Drip pricing and the DMCC Act: show the full price or risk enforcement

If your website shows one price and your checkout shows a higher one, you have a problem. Drip pricing is now one of the first targets of the Competition and Markets Authority's new powers under the DMCC Act, and the regulator has already fined businesses and ordered refunds. The good news is that most websites can be checked, and fixed, in an afternoon.

What drip pricing is

Drip pricing is when a business advertises a headline price, then adds charges the customer cannot avoid as they move through the booking or checkout. Common examples are booking fees, service fees, admin fees, card fees on every payment route and compulsory delivery charges.

The customer does not see the true cost until they are several clicks in and emotionally committed. That is the point regulators object to. Optional extras, such as next-day delivery or an upgrade, are a different matter. They still need to be shown clearly, but they can sit outside the headline price.

What the DMCC Act says about drip pricing

The Digital Markets, Competition and Consumers Act 2024 gave the CMA power to enforce consumer law directly from April 2025, without going through the courts first. The Act includes a specific ban on drip pricing, where an initial price is shown and further unavoidable fees are added during the purchase.

The penalties are significant. The CMA can fine a business up to 10% of global turnover, or £300,000 if that is higher, and can require compensation for affected customers.

The CMA's price transparency guidance (CMA209, published January 2026) sets out what it expects:

• The total price, including unavoidable fees and taxes, should appear in the "invitation to purchase". That can be a product page, an advert or an email, not only the checkout.
• Flat, per-order mandatory charges such as a booking fee must be built into the total, even in early advertising.
• Where a charge varies, for example delivery by location, you must explain it clearly enough for the customer to work out the total, and include it once it can be calculated.
• "From" prices are allowed, but only if they include all mandatory charges.

The CMA has also been clear that listing fees separately "will not normally be enough".

Enforcement so far

This is no longer theoretical. In April 2026 the CMA fined the AA £4.2 million over a mandatory £3 booking fee on AA and BSM driving lessons that was left out of the upfront price, and ordered more than £760,000 in refunds. In June 2026 it fined StubHub UK £889,200 for adding mandatory delivery and service fees late in checkout, with refunds of more than £590,000. In August 2026 it opened drip pricing investigations into Trainline, Virgin Atlantic and RED Driving School. In the CMA's own words: "The first price customers see should be the price they pay."

Who is affected

Any business that sells to consumers and shows prices online should take this seriously. The highest-risk sectors are those where fees are part of the business model:

• E-commerce: compulsory delivery, packaging or "handling" charges.
• Bookings and appointments: booking or admin fees on lessons, treatments, classes and rentals.
• Events and ticketing: service and delivery fees.
• Travel and hospitality: resort fees, local taxes and cleaning charges.
• Services and memberships: joining fees, set-up fees and minimum terms not shown with the monthly price.

If you are mostly B2B but also take bookings or sales from individuals, your consumer-facing pages are still in scope.

A 15-minute drip pricing website check

You do not need a lawyer to spot the obvious issues. Open your website on your phone and buy something, or book something, as a customer would.

1. Write down the first price you see. Note it from your adverts, search listings, emails and product or service pages.
2. Walk the whole checkout. Go all the way to the payment screen and note every line that gets added.
3. Sort each fee. Is it mandatory (everyone pays it) or optional (the customer chooses it)?
4. Compare. If any mandatory fee appears at checkout but not in the first price, that is the issue to fix.
5. Fix the display. Fold mandatory fees into the headline price. Where a fee really does vary, explain how it is calculated next to the price, with equal prominence.
6. Check your other channels. Price comparison feeds, Google Shopping, social ads and email campaigns all count as invitations to purchase.

Then repeat the check every time you change your pricing, checkout or booking system. Third-party plugins and booking tools are a common source of fees that appear without anyone deciding they should.

Our website compliance checklist for 2026 covers drip pricing alongside cookies, reviews and accessibility, so you can work through everything in one go.

Frequently asked questions

Is a booking fee illegal under the DMCC Act?

No. Charging a booking fee is allowed. The problem is hiding it. If every customer has to pay it, it must be included in the price you show upfront rather than added later in the checkout.

Can I still show VAT separately?

For consumers, the total price should include VAT and other unavoidable taxes. Prices aimed only at business buyers are treated differently, but if consumers can buy from the same page, show the VAT-inclusive total.

What if my delivery charge depends on location?

Explain how it is worked out, close to the price and with the same prominence. Once the customer has given enough information for you to calculate it, include it in the total. If customers must pick a paid delivery option, show the cheapest by default.

Get a second pair of eyes on your checkout

If you would rather not audit your own pricing journey, we can do it for you. Request a free website audit and we will flag pricing, compliance and conversion issues in plain English, with clear next steps.

Sources

• CMA: new consumer protection regime comes into force (April 2025)
• CMA: Providing clear and accurate information about prices (CMA209)
• CMA orders the AA and BSM driving schools to refund learner drivers over drip pricing
• CMA orders StubHub UK to refund customers over hidden fees
• Trainline, Virgin Atlantic and RED Driving School investigated for drip pricing

This article is general information, not legal advice.