Drip pricing: will you be fined next?

The Competition and Markets Authority (CMA) has made drip pricing one of its top enforcement priorities, and it is now backing that up with multi-million-pound fines. Several household names have already been caught out.

If you have not already reviewed your pricing journey, now is the time to ask yourself: Would your online checkout process withstand CMA scrutiny?

What is drip pricing?

Drip pricing is the practice of advertising an initial headline price and then adding further mandatory charges as the customer moves through the purchase process. As a result, the final price at checkout is higher than the price that first caught their eye.

Drip pricing has been common practice for years, but it is no longer lawful in the UK since 6 April 2025; it is a new banned practice under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The core rule is straightforward: if a customer cannot complete a purchase without paying a particular fee, tax, or charge, that amount is mandatory and must be built into the headline price shown at the start of the journey. This is different from genuinely optional extras, such as priority boarding or gift wrapping, which can still be added later provided they are clearly optional and not a precondition of the sale.

Examples of drip pricing

Some of the most common breaches we see, and that the CMA has called out, include:

• booking fees, delivery charges or “service charges” added only at the final payment screen
• local taxes or resort fees excluded from the advertised holiday price
• digital or administration fees on driving lessons, tickets or bookings that are not disclosed upfront
• minimum order thresholds where an unavoidable delivery charge is not reflected in the headline price

Why the CMA is taking this so seriously

The CMA has framed drip pricing as a cost-of-living issue. Its position is that dripped fees erode trust and disproportionately affect consumers who are already watching every pound, particularly on high-value purchases such as travel, tickets, and driving lessons. The CMA has also stated explicitly that it intends to use its new enforcement powers, and its record over the past year demonstrates that it is following through.

The DMCCA grants the CMA direct enforcement powers. This means it can investigate suspected breaches of consumer protection law and impose penalties itself, without first going to court. For relevant breaches, those penalties can be up to £300,000 or 10% of a trader’s annual worldwide turnover, whichever is higher.

Recent CMA enforcement action

• Fined the AA and BSM driving schools £4.2 million on 15 April 2026 and ordered more than £760,000 in refunds to over 80,000 learner drivers after a mandatory booking fee was added only at the final stage of checkout.
• Fined StubHub UK on 23 June 2026 close to £900,000 for drip pricing relating to mandatory delivery and service fees on ticket purchases, and required refunds exceeding £590,000 to more than 50,000 customers.
• Opened drip pricing investigations into Trainline (mandatory booking fees), Virgin Atlantic (mandatory resort fees and local taxes on package holidays), and RED Driving School (booking and digital fees) on 19 August 2026.
• Fined Marks Electrical £720,000 on 18 June 2026 and ordered £600,000 in redress for opting customers into additional charges without express consent.
• Opened investigations on 17 November 2025 into Gold’s Gym over how mandatory fees are presented, and into Wayfair and Appliances Direct over pricing and time-limited sale practices.
• Sent advisory warning letters to 100 businesses, with the travel sector specifically identified as a key area of concern.
• Carried out a cross-economy review of more than 400 businesses across 19 sectors, identifying potential compliance concerns in 14 of those sectors.

This is only the beginning. Further enforcement is likely to follow. If you look out for it, you will still see drip pricing in many everyday purchases. The market has been slow to respond to the new law, but businesses should not take false comfort from the fact that competitors may not yet be compliant. Your industry may be next in the CMA’s enforcement spotlight.

What businesses should do now

• Map every step of your online purchase journey exactly as a customer experiences it, from the first search result to final payment.
• Identify every fee, charge, or tax a customer cannot avoid, and verify that it is reflected in the headline price rather than appearing later.
• Distinguish clearly between mandatory charges and genuinely optional extras in how they are presented.
• Review pricing across all channels, including apps, third-party booking platforms, and affiliates, not just your own website.
• Maintain a record of the review and any changes made, as the CMA has demonstrated that it takes earlier warnings into account when assessing penalties.

Get in touch

If your business still uses drip pricing, you are at risk of CMA enforcement action. With fines running into the millions and more investigations opening this year, now is the time to have your pricing journey reviewed before the CMA does it for you. If you would like us to audit your customer journey against the CMA’s guidance, please get in touch with our team today.