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A.History and development of the company
trivago was conceived by graduate school friends Rolf Schrömgens, Peter Vinnemeier and Stephan Stubner, who initially operated trivago out of a garage in Düsseldorf, Germany. trivago GmbH was incorporated in 2005, and its business eventually developed into a leading global hotel and accommodation search platform. Mr. Stubner left the company in 2006 and another graduate school friend, Malte Siewert, joined the founding team.
Between 2006 and 2008, several investors invested €1.4 million in trivago. In 2010, Insight Venture Partners acquired 27.3% of the equity ownership of trivago for €42.5 million. Expedia Group acquired 63.0% of the equity ownership in trivago in 2013, purchasing all outstanding equity from non-Founders and some outstanding equity from the Founders and subscribing for a certain number of newly issued shares for a total of €477 million. Expedia Group subsequently increased its shareholdings slightly in the second and fourth quarter of 2016 through the purchase of shares held by certain employees who had previously exercised stock options.
We were incorporated on November 7, 2016 as travel B.V., a private company with limited liability (besloten vennootschap met beperkte aansprakelijkheid) under Dutch law. On December 16, 2016, we completed our initial public offering, or IPO, on the Nasdaq Stock Exchange. In connection with our IPO, we converted into a public company with limited liability (naamloze vennootschap) under Dutch law pursuant to a deed of amendment and conversion and changed our legal name to trivago N.V. On September 7, 2017, we consummated the cross-border merger of trivago GmbH into and with trivago N.V.
We are registered with the Trade Register of the Chamber of Commerce in the Netherlands (Kamer van Koophandel) under number 67222927. Our corporate seat is in Amsterdam, the Netherlands, and our registered office is at Kesselstraße 5 - 7, 40221 Düsseldorf, Germany (under number HRB 79986). Our telephone number is +49-211-3876840000.
Our agent in the United States is Cogency Global Inc., and its address is 122 East 42nd Street, 18th Floor, New York, NY 10168.
The Securities and Exchange Commission (the "SEC") maintains an Internet site (http:// www.sec.gov) that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC. We also maintain a website that includes our SEC filings and other information at ir.trivago.com.
Principal capital expenditures and divestitures
For information on our principal capital expenditures and divestitures, see "Note 3 - Holisto Investment and Acquisition" in the notes to our consolidated financial statements included in this annual report.
Public takeover offers
There have been no public takeover offers by third parties with respect to our shares, and we have not made any public takeover offers in respect of any other company’s shares during the last and current financial year.
Segment reporting
Management has identified three reportable segments: Americas, Developed Europe and Rest of World (RoW), collectively referred to as the trivago Core segments. Our Americas segment is comprised of Argentina, Brazil, Canada, Chile, Colombia, Ecuador, Mexico, Peru, the United States and Uruguay. Our Developed Europe segment is comprised of Austria, Belgium, Denmark, Finland, France, Germany, Ireland, Italy, the Netherlands, Norway, Portugal, Spain, Sweden, Switzerland and the United Kingdom. Our RoW segment is comprised of all other countries, the most significant by revenue of which are Japan, Turkey, Australia, New Zealand and Poland. We have also determined that our trivago DEALS operating segment does not meet the quantitative thresholds of a separate reportable segment.
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For additional information relating to the development of our company, see “Item 4: Information on the company - B. Business overview.”
B. Business overview
Overview
trivago is a leading global hotel search and price comparison platform and one of the most recognized travel brands in the world. When price savvy travelers are searching for a hotel, we want trivago to be the obvious choice. We aim to help travelers find the best place to stay and the best time to go. trivago aims to enable them to book with confidence, saving travelers valuable time and money. By leveraging cutting-edge technology, we seek to personalize and simplify the hotel search experience for millions of travelers every month. We provide access to more than 7.0 million hotels and other types of accommodation in over 190 countries.
We believe that the number of travelers accessing our websites and apps makes us an important and scalable marketing channel for our advertisers, which include OTAs, hotel chains, independent hotels and providers of alternative accommodation. Additionally, our ability to refine user intent through our search function allows us to provide advertisers with transaction-ready referrals. Recognizing that advertisers on our marketplace have varying objectives and varying levels of marketing resources and experience, we provide a range of services to enable advertisers to improve their performance on our marketplace.
Our search platform can be accessed globally via 53 localized websites and apps available in 31 languages. Users can search our platform on desktop and mobile devices, and benefit from a familiar user interface, resulting in a consistent user experience. We completed the strategic acquisition of Holisto Ltd (renamed to trivago DEALS Ltd) in July 2025. trivago DEALS is an AI-driven travel technology platform that serves as a hotel rate aggregator and white-label booking engine provider. The acquisition plays a pivotal role in enhancing user experience by expanding our trivago-branded booking funnel which will help us drive long term growth.
In the year ended December 31, 2025, we generated revenue of €548.9 million, net income of €11.2 million, and Adjusted EBITDA of €15.8 million. Adjusted EBITDA is a non-GAAP financial measure, and we therefore direct you to “Item 5: Operating and financial review and prospects - G. Non-GAAP financial measures" for an additional description of Adjusted EBITDA and a reconciliation of Adjusted EBITDA to net income/(loss). See, also "Item 5: Operating and financial review and prospects - Results of Operations - Revenue" for Referral Revenue by segment, representing a breakdown according to principal geographic markets.
trivago's search platform
Our accommodation search platform forms the core of our user experience. It is a search and comparison product, and users usually complete their bookings on our advertisers’ websites. When they click on an offer for a hotel room or other accommodation at a certain price, they are referred to our advertisers’ websites where they can complete their booking. We also facilitate direct booking on our platform for select offers through our trivago DEALS business. We maintain one of the largest searchable databases of accommodations in the world. As of December 31, 2025, our database included more than 7.0 million hotels and other types of accommodations, including vacation rentals and private apartments, gathered through OTAs, hotel chains, independent hotels and providers of alternative accommodations.
In order to create a superior search experience we cluster our user experience into the following pillars:
•Search: We offer search functionalities which include destination based search, natural language based search powered by AI, and refinement options such as filters;
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•Deals: We help users compare prices across more than 100 booking sites and aim to highlight available offers to them. Refer to "Marketplace" below for how we determine the prominence given to offers and their placement in our search results;
•Book: Our "Book & Go" functionality streamlines the user journey by enabling direct, on-platform bookings. By removing the need for third-party redirects, we significantly reduce friction, resulting in a superior user experience and improved conversion rates.
We provide our services through websites and apps, including through our mobile-optimized website available on mobile device browsers. Our full-featured native mobile app is available on iPhone, iPad, Android Phone and Android Tablet.
Marketing
Through test-driven marketing operations, we have positioned our brand as a key part of the process for travelers in finding their ideal hotel or other accommodation. We focus the efforts of our marketing teams and Advertising Spend towards building effective and efficient messaging for a broad audience. We believe that building and maintaining our brand and clearly articulating our role in travelers' hotel or other accommodation discovery journey, will continue to drive both travelers and advertisers to our platform to connect in a mutually beneficial way.
We have deployed the use of AI technology into our marketing campaigns enabling us to trial and experiment advertising strategies more extensively. For example, we have produced localized TV advertisements in more than ten different languages, all featuring the same actor, but uniquely tailored for each target market.
Our application of data-led improvement and innovation also informs our marketing strategy, which we believe enables us to become increasingly more effective with our marketing spend. We have built tools that capture data and calculate our return on many elements of our brand and performance marketing measures.
Brand marketing
To grow brand awareness and increase the likelihood that users will visit our websites and use our apps, we invest in brand marketing globally across a broad range of media channels, including TV marketing, on demand video platforms and online video advertising. We also generate travel content as a means of engaging with travelers, which is distributed online via social media, our online magazine and email.
The amount and nature of our Advertising Spend varies across our geographic markets, depending on multiple factors including the emphasis we wish to place on profitability versus traffic growth, cost efficiency, marginal effectiveness of our Advertising Spend, local media dynamics, the size of the market and our existing brand presence in that market.
Branded channel traffic refers to traffic to our platform through: one of our localized platform websites, one of our downloadable mobile applications, branded search engine marketing channels (or "branded free traffic") for keyword searches that are inclusive of the trivago brand name, and/or paid keyword searches that include the trivago brand name, such as "trivago" or "trivago hotel".
Performance marketing
We market our services and directly acquire traffic for our websites by purchasing travel and hotel-related keywords (excluding keyword combinations inclusive of the trivago brand name) from general search engines (referred to as "search engine marketing") such as Google and Yahoo!, and through advertisements on other online marketing channels such as advertising networks, social media sites, and affiliate websites. We call this performance marketing channel traffic. Paid app marketing remains important given the increasing demand for app usage.
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Allocation of marketing spend
We take a data-driven, testing-based approach to making decisions about allocating marketing spend, where we use tools, processes and algorithms, many of which are proprietary, to measure and optimize performance end-to-end, starting with the pretesting of the creative concept and ending with the optimization of media spend. We continue to develop the methodologies we use to inform decisions about how much we spend on each marketing channel. We look at a range of metrics including behavior on the trivago website as well as subsequent booking behavior with our advertisers to determine the optimal mix of spend. We assess the returns on marketing spend by looking at a range of factors, both short and long-term, including impact on Referral Revenue, user retention and advertiser engagement.
Sales & Account management
Our sales and account management team builds and grows relationships with OTAs, hotel chains and other travel companies, including hospitality technology providers. From facilitating their participation in our marketplace to growing the adoption of our products, our dedicated teams provide ongoing consultation and guidance to our advertisers around CPC (cost-per-click) and CPA (cost-per-acquisition) bidding options, product updates, and optimization opportunities. We proactively engage with our advertisers to better understand their specific objectives in order to offer solutions through our marketplace.
Independent hotels receive dedicated attention through our customer success team. With tailored solutions for hoteliers, we enable independent hotels to generate business insights and direct business through their official website by advertising their rates directly in our price comparison, allowing them to compete with the large OTAs and chains. Our team accompanies hoteliers throughout the sales cycle, from creating awareness about our products to onboarding them.
Marketing tools and services for advertisers
We offer our advertisers a suite of marketing tools to help promote their listings on our platform and drive traffic to their websites. Our tools and services provide tailored solutions for OTAs, hotel chains and independent hotel advertisers to help them manage their presence on our marketplace and steer their investments according to their budget and traffic needs.
Marketplace
We design our algorithm to display hotel room and other accommodation rate offers that we believe will be attractive to our users, emphasizing those offers that we believe are more likely to be clicked and ultimately booked on our advertisers' websites. We prominently display a suggested deal for each hotel, which is determined based on our algorithm as described below, while also listing additional offers made available to us from our advertisers in a list format.
We consider the completion of hotel and other accommodation bookings, which we refer to as booking conversion, to be a key indicator of user satisfaction on our website. At the core of our ability to match our users’ searches with large numbers of hotel and other accommodation offers is our auction platform, which we call our marketplace. With our marketplace, we provide advertisers a competitive forum to access user traffic by facilitating a vast quantity of auctions on any particular day.
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CPC bidding model
Our advertisers continue to participate in our marketplace primarily through CPC, or cost-per-click, bidding. Advertisers that use this method submit CPC bids for an advertised rate for a hotel. CPC bids represent the maximum that an advertiser is willing to pay for a click. The price paid by the advertiser may ultimately be lower than the CPC bid submitted based on our dynamic auction model. By clicking on a given rate, an individual user is referred to that advertiser’s website where the user can complete the booking. Advertisers can submit and adjust CPC bids on our marketplace frequently - as often as twice per day - on a property-by-property and market-by-market basis, and provide us with information on hotel room and other accommodation rates and availability on a near-real time basis. CPC bids can be adjusted upwards or downwards for a set of dimensions (length-of-stay, booking-window, standard-date, group-size) as determined by the advertiser.
We also offer our advertisers the opportunity to advertise and promote their business through hotel/accommodation sponsored placements on our websites. This service is generally also priced on a CPC basis and guarantees that advertiser placement in a pre-selected slot typically at the top of our search results.
Cost-per-acquisition model
We also offer our advertisers the opportunity to participate in our marketplace on a CPA, or cost-per-acquisition, basis, whereby an advertiser pays us a percentage of the booking amount that ultimately result from a referral. The CPA model enables our advertisers to be charged only in the event a user ultimately completes a booking, enabling them to reduce their risk as they only pay when an actual booking takes place. Advertisers may set multiple CPA campaigns in a given market, and update CPA inputs for each campaign frequently. When an advertiser opts to participate in our marketplace on a CPA basis, we calculate a CPC bid-equivalent based on potential booking value, and the CPA inputs. This equivalent is then used for the purpose of the ranking and sorting algorithm described below. CPA inputs can be adjusted upwards or downwards relative to the booking-window dimension as determined by the advertiser.
Ranking and sorting algorithm
In determining the prominence given to offers and their placement in our search results, including in comparison search results for a given location and on detail pages for a given property, our proprietary algorithm considers a number of factors in a dynamic, self-learning process. These include (but are not limited to) the advertiser’s offered rate for the hotel room or other accommodation, the likelihood the offer will match the user’s accommodation search criteria, data we have collected on the likelihood an offer will be clicked and the CPC that our advertisers will be charged (or CPC bid-equivalent under the CPA model, as the case may be).
CPC and CPA levels play an important role in determining the prominence given to offers and their placement in our search results. Advertisers can analyze the number of referrals obtained from their advertisements on our marketplace and the consequent value generated from a referral based on the booking value they receive from users referred from our site, to determine the amount they are willing to pay. Generally, the higher the potential booking value or booking conversion generated by a referral and the more competitive the bidding, the more an advertiser is willing to bid for an accommodation advertisement on our marketplace. This means that the levels of advertisers’ CPC bids generally reflect their view of the likelihood that each click on an offer will result in a booking by a user. We exclude from our marketplace auction offers where the CPC has been set to a de minimis level, as this typically denotes room inventory that the advertiser has withdrawn for some period of time from its active inventory on trivago.
By managing their CPC bids, their CPA campaigns and hotel room and other accommodation rates submitted on our marketplace, our advertisers can influence their own returns on investment and the volumes of referral traffic we generate for them. We believe that by providing services to help our advertisers, we can increase competition and create a more level playing field for our advertisers. By
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doing this, we aim to mitigate competitive disadvantages for smaller advertisers on our marketplace and to deliver more choice for our users.
Our strategy
When travelers are searching for a “Hotel?” we want the obvious choice to be “trivago”. We aim to simplify their planning, help them save, and instill confidence in their booking decisions. The value proposition of trivago is highly relevant as consumers continue to be price-conscious, great deals continue to be available and the trivago brand is well-recognized globally. To accelerate this potential, we are rapidly adopting AI to amplify our marketing and improve our product and innovate faster, allowing our team to scale our impact significantly, without expanding our workforce. This provides a strong foundation for us to build upon. We maintain our focus on the following three strategic priorities to drive our success.
Brand
Our focus remains on brand initiatives designed to rebuild our branded visitor baseline, which is viewed as key for long-term growth. Our approach is result-oriented: investing where response is strongest and continuously optimizing our budget allocation as well as our ads. We believe these efforts will enhance the efficiency of our marketing investments and allow compounding effects to materialize over the long term. Furthermore, we are amplifying AI technologies in content production, which allows us to maintain efficiency in production costs.
Going forward, we will continue to invest in brand within our core markets, though at a notably slower rate as we reach our target brand marketing investment levels. Our strategy is transitioning from expansion into new markets toward the optimization of existing ones, marking a departure from the phase where mature regions subsidized our entries into new markets. By moderating brand spend growth while leveraging the cumulative impact of previous investments, we plan to prioritize delivering improved profitability in the years ahead.
Hotel Search
We continue to focus on evolving our core product to streamline the accommodation search experience for price-savvy travelers. Underpinned by a high-velocity testing culture that delivers tangible product enhancements and conversion gains - further driving marketing efficiency - our roadmap centers on advancing three core pillars: Search, Deals, and Book.
In Search, we are scaling capabilities within AI Smart Search & Content to personalize results and simplify complex queries. By leveraging advanced machine learning and Large Language Models ("LLMs"), we deliver widely adopted features - such as AI Highlights and AI Review Summaries - that improve how users evaluate hotels. Furthermore, our natural language integration enables travelers to explore accommodation options in more intuitive ways.
We are strengthening our Deals pillar by combining exclusive offers with functional enhancements like list sharing - a strategy that is driving rising revenue from logged-in members while fostering long-term user retention. Logged-in members represent users that have registered on our platform to access exclusive rates and personalized features. We believe this membership layer allows us to better understand user preferences through first-party data. Our strategy focuses on converting anonymous traffic into logged-in members with the objective of fostering recurring usage and driving engagement through a more personalized user interface.
Finally, our Book pillar's main priority is to facilitate a seamless booking process. We are prioritizing the expansion of trivago "Book & Go" and the integration of it more deeply in our platforms. We believe this will help facilitate a smoother booking experience for our users.
We will continue to invest in AI‑powered features that are central to offering a superior hotel search experience. We aim to be a leader on price perception, offering great deals and making them easy for users to find.
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Partnerships
By co-creating and innovating with our advertising partners, we focus on unlocking user value throughout our metasearch platform and remaining a relevant marketing channel for our advertisers that drives high quality traffic. We continue to prioritize our transaction‑based CPA-model, which has exceeded expectations in 2025 and continues to gain market share. By shifting risk and optimization complexity away from bidding, the CPA-Model helps smaller partners compete more effectively in our marketplace. Additionally, trivago "Book & Go" (accelerated by our trivago DEALS integration) enables our partners to leverage our facilitated trivago-branded booking funnel, enhancing their conversion rates and competitiveness within our marketplace.
Advertiser mix
Customers that pay to advertise on trivago include:
•OTAs, including large international players, as well as smaller, regional and local OTAs;
•Hotel chains, including large multi-national hotel chains and smaller regional chains;
•Individual hotels;
•Providers of alternative accommodation, such as vacation rental or apartments.
We generate the large majority of our Referral Revenue from OTAs. Certain brands affiliated as of the date hereof with our majority shareholder, Expedia Group, including brands Expedia, Hotels.com, Wotif and Vrbo, in the aggregate, accounted for 34% of our Referral Revenue for the year ended December 31, 2025. Booking Holdings and its affiliated brands, including Booking.com, Agoda and priceline.com, accounted for 40% of our Referral Revenue for the year ended December 31, 2025.
Nearly all of our agreements with advertisers, including our agreements with our largest advertisers, may be terminated upon prior notice of thirty days or less by either party. For more information on risks related to the concentration of our revenue and our relationship with our largest advertisers, see "Item 3: Key information - D. Risk factors".
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Competition
We face competition for hotel and alternative accommodation advertisers’ marketing spend and for users. Additionally, emerging technologies like AI powered chatbots - such as ChatGPT (OpenAI), Gemini (Google), Grok (xAI), Claude (Anthropic), and Perplexity - are redefining user engagement and advertising strategies within the travel industry, presenting new competitive challenges and opportunities.
Competition for users
We compete to attract users to our websites and apps to help them research and find hotels and other accommodation. Given our position at the top of the online search funnel, many companies we compete with are also our customers.
Our principal competitors for users include:
•Online metasearch and review websites, such as Google Hotel Ads, Kayak, Skyscanner, Check24 and TripAdvisor;
•Search engines, such as Bing, Google, Naver and Yahoo!;
•Independent hotels and hotel chains, such as Accor, Hilton and Marriott;
•OTAs, such as Booking.com, Agoda, Priceline, Ctrip, TUI, trip.com and Brand Expedia; and
•Alternative accommodation providers, such as Airbnb and Vrbo.
Competition for advertisers
We compete with other advertising channels for hotel and alternative accommodation advertisers’ marketing spend. These include traditional offline media and online marketing channels. In terms of user traffic, we compete on the basis of the quality of referrals, CPC/CPA rates, and advertisers’ implied return on investment.
Our principal competitors for advertisers’ marketing spend include:
•Print media, such as local newspapers and magazines;
•Other traditional media, such as TV and radio;
•Search engines, such as Bing, Google, Naver and Yahoo!;
•Online metasearch and review websites, such as Google Hotel Ads, Kayak, Skyscanner, Check24 and TripAdvisor;
•Social networking services, such as Meta (Facebook, Instagram), X (formerly Twitter) and TikTok;
•Websites offering display advertising;
•Email marketing software and tools;
•Connected TV (CTV) streaming services and online video channels, such as YouTube; and
•Mobile app marketing.
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Seasonality
We experience seasonal fluctuations in the demand for our services as a result of seasonal patterns in travel. For example, searches and consequently our revenue are generally the highest in the first three quarters as travelers plan and book their spring, summer and winter holiday travel. Our revenue typically decreases in the fourth quarter. Seasonal fluctuations affecting our revenue also affect the timing of our cash flows.
We typically invoice once per month, with customary payment terms. Therefore, our cash flow varies seasonally with a slight delay to our revenue, and is significantly affected by the timing of our Advertising Spend. Changes in the relative revenue share of our offerings in countries and areas where seasonal travel patterns vary from those described above may influence the typical trend of our seasonal patterns in the future.
Intellectual property
Our intellectual property, including trademarks, is an important component of our business. We rely on confidentiality procedures and contractual provisions with suppliers to protect our proprietary technology and our brands. Based on recent technological developments, we amended our artist and agency agreements to ensure that we can secure all relevant rights for creative work when using artificial intelligence in relation to marketing materials. In addition, we enter into confidentiality and invention assignment agreements with our employees and consultants.
We have registered domain names for websites that we use in our business, such as www.trivago.com, www.trivago.de and www.trivago.co.uk. Our registered trademarks include: trivago, "Hotel? trivago", "trivago Rating Index", Youzhan, and our trivago logo. These trademarks are registered in various jurisdictions.
Government regulation
trivago provides, receives and shares data and information with its users, advertisers and other online advertising providers and conducts consumer facing marketing activities that are subject to consumer protection laws in jurisdictions in which we operate, regulating unfair and deceptive practices. For example, the United States and the European Union, or EU (including at member state level), but also many other jurisdictions, are increasingly regulating commercial and other activities on the Internet, including the use of information retrieved from or transmitted over the Internet, the display, moderation and use of user-generated content, and are adopting new rules aimed at ensuring user privacy and information security as well as increasingly regulating online marketing, advertising and promotional activities and communications, including rules regarding disclosures in relation to the role of algorithms and price display messages in the display practices of platforms.
There are also new or additional rules regarding the taxation of digital products and services, the quality of products and services as well as addressing liability for third-party activities. Moreover, the applicability to the Internet of existing laws addressing issues such as intellectual property ownership and infringement is uncertain and evolving.
In particular, we are subject to an evolving set of data privacy laws. trivago is subject to the GDPR, which has been in effect since May 25, 2018 and which has recently led to the imposition of significant fines on various companies. Due to the global nature of our operations, trivago is subject to an ever changing and growing patchwork of privacy laws, including the UK GDPR and the UK Data Protection Act 2018, the Brazilian General Data Protection Law, the Canadian Personal Information Protection and Electronic Documents Act, and India’s Digital Personal Data Protection Act, to name a few.
In the US, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (CCPA) among other US state privacy laws; impose certain privacy requirements and restrictions
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as well as provide rights for consumers. Other privacy laws will continue to come into force in other US states, rendering it almost impossible to adopt a single compliance approach for the US. Other substantial markets have adopted or are in the process of adopting data protection regulations. As a result, the data privacy regulatory landscape is becoming more and more fragmented, and such regulations and the implementation and enforcement thereof risk being inconsistent or conflicting.
While we strive to monitor and comply with this complex and ever-changing set of laws, a failure or perceived or alleged failure to comply with data privacy requirements in one of the jurisdictions where we operate, or target users may significantly harm our businesses. In addition, we could be adversely affected if data privacy regulations are expanded (through new regulation or through legal rulings) to require major changes in our business practices.
The growing complexity of the data protection landscape is exemplified by the regulation regarding international transfer of personal data, which is rapidly evolving and likely to remain uncertain for the foreseeable future. In particular, the GDPR regulates transfers of EU personal data to third countries that have not been found by the European Commission to provide adequate protection to such EU personal data, such as the United States. A considerable number of our service providers and hotels operate in such jurisdictions. In July 2023, the European Commission adopted an adequacy decision for the Data Privacy Framework (DPF) which has been negotiated between the US and the European Union. This DPF provides companies with a mechanism to comply with data protection requirements when transferring personal data from the EU to the United States. While this new framework might help reduce the complexity surrounding the transfer of personal data from the EU to the US, uncertainty remains as to the long-term validity of this DPF (it is already subject, and might continue on being subject to, legal challenges). At present, companies still mostly rely on the European Commission’s Standard Contractual Clauses to transfer personal data from Europe to the United States and other countries that have not been found to provide adequate protection to EU personal data. However, reliance on the Standard Contractual Clauses is subject to enhanced due diligence on the data importer's national laws: a transfer impact assessment must be carried out for any transfers and supplementary measures may have to accompany the Standard Contractual Clauses for a transfer to be compliant. These changes are causing us to continually review our current compliance approach and may result in additional compliance costs. The legal uncertainty related to cross-border transfers of personal data, could harm our ability to transfer personal data outside of the EU, and could in turn harm our ability to provide, and our customers' ability to use, some of our services.
Many governmental authorities in the markets in which we operate, especially in the EU, are also considering, or are in the process of implementing, additional and potentially diverging legislative and regulatory proposals that would or will increase the level and complexity of regulation of technology companies. For example, the EU’s Digital Services Act, which fully entered into force on February 17, 2024, applies to trivago and, inter alia, imposes further disclosure obligations on us. The interpretation of this new regulation, which remains unclear for some of its provisions, is still subject to the upcoming publication of guidelines by the European Commission – the issuance of which could lead us to reassess our compliance approach on short notice. On July 14, 2025, the European Commission published Guidelines on the protection of minors under the DSA. However, the Commission may still issue additional guidelines, which could require further adjustments to our compliance strategy. Moreover, the European Commission adopted an Implementing Regulation setting out the rules and templates for transparency reporting by providers of intermediary services under the DSA. Providers were required to start collecting data under this regulation as of July 1, 2025, with the first harmonized reports due in early 2026. The EU has also adopted, or is in the process of adopting, a broad range of new legal instruments aimed primarily at regulating the technology sector (for example, the EU's Data Governance Act, the EU's Digital Markets Act, the EU’s Data Act, the new EU's Network and Information Security Directive ("NIS 2"), the ePrivacy Regulation and the Digital Fairness Act).
The emergence of increasingly sophisticated artificial intelligence (“AI”) models in recent years has prompted lawmakers around the world to consider or adopt AI-related regulations. For example, in February 2024, representatives of European Union Member States reached agreement on the proposed text of the EU’s Artificial Intelligence Act, one of the first comprehensive regulations on AI. The AI Act
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entered into force on August 1, 2024, with full implementation scheduled by August 2, 2027. Enforcement will commence on August 2, 2026. The regulation remains subject to further guidance from the European Commission, with additional guidelines expected to be developed in the course of 2026. Other substantial markets, like the US and the UK, are also in the process of considering AI-specific legislation.
The Digital Omnibus package, initially proposed by the European Commission on November 19, 2025, to simplify EU digital rules, is currently undergoing the ordinary legislative procedure within the European Parliament and the Council. The initiative seeks to help businesses innovate, scale, and save on administrative costs by streamlining several of the EU’s core digital laws. Rather than introducing new regulations, the package aligns and adjusts existing frameworks to ensure they work together more coherently. This includes, among other things, legislative amendments to the AI Act as well as updates to the GDPR, Data Act, ePrivacy Directive, and cybersecurity rules. The legal landscape surrounding AI therefore remains uncertain and will require close monitoring in the coming years, as trivago increasingly applies AI technologies. For more details, see “Item 3: Key information - D. Risk factors – Operational risks - Any use of artificial intelligence/machine learning (AI/ML) technologies in our operations may present additional legal, regulatory, and social risks, which could lead to additional costs and impact our competitive position.”
It is impossible to predict whether further new taxes or regulations will be imposed on our services and whether or how we might be affected. Increased regulation of the Internet could increase the cost of doing business or otherwise materially adversely affect our business, financial condition or results of operations. In addition, the application and interpretation of existing laws and regulations to our business is often uncertain, given the highly dynamic nature of our business and the sector in which trivago operates.
Technology and infrastructure
Data and proprietary algorithms
We process a large amount of information about user traffic and behavior, advertisers and direct connections into the databases of many of our advertisers. We believe it is central to the success of our business that we effectively capture and parse this data. To achieve this, we have developed proprietary algorithms that drive key actions across our platform, including search, listings and bidding tools. We continue to explore new ways to capture relevant data and feed this into our platform to further enhance the experience for both our users and advertisers. We also use AI-enabled tools and models in certain user-facing product features, including to generate hotel highlights and to power AI-enabled search functionality on our website.
Infrastructure
Our primary data center is situated in Germany, and we additionally utilize cloud servers located in the E.U., U.S., and Singapore, which we believe offer us secure and scalable storage and processing power at manageable incremental expense. While much of the data we receive and capture is not sensitive, our data centers and our cloud providers strive to be compliant with the highest security standards. Where required, our data centers and cloud providers are payment card industry (PCI) compliant and accordingly, it is our policy to store separately the limited amount of relevant sensitive data that we do capture. We have designed our websites, apps and infrastructure to be able to support high-volume demand.
Software
We develop our own software employing a rigorous iterative approach. This includes the proprietary algorithm underlying our search function, internal management tools, data analytics and advertiser tools.
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C. Organizational structure
The following chart depicts our corporate structure including significant subsidiaries and percentages of economic interest based on the number of shares outstanding as of December 31, 2025:
*Class A shares are held by the public shareholders and by the Founders. Based on the information available through public filings, Rolf Schrömgens, one of our Founders and a member of our supervisory board owns 34,483,930 Class A shares (F-3 filed on July 16, 2024). For more information on shareholding, please see Item 7A. Major Shareholders.
**As of December 31, 2025, Class B shares of trivago N.V. are only held by Expedia Group and Rolf Schrömgens.
*** The holders of our Class B shares are entitled to ten votes per share, and holders of our Class A shares are entitled to one vote per share. For more information about the voting rights of our Class A and Class B shares, see Exhibit 2.5 hereto. Each Class B share is convertible into one Class A share at any time by the holder thereof, while Class A shares are not convertible into Class B shares under any circumstances.
trivago N.V. is the direct or indirect holding company of our subsidiaries. Refer to Exhibit 8.1 in this annual report for a complete list of trivago N.V. subsidiaries.
D. Property, plant and equipment
In June 2018, we moved into our headquarters located in Düsseldorf's media harbor. We currently occupy 18,632 square meters of office space, which has been certified with LEED core & shell Gold - representing a state-of-the-art workplace for trivago. The lease provides for a fixed ten-year term plus two renewal options, each for a term of five years. Initially, trivago N.V. was the sole tenant of the building and the building was, therefore, built to our specifications.
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