Dan Smith
Legal Director
Head of Advertising Law (UK)
Article
The Competition and Markets Authority (CMA) has published an open letter to online retailers selling goods to UK consumers, warning businesses to ensure their pricing practices comply with the Digital Markets, Competition and Consumers Act 2024 (DMCCA).
The message is clear: "The first price consumers see should be the price they pay". Where a delivery charge must be paid to buy a product, the price displayed to consumers throughout the sales process must include the minimum mandatory delivery charge.
With the Christmas shopping period approaching, the CMA has warned that some businesses are still presenting delivery charges in ways that do not comply with the DMCCA's price transparency requirements.
At a basic level, where a business gives consumers the price of a product as part of an "invitation to purchase", the DMCCA requires the total price to be displayed. This means including any mandatory delivery or collection charges, as well as other unavoidable fees, taxes and charges.
Importantly, the total price must be provided at every stage of the customer journey where a price is displayed, including in advertising, on product and listing pages, in shopping baskets and order summaries, and throughout checkout and payment.
The CMA's expectations can broadly be summarised as follows:
where one charge applies to the whole order, regardless of how many items are bought, you must show the total price payable, including any mandatory delivery or collection charge, throughout the shopping process.
You may also provide additional information, such as:
You must make clear throughout the shopping process that optional delivery charges apply.
Where the amount cannot reasonably be calculated in advance, clearly explain that an additional delivery charge is payable and explain how it should be calculated.
This information should be prominent and readily visible. Businesses should not rely on customers accessing links, separate pages, pop-ups, expandable sections or drop-down menus to find it.
The requirements also apply to marketplaces, comparison sites and search engines. Where items from different traders each carry their own delivery charge, delivery should be included in the total price of each product.
The CMA has identified a number of practices that it is specifically scrutinising, including:
With the CMA signalling that it is prepared to take enforcement action, online retailers and other businesses selling to UK consumers should review their pricing practices now. In particular, we recommend:
We have been advising clients on the compliance of their customer journeys, pricing practices and product listings with the DMCCA. If you would like to discuss what the CMA's approach means for your business, please speak to Dan Smith or Zoe Pearman.
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.