On 18 November 2025, the UK’s Competition & Markets Authority (“CMA”) announced the launch of its first consumer protection investigations under the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”).
These investigations concern eight businesses in relation to several of their online pricing practices, including their use of fees, use of misleading time-limited offers and practice of automatically opting consumers in for optional charges. The CMA at the same time also indicated that it will be sending advisory letters to 100 businesses across 14 sectors outlining concerns about their online sales tactics, and published guidance to help businesses comply with the law on price transparency and optional charges.1
The DMCCA, which came into force earlier this year2, gave the CMA wider enforcement powers, enabling it to decide whether consumer laws have been broken, rather than having to go through the courts. Substantial penalties may be imposed where the CMA finds that an infringement has taken place, which can amount to fines of up to 10% of a company’s global turnover and the payment of compensation to affected consumers. The CMA is also able to issue fines of up to 1% of a company’s turnover for failure to cooperate with an investigation.
More specifically, the CMA is investigating the following online pricing practices in respect of each of the 8 businesses targeted:
The CMA will gather information and evidence in connection with the suspected infringements during the initial phase of its investigation and is expected to give a case update in March 2026.
The advisory letters (which are being sent to 100 businesses) will look to advise the relevant businesses to review their practices around the use of additional fees and online sales tactics. These businesses were identified based on the CMA’s compliance sweeps, which looked into the conduct of over 400 businesses. The CMA identified potential concerns in the following 14 sectors: holidays (including package travel), driving schools, homeware retailers, rail travel, parking and airport parking, bus and coach travel, luggage storage providers, cinemas, live event tickets, food and drink delivery companies, letter and parcel delivery, gyms and fitness, fashion and online vouchers. These advisory letters are putting the recipients on notice that they need to review their practices to ensure that they comply with consumer protection laws (in particular with regards to pricing transparency and unfair commercial practices), at the risk of further enforcement action being taken.
In addition to announcing the actions that it is taking, the CMA has also published guidance to help businesses comply with the law on price transparency and optional charges.3
In its finalised guidance on price transparency, the CMA sets out in further detail ways in which certain pricing practices could be considered as misleading – such as drip pricing (i.e., not disclosing upfront mandatory charges to a customer, instead introducing those as additional charges later in the purchase process) or partitioned pricing (i.e., providing a breakdown of fees and charges without also providing the total price). Businesses should be especially careful around how delivery charges, administration/booking fees, periodic payments, local charges and taxes, charges paid to other traders and introductory offers are presented to their customers.
The guidance on optional charges clearly puts an obligation on businesses to obtain express consent from its customers for optional extras, such as insurance, express delivery or charity donations. With the help of visualised examples, the CMA describes how businesses can ensure that their online purchase process complies with the consumer protection regime.
Lastly, the guidance on unfair commercial practices (initially published on 4 April 2025) was updated to reflect the new guidance on price transparency.
There is a renewed focus on consumer protection, and in this climate we can expect enforcement action and more, where serious concerns arise. For instance, in the live events tickets sector, the CMA launched an investigation in September 2024 to determine whether the sale of Oasis tickets by Ticketmaster may have breached consumer law, following very public criticism from prospective ticket buyers about the lack of pricing transparency.
On 19 November 2025, the Government announced that it will become illegal to resell tickets for live events above original cost, and that enforcement of this new measure will be carried out by the CMA under its new powers granted by the DMCCA.4
Businesses should be aware of developments in this area, as the regulatory landscape evolves.
The DMCCA has ushered in fundamental changes to the consumer law landscape in the UK. In particular, the power of both the CMA and the courts to impose fines of up to 10% of an entity's worldwide turnover means that businesses must look very carefully at their commercial practices to ensure that they work fairly for consumers.
In particular, now that the CMA has published its finalised guidance on price transparency and optional charges, it will expect businesses to be familiar with their requirements, and the CMA is expected to monitor compliance by carrying out sweeps across over hundreds of businesses’ websites. The launch of the CMA’s first investigations under its new consumer protection powers sends a clearer signal than ever that it expects businesses to be up to speed with consumer protection laws, and that it is ready to intervene if it has concerns about their compliance.
Businesses should act now to ensure that their pricing structures, customer journeys and disclosures meet the legal requirements. Set out below are some practical steps that organisations should consider taking:
The CMA is actively conducting sweeps and has indicated that further investigations will follow. Businesses should prepare protocols for responding to CMA enquiries, and train customer service, legal, compliance and commercial teams on how to treat communications from the CMA. It is important to cooperate with CMA investigations as failure to do so can result in turnover-based fines of up to 1%.
Our Competition Team can assist in identifying and avoiding problematic online pricing practices, to respond to any communications from the CMA and ensure compliance with consumer protection laws more broadly so that further regulatory action may be avoided.
If you have received a letter from the CMA, and/or you would like to discuss any of the topics raised in this update more generally or receive training on the CMA’s new consumer protection powers, please do get in touch.
1 See: CMA launches major consumer protection drive focused on online pricing practices - GOV.UK,
2 See here and here
3See: Price transparency: CMA209 - GOV.UK, Unfair commercial practices: CMA207 - GOV.UK, and Getting consent for additional charges when selling online - GOV.UK.
4See Government bans ticket touting to protect fans from rip-off prices - GOV.UK.
