The Middleton family has complained to the Press Complaints Commission after four papers published photographs of Kate and Pippa in bikinis.
The five-year-old snaps of the sisters with their mother, Carole, showed them swimming, diving and relaxing on and around a yacht off Ibiza.
They appeared in the News of the World, Daily Mail, Mail on Sunday and Daily Mirror - none of whom have commented.
The complaint is likely to focus on whether their privacy was invaded.
Many of the photographs, taken in 2006, have been published before but are now more in demand given Kate's marriage to Prince William and her new royal status as the Duchess of Cambridge.
PaparazziOne photograph in the News of the World showed Pippa removing her bikini top under the headline "Oh buoy it's Pippa". They have since been removed from the paper's website.
The Mail on Sunday's article showed the sisters on their uncle Gary Goldsmith's yacht under the headline "Perfect Pippa - and the Prince of Belly Flops".
The Middletons were on holiday with Prince William, who also appeared in some of the shots.
A press watchdog spokesman said: "I can confirm that the PCC has now received complaints from representatives of the Middleton family concerning photographs published in the News of the World, Daily Mail, Mail on Sunday and Daily Mirror. We will now consider those complaints."
The complaint, exposing tensions between the Royal Family and Middletons on one side and the paparazzi on the other, is not the first by the Middletons.
In April, Kate Middleton's family contacted the PCC over alleged "harassment" by photographers.
The BBC understood it followed incidents where Carole and Pippa Middleton were followed by agency photographers on mopeds.
At the time, the PCC sent an advisory notice to editors reminding them of their ethical obligations.
The Editors' Code of Practice, ratified by the PCC, states: "It is unacceptable to photograph individuals in private places without their consent."
It defines private places as "public or private property where there is a reasonable expectation of privacy".
Clarence House declined to comment about the latest complaint.
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