The UK Competition and Markets Authority (CMA) has launched its first investigations under the Digital Markets, Competition and Consumers Act 2024 (DMCC) into the online pricing practices of eight companies, which includes driving schools, ticket resellers, homeware and appliance retailers and a gym.
On 6 April 2025, the CMA gained new enforcement powers under the DMCC, including the power to impose fines of up to 10% of global turnover for breaches of UK consumer law. This marks a significant shift in the risk profile for B2C businesses in the UK. The DMCC made clear that drip pricing is prohibited, which includes the failure to include mandatory charges upfront, introducing unavoidable fees at checkout and presenting misleading headlines prices.
On 18 November 2025, the CMA published its final price transparency guidance and a summary of responses to its consultation on a previous draft of the guidance, to help businesses comply with the law on price transparency and optional charges. The CMA is sending advisory letters to 100 businesses across 14 sectors to put them on notice to review their practices around the use of additional fees and other online sales tactics.
The CMA’s investigations target drip pricing, misleading countdown timers (i.e. creating false urgency where no time-limited offer exists) and default opt-ins (i.e. pre-selecting optional extras instead of requiring consumers to actively opt-in).
In this article, we summarise the key points that consumer-facing businesses should note from the CMA’s Guidance and what they should consider doing now.
Price Transparency Guidance
The Guidance advocates against misleading pricing practice. It makes clear that businesses should be careful about ensuring that prices include any fees, taxes, charges or other payments that consumers will necessarily incur, with the total price presented at the outset wherever possible. As such, this information must be provided to the consumer in a clear and timely manner at the start of the purchase journey and in wider promotional material.
The Guidance provides clarity on the distinction between mandatory and optional charges. If consumers cannot purchase the product without paying a charge (such as delivery charges where there is no free click and collect), that charge is mandatory that should be reflected upfront and must be included in the total price. For example, businesses can present pricing information such as showing the base cost excluding delivery as the headline price, with the total price (including delivery charges) below, or providing the total price with a breakdown. Where mandatory delivery charges vary and cannot be reasonably calculated in advance, businesses must indicate that they are payable and how they will be calculated, with this information being prominent.
In contrast, an optional charge relates to an optional service which is being offered in addition to the advertised product (such as express delivery, charity donation, etc). Businesses must obtain express consent from customers for optional extras.
Where the nature of the product means that the whole or part of the total price cannot be reasonably calculated in advance (such as products sold by weight, time, length or distance), traders must provide information about how the price will be calculated in advance with equal prominence. Once the total price becomes calculable, it must be presented as such from that point onwards.
What should businesses do to reduce their risk?
As the CMA has published its finalised Guidance on price transparency and has begun taking enforcement action, it will expect businesses to be familiar with the requirements, It is important for businesses to act now to ensure their pricing practices and customer journeys are compliant with the DMCC. We have set out some practical tips to keep in mind below:
- Review your website to ensure that all misleading online pricing practices are amended so that you are compliant.
- Update wider promotional material. For example, to ensure that advertising does not make use of “headline” prices that would be regarded as misleading.
- Staff awareness training: It is important for staff to be aware of the DMCC requirements to ensure that internal processes reflect the legal requirements (such as ensuring promotional activity is compliant).
The CMA’s initial actions are likely the start of a broader crackdown.
Please contact our team at [email protected] if you have any pricing questions considering the legal requirements, complying with other consumer law obligations or responding to a CMA investigation or letter.
