Dan Smith
Legal Director
Head of Advertising Law (UK)
Article
5
The Competition and Markets Authority (CMA) has sent a clear message in its latest press release: "The first price customers see should be the price they pay." The regulator is continuing its crackdown on drip pricing and misleading price presentation, with enforcement activity showing no signs of slowing down.
This follows the CMA's 'major consumer protection drive' launched in November 2025, which focused on pricing practices and concerns around drip pricing.
Action included:
Several of those investigations have now concluded. Enforcement action against AA Driving School, BSM Driving School, StubHub and Marks Electrical resulted in significant financial consequences, with consumer refunds and fines becoming the norm under the CMA's new enforcement regime. According to the CMA, it has already secured more than £1.95 million in consumer refunds and imposed fines of almost £6.2 million since its strengthened consumer powers came into force.
The CMA has now opened three new investigations into businesses, including Trainline.
All three businesses have previously received advisory letters as part of the CMA's 'major consumer protection drive'. The investigations are now focused on issues such as transaction fees, booking fees, resort fees and local taxes and whether they have been included in the headline price initially presented to consumers.
Any business advertising prices to consumers should:
The CMA's message is becoming increasingly difficult to ignore. Businesses that advertise prices excluding mandatory fees now face a heightened risk of investigation, consumer redress orders and substantial financial penalties.
If you'd like support reviewing your pricing practices or stress-testing your customer journey for compliance, we're here to help.We regularly work with businesses to identify and fix drip pricing risks, design compliant price promotional strategies and respond swiftly to CMA scrutiny. Speak to Dan Smith or Zoe Pearman for expert advice.
NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as, legal advice. You should not rely on, or take or fail to take any action based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. Gowling WLG professionals will be pleased to discuss resolutions to specific legal concerns you may have.
Gowling WLG is an international law firm comprising the members of Gowling WLG International Limited, an English Company Limited by Guarantee, and their respective affiliates. Each member and affiliate is an autonomous and independent entity. Gowling WLG International Limited promotes, facilitates and co-ordinates the activities of its members but does not itself provide services to clients. Our structure is explained in more detail on our Legal Information page.
© 2026 Gowling WLG All rights reserved.