Industry outlook based on 2022–2025 regulatory trends

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Introduction

Hotels, resorts, short-term rentals, and travel platforms rely heavily on personal data—guest names, contact details, payment information, loyalty programs, location data, and increasingly, artificial intelligence (AI)-driven personalization tools.

As of 2025, the United States still does not have a single comprehensive federal data privacy law, requiring hospitality businesses to comply with a patchwork of state laws and sector-specific federal rules

Looking ahead to 2026, federal privacy policy is expected to continue evolving, shaped by state legislation, federal enforcement actions, and proposed—but not yet enacted—federal privacy bills.

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1. The Current Federal Privacy Landscape (Confirmed)

As of 2025:

• There is no comprehensive U.S. federal consumer privacy law
• Many states have enacted their own privacy statutes
• Federal agencies, particularly the Federal Trade Commission (FTC), actively enforce data protection standards

Legal and regulatory reviews confirm that state privacy laws are filling the federal gap, creating compliance challenges for hospitality businesses operating nationwide

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2. Why Hospitality Faces Higher Privacy Expectations (Confirmed Trend)

Hospitality businesses routinely collect:

• Identity and contact information
• Payment and transaction data
• Location data
• Loyalty and behavioral data

Regulators consistently identify these categories as high-risk personal data, especially when combined with digital tracking and analytics
This makes hospitality a frequent focus of regulatory scrutiny, even without a single federal privacy statute.

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3. Federal Privacy Direction Toward 2026 (Predictive, Not Confirmed Law)

Although the United States has not enacted a comprehensive federal consumer privacy law, congressional activity between 2022 and 2025 indicates a consistent policy direction. Based on these developments, any future federal privacy framework is likely to align with standards already established by state privacy laws, rather than creating an entirely new regulatory model.

Federal proposals and hearings commonly reference:

• Consumer rights to access, delete, and correct personal data
• Data minimization, limiting data use to defined business purposes
• Greater transparency around how personal data is collected, used, and shared

One prominent example is the American Privacy Rights Act (APRA), introduced in Congress in 2024. While the proposal outlines a nationwide baseline for consumer data protection, it has not been enacted into law as of 2025

For clarity, references to future federal privacy requirements in this article are intentionally framed as “likely,” “expected,” or “based on current trends,” not guaranteed outcomes.

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4. AI, Personalization, and Guest Data (Confirmed Trend)

AI tools are increasingly used in hospitality for:

• Personalized guest offers
• Dynamic pricing
• Customer service chatbots
• Operational forecasting

While there is no comprehensive federal AI privacy law, recent federal action—including the passage of targeted digital safety legislation—signals growing attention to AI-related privacy risks

Hospitality businesses using AI should expect increased expectations around transparency, oversight, and responsible data use.

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5. Third-Party Vendors and Shared Accountability (Confirmed Enforcement Direction)

Hospitality businesses rely heavily on third parties, including:

• Booking platforms
• Property management systems
• Payment processors
• Marketing and analytics providers

Regulatory guidance increasingly emphasizes that outsourcing data processing does not eliminate responsibility. Businesses are expected to conduct due diligence, maintain contractual safeguards, and monitor vendor practices

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6. Data Security and Breach Preparedness (Confirmed)

Even without a comprehensive federal consumer privacy law, data security obligations are actively enforced at the federal level. The Federal Trade Commission uses its authority under Section 5 of the FTC Act to take action against companies that fail to implement reasonable security measures to protect personal data.

The FTC has consistently stated that businesses must take proactive steps to safeguard personal information

For hospitality businesses, this includes:

• Conducting regular risk assessments
• Maintaining documented incident response plans
• Training employees on privacy and data security practices
• Preparing for breach notification obligations under applicable laws

Based on enforcement patterns from 2022–2025, regulators are expected to continue focusing on whether organizations took reasonable, proactive steps to prevent harm, not just whether a breach occurred.

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7. What Hospitality Businesses Should Do Now

Regardless of whether a federal privacy law is enacted by 2026, hospitality businesses can reduce risk by:

• Mapping guest data across systems and vendors
• Reviewing privacy notices for clarity and accuracy
• Evaluating AI tools for privacy risks
• Strengthening vendor oversight programs
• Aligning practices with leading state privacy standards

These actions reflect current regulatory expectations, not speculative requirements.

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How The Data Privacy Lawyer LLC Can Help

The Data Privacy Lawyer LLC helps hospitality businesses translate evolving privacy expectations into practical, business-friendly solutions, including:

• Privacy readiness assessments
• Vendor and SaaS risk reviews
• AI and data governance support
• Federal and state compliance planning

📧 info@thedataprivacylawyer.com
🌐www.thedataprivacylawyer.com

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Editorial Disclaimer

This article is for informational purposes only and reflects regulatory developments observed between 2022 and 2025. References to potential federal privacy requirements are predictive and based on existing proposals, enforcement trends, and state legislation. This content does not constitute legal advice.