Price transparency is firmly in the CMA's sights. This week, the Competition and Markets Authority ("CMA") launched three new drip pricing investigations, its latest in an enforcement campaign that shows no sign of slowing down. Businesses wanting to avoid scrutiny from the CMA and the threat of hefty fines should review their pricing practices sooner rather than later.

What is drip pricing, and why does the CMA care?

Drip pricing is when an initial price for a product, service or digital content is presented to a consumer only for additional mandatory charges to be added to it further along the customer journey. The new Digital Markets, Competition and Consumers Act 2024 ("DMCCA") makes substantial changes to consumer law, including drip-pricing, requiring the "total price" to be provided upfront in consumer journeys.

Government research has estimated that dripped fees (other than delivery fees) cause UK consumers to spend between an additional £595 million to £3.5 billion each year. The CMA has said that enforcing drip pricing is a priority, as part of its efforts to assist consumers experiencing cost of living pressures by enabling them to compare prices, shop around and make informed choices more easily.

Last year, the CMA began a cross-economy review of more than 400 businesses across 19 sectors, looking closely at whether businesses were being transparent with consumers about prices. The CMA identified potential compliance concerns in 14 sectors and, in November 2025, wrote to 100 businesses to put them on notice.

Trains, planes and driving lanes: three new investigations

The CMA launched its first wave of drip pricing cases towards the end of last year.  Five of these were about mandatory booking fees and whether their presentation breached the new law.  The CMA has now launched three new consumer protection investigations into firms suspected of failing to show customers the full price upfront. The move forms part of a broader clampdown on misleading pricing practices.

The three investigations focus on:

• Trainline: whether all mandatory fees were included in the upfront prices shown to consumers buying advance train and coach tickets through the Trainline app and website. For train travel, the CMA observed fees ranging from £0.59 to £2.79. For coach bookings, the fee was £1.50. These may look small individually, but they can quickly add up for frequent travellers.
• Virgin Atlantic: whether mandatory resort fees and local taxes were included in the upfront prices shown to customers buying package holidays. These fees vary but can run to hundreds of pounds and materially change the cost of a holiday.
• RED Driving School: how a mandatory booking fee and "digital" fee were displayed to learners booking driving lessons, and whether those fees, £7 or more per booking, were included in the total upfront price.

What's at stake?

For now, the CMA is only at the start of its investigations and has not reached any conclusions on whether the firms have broken the law. But the potential consequences are significant given the CMA's new powers under the DMCCA. If the CMA finds an infringement, it can order businesses to pay compensation to affected customers and impose fines of up to 10% of global turnover.

As we have seen in the first cases which have reached this stage already, businesses are also likely to have to refund consumers on top of a fine, which adds to the financial risk of non-compliance.

Ignore advisory letters at your peril

The fact that these businesses had already received "advisory letters" also matters. Those letters, sent as part of the CMA's first consumer protection drive using its new enforcement powers, reminded businesses of their obligations under consumer law.

The CMA's continued concerns show that advisory letters should not be treated as light-touch correspondence. Think of them less as friendly advice and more as a shot across the bows.

A business that receives an advisory letter and fails to change course may find that the CMA treats such inaction as an aggravating factor when calculating any subsequent penalty. This would be on the basis that it was committed knowingly, or at least that the business had every opportunity to comply and chose not to.

What should businesses do now?

The message is clear: if the CMA has been in touch, and even if it hasn't yet, now is the time to ensure your pricing practices are compliant, ahead of further action in this area.  In-house teams should be taking practical steps now to reduce exposure:

• Audit your customer journey end-to-end. Map every fee and charge that is added between the headline price and final checkout - and check whether each one is genuinely optional or effectively mandatory.
• Review how prices are displayed. Ensure that all unavoidable costs are included in the price shown to consumers, across every sales channel - website, app, call centre and in-store.
• Stress-test with fresh eyes. Consider engaging external advisers to identify pricing practices that may have become normalised internally but look misleading from a consumer's perspective.

Acting now is likely to be far cheaper than dealing with enforcement action, fines and consumer redress down the line.

If you would like help reviewing your pricing practices, please contact us or consult our Consumer Law Hub.