.
On July 25, SAMR issued its final administrative decision, ordering the company to cease the offending conduct and to refund RMB122 million in compulsorily withheld hotel security deposits. The decision also confiscated RMB1,658 million in gains. The fine itself was RMB3,521 million, set at 7.5% of the company's China sales in its last full fiscal year. The combined charge of RMB5.2 billion was booked in second-quarter general and administrative expenses. That single line item swung the quarter from a prior-year profit of RMB4.9 billion to a GAAP loss of RMB2.4 billion, even though the underlying booking business grew. The penalty is now a known and paid event, which changes how the rest of the quarter should be read.
The operating evidence underneath the penalty is more encouraging than the headline suggests. Second-quarter net revenues rose 6% to RMB15.7 billion. The international platform grew more than half again in year-over-year terms. Non-GAAP net income of RMB4.8 billion came in essentially flat against the prior year. Adjusted EBITDA margin of 29% sits just below the 33% pace of a year earlier, a gap that largely reflects the penalty itself rather than a deterioration in unit economics. The regulatory overhang is now priced as a historical event, so the question for investors is whether the growth and a $5 billion buyback program can carry the valuation back toward its 52-week high. The alternative reading is that the fine signals a permanent ceiling on how much margin the company can extract from its hotel and ticketing partners, a ceiling that would cap the stock near the $40.65 it currently trades at.