On 18 November, the Competition and Markets Authority (CMA) published its long-awaited Price transparency guidelines (the Guidelines) under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The Guidelines represent a significant shift in the UK’s consumer protection landscape, aimed at tackling misleading pricing practices and ensuring that consumers receive clear, upfront information about the total cost of goods and services. The Guidelines apply to any “invitation to purchase,” including online listings, advertisements, and influencer promotions and will help businesses comply with the requirements stipulated under the DMCCA which we set out here: Unfair trading with consumers - an overview of UK rules and reforms under the DMCCA - Stevens & Bolton LLP.

Core requirements

The basic premise of the Guidelines is that prices must not be misleading and include any fees, taxes, charges, or other payments that consumers will necessarily incur, with the total price presented at the outset wherever possible and communicated to the customer. Price information must be provided to the consumer in a “clear and timely way and in such a way as the consumer is likely to see it” and must relate to the product that is being advertised. For example, if an invitation to purchase presents a particular version of a product such as a car or phone model, or advertises the product as having certain features, the price should reflect what the consumer would need to pay to obtain that version of the product. 

Mandatory and optional charges

The Guidelines differentiate between “mandatory charges” and “optional charges”. If the consumer cannot purchase the advertised product without the payment of a charge (i.e. any fee, tax, charge or other payment), then that charge is mandatory. Mandatory charges should be included in the total price for the product and include charges such as VAT, administration fees, delivery charges, local taxes, pick up fees for example on car hire, or joining fees such as a gym membership.  The total price given in an invitation to purchase should relate to the specific product being advertised (e.g. a weekend’s stay at a hotel). In some cases, a trader may wish to offer an optional service in addition to the product they are selling - this can be presented separately and does not have to be included in the headline price if it is genuinely optional. However, merely presenting a charge separately to the headline price or describing it as an extra service does not make it optional. If the consumer will have to pay the additional charge in order to purchase or receive the advertised product, it is a mandatory charge. It is still a mandatory charge even if the consumer could theoretically avoid it by purchasing or signing up for an additional product, or paying an additional membership fee. 

Drip pricing and partitioned pricing 

Practices such as “drip pricing” (adding unavoidable costs late in the process) and “partitioned pricing” (showing component prices without the overall cost) are prohibited. Businesses must clearly distinguish between base price, headline price, total price, and final price, ensuring consumers can make informed decisions before committing to purchase. See the below examples:

1. Drip pricing: a company offers an online learning course in a specific subject area for £100, when the consumer prepares to pay the £100 total, they are informed of an additional mandatory £40 “enrolment fee” to access the course content - the consumer should have been presented with the total price of the course which is £140 at the outset.
2. Partitioned pricing: a luggage storage provider advertises a £5 per-bag, per-day price to store a suitcase in one of a range of secure locations across the UK. Below this headline price is a statement that all bags will incur a mandatory £2 per-day ‘service charge’. The £2 per-day ‘service charge’ should be included in the headline price so that the cost per-bag, per-day is £7. The trader can state that the price includes a £2 per-day service charge.

Calculation of the total price

For most products the total price of a product will be clear and easily calculable. However, there are some products for which this may be more difficult where, owing to the nature of the product, the whole or any part of the total price cannot reasonably be calculated in advance. In such instances where the total price cannot be reasonably calculated in advance, consumers should be given information about how the price (or that part of it) will be calculated. The exception will commonly apply to products sold by; weight, length, time and distance. If the nature of a product means that its total price cannot reasonably be calculated in advance, the trader must instead give the consumer the information needed to enable the consumer to calculate the total price themselves (e.g. the price per kg or the price per person). This may particularly affect international e-commerce businesses as the landed cost price should be shown rather than just signposting to a customer that they are responsible for any additional taxes and duties applicable in their country.

Practical compliance 

The Guidelines set out numerous worked examples of how to apply the pricing requirements under the DMCCA in a user friendly, practical way. Responsibility for compliance rests with the party “making the invitation to purchase”—this could be a retailer, marketplace operator, or even an influencer promoting goods - this means that companies may be liable for non-compliance by their influencers, market places or affiliates promoting and selling products on their behalf and as such, either these parties need to be made aware of what they need to do to comply with the Guidelines, OR companies should implement a pre-approval mechanism of promotional content encouraging consumers to buy to ensure compliance. Non-compliance can trigger enforcement action, including fines of up to 10% of global turnover, making this a critical compliance area for consumer-facing businesses. Companies should therefore conduct a pricing audit, update internal policies, review marketing practices and train marketing and sales teams on the new requirements (including the Guidelines). Given the CMA’s new administrative powers under the DMCCA and the investigations launched by the CMA on 18 November 2025 across the ticketing, driving schools, gyms, and homeware sectors (see our discussion this here: Significant new enforcement of consumer pricing practices); early alignment with these Guidelines is essential to mitigate exposure to significant financial penalties and reputational harm.