In its annual plan for 2026-2027, published in March, the CMA said it would focus consumer enforcement on the clearest and most serious harms, including terms that are obviously imbalanced or unfair.
Following a complaint by Which?, the CMA has now launched an investigation into Ryanair over charging parents to sit with their children on flights.
UK law does not require airlines to seat families together. However, the Civil Aviation Authority advises that young children and infants should ideally be seated in the same row as their accompanying adults. Ryanair's terms and conditions of carriage require at least one parent to sit with children aged 2–11. Ryanair charges a fee for what it calls a "mandatory family seat", which a parent must pay to secure a seat next to the child. For other passengers, reserving a seat is optional. The fee applies on both outbound and return flights and typically costs around £8 each way.
The CMA says its evidence suggests Ryanair uses this approach across most of its UK routes, although not on every flight. In some cases, parents may be seated with their children at no additional cost. The CMA has also noted that, following action by Italy's Civil Aviation Authority, Ryanair does not apply this fee on flights to and from Italy.
Unfair terms
The CMA is investigating whether Ryanair's approach to seat reservations results in parents being charged for the airline to meet child safety and disability-related obligations under aviation rules, and whether that approach complies with consumer law.
In particular, the CMA is considering whether Ryanair's relevant contract term is unfair under the Consumer Rights Act 2015. An unfair term is not binding on consumers, and the CMA can take enforcement action to stop businesses using it. The CMA published updated draft guidance on unfair terms earlier this year.
The CMA understands that Ryanair is the only major airline operating from the UK to impose this charge. Other airlines either seat children with a parent or guardian without requiring a paid adult seat reservation, or allocate seats together automatically during booking at no extra cost. Ryanair's website refers to "Free reserved seats for kids under 12", but parents and guardians must pay a booking fee to access those seats. Ryanair has reportedly argued that charging only the parent makes the fee permissible. It also told Which?: "For safety reasons, children under the age of 12 must sit beside an accompanying adult, and infants (aged 8 days to 23 months inclusive) must sit on an accompanying adult's lap. It is mandatory for an adult travelling with children under 12 (excl. infants) to reserve a seat".
Drip pricing
The CMA is also considering whether the mandatory family seat fee is "dripped" during the booking process, rather than being included in the total price presented to consumers upfront.
Under the Digital Markets, Competition and Consumers Act 2024, businesses must show consumers the total price, including all unavoidable charges, rather than adding those charges later in the purchase journey. The aim is to make pricing transparent and enable meaningful comparison between offers. See our guide on drip pricing.
Price transparency remains a key enforcement priority for the CMA, which has already opened five cases under its new powers in this area.
What happens next?
The CMA will now examine the evidence and decide whether Ryanair's approach breaches consumer protection law. Depending on its findings, the investigation could end with no further action, lead to changes in Ryanair's practices, or result in enforcement action. Under the new consumer regime, the CMA can impose fines of up to 10% of global turnover (or £300,000 if higher) and also order redress to be paid to affected consumers.
The case is a useful reminder that the CMA is actively scrutinising pricing architecture, customer journeys and standard terms, particularly where charges may be difficult to justify as optional in practice. Businesses with consumer-facing booking flows or add-on fees should review whether mandatory charges are surfaced clearly and whether related terms could be challenged as unfair. For more information, see our Consumer Law Hub.
