The Supporting Equal Access to Tables Act of 2024 (SEAT Act of 2024) seeks to regulate the practices of third-party restaurant reservation services. The bill prohibits these services from listing or promoting restaurant reservations without a formal agreement with the food service establishment. It empowers the Federal Trade Commission (FTC) to enforce these rules, applying them 180 days after the bill's enactment. The legislation aims to ensure that all reservations made through such services are authorized by the establishments themselves, thereby enhancing transparency and fairness in the dining industry.

Summary of Significant Issues

One of the primary concerns is the reliance on the Federal Trade Commission for enforcement, which may not be specifically equipped to handle the unique challenges posed by third-party reservation services. This could lead to ineffective oversight and inconsistent application of the law. Additionally, the bill does not specify penalties for violators, further complicating enforcement efforts.

Another critical issue is the broad definition of "food service establishment," which encompasses a wide range of entities, including potentially unintended ones like temporary event vendors. This broad scope could lead to legal disputes and regulatory overreach. Furthermore, the bill lacks clarity on what constitutes a proper "written agreement" between third-party services and establishments, introducing potential compliance challenges.

The 180-day compliance window may also be unrealistic for some service providers, who might struggle to renegotiate agreements with all their listed establishments, possibly resulting in operational disruptions. Lastly, the bill does not address jurisdictional conflicts that could arise if a service operates across state lines, posing regulatory challenges.

Potential Impact on the Public

For the general public, the bill seeks to guarantee that all reservations made through third-party services are legitimate and authorized by the restaurants themselves. This could lead to a more straightforward and trustworthy reservation process for diners, potentially reducing instances of overbooking or unrecognized reservations at establishments.

Impact on Stakeholders

For restaurants and food service establishments, the bill could ensure greater control over their reservations, preventing unauthorized listings that might mislead customers or cause operational hiccups. However, smaller establishments might face challenges in negotiating agreements with third-party services, particularly if they lack legal expertise.

For third-party reservation services, the bill introduces compliance burdens, as they will need to secure formal agreements with every establishment they list. This could require significant administrative efforts, particularly for smaller services with limited resources. The absence of clear guidelines on penalties and cross-jurisdictional operations could create additional complications.

For customers, the legislation promises increased reliability and legitimacy in reservation systems but may result in fewer available options if some third-party services find compliance overly burdensome and reduce their listings.

Overall, while the SEAT Act of 2024 aims to foster fairness and transparency in the restaurant reservation industry, its broad definitions and enforcement mechanisms may pose challenges that could affect various stakeholders differently. The details of enforcement and compliance clarity will be crucial in determining the effectiveness of the bill in practice.