Does the price change at checkout? What the CMA’s latest drip pricing investigations mean for businesses 

The Competition and Markets Authority (CMA) has opened investigations into Trainline, Virgin Atlantic and RED Driving School over concerns about how mandatory fees are presented to customers. 

If your business adds booking fees, delivery costs, taxes or other unavoidable charges during the buying process, the investigations underline the importance of checking whether customers are being shown the total price early enough in the journey. 

What's happening?

On 19 August 2026, the CMA announced it would be investigating three business on consumer protection issues: 

• Trainline, over whether mandatory fees were included in upfront prices for advance train and coach tickets 

• Virgin Atlantic, over whether mandatory resort fees and local taxes were included in upfront prices for package holidays 

• RED Driving School, over how mandatory booking and digital fees were displayed when customers booked lessons 

The investigations are at an early stage, and no finding has been made that any of the businesses has broken consumer law. 

However, they form part of a wider CMA focus on online pricing. In 2026, the regulator fined the AA £4.2 million after finding that AA Driving School and BSM Driving School had added a mandatory £3 booking fee too late in the purchasing process. 

What do the rules?

Under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), businesses must generally show customers the total price when advertising a product or service, including fees, taxes and other charges the customer must pay to buy it. 

Importantly, this requirement can apply well before checkout. An “invitation to purchase” could include a product page, online advert, marketing email or social media post. 

If a customer has to pay a charge to complete the purchase, businesses shouldn’t assume they can advertise a lower headline price and add the unavoidable cost later. 

Mandatory costs might include booking or administration fees, unavoidable delivery charges, service or platform fees, applicable taxes and other charges the customer must pay to complete the purchase. 

Optional extras are different: if customers can genuinely choose whether to buy an additional product or service, its cost can usually be shown separately. Businesses should still make sure customers actively consent to paid extras rather than automatically adding or pre-selecting them. 

What if the total price can't be calculated upfront?

Sometimes the exact total won’t be known when the customer first sees a price. 

Delivery costs might depend on location, for example, while a service may depend on measurements, quantities or other information the customer hasn’t yet provided. 

If a mandatory charge genuinely can’t be calculated in advance, businesses should clearly explain how it will be calculated, so customers can understand what they may need to pay. The CMA says this information should be displayed as prominently as the headline price. 

Using a “from” price doesn’t remove this requirement – any mandatory costs that can already be calculated should still be reflected in the price shown. 

What should businesses check?

Businesses should look at the complete customer journey; from the first advert or price a customer sees through to payment. 

Relevant touchpoints include paid advertising, landing pages, product listings, pricing calculators, promotional emails, booking platforms and checkout pages. 

A practical review should cover: 

• identifying every mandatory fee, tax or charge associated with products or services 

• checking whether those costs are included when a price is first presented 

• reviewing “from” prices, introductory offers and promotional campaigns 

• making sure optional charges are genuinely optional 

• checking mobile and desktop buying journeys 

• reviewing charges applied through third-party platforms or technology 

• checking that marketing, ecommerce, sales and legal teams take a consistent approach to pricing. 

The CMA can impose fines of up to 10% of global turnover or £300,000, whichever is greater, if it finds a business has broken consumer law. 

Reviewing the customer journey now can help businesses spot pricing issues early and make sure the price customers see is clear throughout the buying process. Our commercial solicitors can review your pricing practices and customer journey and advise on any changes needed.