Hyatt and Texas: What “Hidden Fee” Enforcement Looks Like Now

On December 30, 2025, Texas Attorney General Ken Paxton announced a $1.25 million settlement with Hyatt Corporation resolving a case Texas filed on May 15, 2023. Texas alleged Hyatt violated the Texas Deceptive Trade Practices Act by marketing hotel rooms at prices that were not available at the advertised rate because mandatory and unavoidable fees were added during the booking process. According to the press release, Hyatt agreed to disclose any fees added onto a hotel room’s price so consumers can more efficiently shop and compare prices.

How the State Sees It:

Texas is framing the Hyatt settlement as a price transparency and comparison shopping case. The core claim is not simply that a fee existed. It is that the fee structure made it harder for consumers to compare options using the headline price. Texas alleges that Hyatt advertised one price and then increased the final price by adding a mandatory fee that was not included in the quoted room rate, and that this approach thwarts comparison shopping and creates an advantage over competitors that display the full price up front.

The Attorney General’s office has positioned this as part of a larger enforcement run. The Hyatt settlement is the sixth hotel pricing transparency settlement Texas has announced in this series, following earlier settlements involving Marriott, Omni, Choice, Hilton, and Booking.com. Texas’s press release also underscores the State’s focus on how disclosures function in practice, emphasizing that even where fees were eventually disclosed, they were presented “in a manner that was unlikely to alert consumers” that the initial rate was not the actual price.

From Practice to Pleading:

Texas’s petition is a useful read because it is written like a walkthrough of the booking flow. It focuses less on abstract pricing principles and more on a few specific mechanics that show up across online commerce.

1. Disclosure that requires extra effort from the consumer
   Texas alleges the mandatory fee remained undisclosed in the “Price Summary” and was only revealed if a consumer clicked “Show Price Details.”
2. Labeling that can change consumer perception
   Texas alleges Hyatt “buries” the fee in “Taxes & Fees,” which, according to the petition, may lead consumers to believe the charge is government imposed.
3. Comparison shopping anchored to the headline number
   Texas emphasizes that consumers shop by price and alleges that headline pricing that excludes mandatory fees can distort comparison shopping.

The first number a consumer sees is the number that drives choice. If the real total price only becomes clear late in the process, states often argue the problem is the way the price is presented, not the absence of a disclosure.

Monday Morning Checklist:

A practical checklist for in house legal and compliance teams

Most companies do not need a months long redesign to reduce the risk the Hyatt settlement illustrates. What helps is a targeted review that brings legal, product, marketing, and compliance teams into the same conversation early.

Step 1: Inventory unavoidable fees and where they appear. Identify each mandatory fee that can attach to a transaction and map where it is displayed across channels, including your brand site, mobile experience, app, call center scripts, and major third-party platforms.

Step 2: Pressure test the headline price and any price-based ranking. Confirm whether the first price a consumer sees includes unavoidable company imposed fees and verify what “price” is used in any sorting, filtering, ranking, or comparison features.

Step 3: Review labels, grouping, and the internal story. Assess whether company-imposed fees could be mistaken for government fees based on labeling or placement and document the rationale for your fee presentation in plain English so teams can explain it consistently if questions arise.

Closing thought

The Hyatt settlement should not be treated as a surprising development. Texas has announced a series of similar settlements in this area. What makes the Hyatt settlement worth reading is the clarity of the playbook and the practical way the petition frames the allegations: walk the flow, identify what the consumer sees first, and focus on whether the headline price supports real comparison shopping.

If your business competes on headline price, it is worth pressure-testing how unavoidable fees are presented across channels. The same fact pattern can draw attention from state regulators and also fuel private litigation under state UDAP and related consumer-protection theories. We help in-house teams spot issues early and align practical fixes. Reach out to us by email for information on how we can help.

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