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1. Summary
On 18 November 2025, the UK's Competition and Markets Authority ("CMA") launched what it described as a "major consumer protection drive" targeting online sales tactics, including drip pricing and pressure selling.
As part of the drive, the CMA has opened investigations into 8 businesses and issued advisory letters to 100 firms. It has also published its finalised price transparency guidance for businesses.
2. Background
The CMA's new consumer protection regime under the Digital Markets, Competition and Consumers Act ("DMCCA") 2024 came into force in April 2025. It gave the CMA new direct enforcement powers, including the ability to issue fines for companies that fail to comply with consumer protection laws, of up to 10% of the company's annual worldwide turnover.
The new regime also introduced new banned practices regarding drip pricing (the practice of adding additional charges as consumers progress through the purchase process) and fake online reviews, which are in force now, as well as new rules for businesses offering subscription contracts, which are due to come into force in 2026.
When the consumer protection regime came into force in April, the CMA published procedural guidance regarding its approach to enforcement, and committed to publishing more detailed guidance on pricing later in the year. The CMA also said that its initial enforcement activity would target only practices which "clearly breach the rules" regarding drip pricing, and that during the first three months of the new regime its focus regarding fake and misleading reviews would be on supporting compliance rather than on enforcement.
The new regime has now been in force for over six months, and the CMA has announced a major package of action which it says will ensure people can shop with confidence and allow fair-dealing businesses to compete on a level playing field. The launch of the consumer protection drive follows a major cross-economy review, during which the CMA assessed the price transparency compliance of more than 400 businesses in 19 different sectors. The CMA says it identified compliance concerns in 14 sectors, including drip pricing and the use of misleading countdown timers, which are banned under the new regime.
Writing on LinkedIn, the CMA's CEO Sarah Cardell said:
"People across the UK deserve a fair deal. Whether you're spending your money on concert tickets, driving lessons, a gym membership or buying furniture and appliances for your home, it's important you're treated fairly and know what you're paying upfront.... Since the launch of the new regime, we've been working hard to help businesses understand the law. Alongside supporting businesses to comply, we've always been clear that we will take swift action where we suspect potentially serious breaches of the law. This is just the start of our work, any businesses who break consumer law should be in no doubt we will stamp out illegal conduct and protect the interests of consumers and fair-dealing businesses".
3. Enforcement action
The CMA has opened investigations into StubHub, viagogo, AA Driving School, BSM Driving School, Gold's Gym, Wayfair, Appliances Direct and Marks Electrical. These investigations are the first enforcement cases opened by the CMA using its new powers under the DMCCA.
The specific conduct being investigated is as follows:
- StubHub and viagogo: the imposition of mandatory additional charges applied when consumers buy tickets, and whether or not these fees are included upfront.
- AA Driving School and BSM Driving School: whether certain mandatory fees are included in the total price the consumer sees at the beginning of the purchase process.
- Gold's Gym: whether a one-off joining fee for its annual membership is introduced part way through the sign-up process and not included in advertised membership costs.
- Wayfair, Appliances Direct, and Marks Electrical: whether time-limited sales ended when they said they would, and/or whether customers are being automatically opted in to purchasing additional services.
If the CMA finds there has been an infringement of the law, it can fine the infringing business up to 10% of its annual worldwide turnover, as well as ordering the business to pay compensation to affected consumers.
4. Advisory letters
In addition to the 8 formal enforcement cases, the CMA has also
sent advisory letters to 100 businesses, outlining concerns about
their use of additional fees and online sales tactics in areas
identified as "key areas of spending", including:
holidays, driving schools, homeware retailers, rail travel,
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.
The CMA said that a report by the Department for Business &
Trade found that drip pricing was particularly prevalent regarding
event tickets (with 93% of businesses reviewed engaging in drip
pricing), cinema tickets (69%), and gym membership (60%).
The advisory letters explain how consumer law applies to the businesses' practices, and put the firms on notice that they must review their practices and ensure they are in line with the law in order to avoid the risk of future enforcement action. The recipients of the advisory letters have not been named, consistent with the CMA's standard practice.
5. Consumer law guidance
Finally, the CMA also published its finalised price transparency guidance following a consultation over the summer. The guidance is directed at businesses that advertise, market, sell or otherwise promote products to consumers. It covers what should be included in pricing information provided to customers (including mandatory fees, taxes and charges), as well as the prohibition on 'drip pricing' and 'partitioned pricing' (the practice of providing a breakdown of fees and charges, but not the overall price a customer would pay).
6. Next steps
The CMA's enforcement action and warning letters are focussed on practices that were already unlawful under the Consumer Protection from Unfair Trading Regulations 2008 (i.e., failing to include mandatory charges upfront, introducing unavoidable fees at checkout, and presenting misleading headline prices that exclude compulsory costs). This is consistent with the CMA's earlier statements on its approach to the new consumer enforcement regime, that its early focus regarding new banned practices will be on supporting compliance rather than on enforcement. However, firms should expect this approach to change once the new regime has been in force for longer, and the CMA considers that consumer-facing businesses have had sufficient time to adapt their practices to comply with the new rules.
Updates to the CMA's enforcement cases will be published on the relevant case page on the CMA's website. At this early stage, the CMA has not reached any conclusions about whether the businesses under investigation have broken the law.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
