CMA launches first DMCCA enforcement cases and finalises price transparency guidance

What enforcement action has the CMA taken under the Digital Markets, Competition and Consumers Act (DMCCA), and what are the key updates in its finalised price transparency guidance?

The question

What enforcement action has the CMA taken under the Digital Markets, Competition and Consumers Act (DMCCA), and what are the key updates in its finalised price transparency guidance?

The key takeaway

The CMA has opened its first enforcement cases under the DMCCA, targeting businesses suspected of misleading pricing practices such as drip pricing, hidden fees and misleading countdown timers. Alongside this, the CMA has published its final price transparency guidance, setting clearer expectations on how mandatory charges and time-limited offers must be presented. Businesses should urgently review their pricing practices: non-compliance may now trigger direct fines of up to 10% of global annual turnover.

The background

The DMCCA came into force on 6 April 2025, strengthening the UK’s consumer protection framework and expanding the CMA’s powers. Key changes include:

• modernising the unfair commercial practices rules;
• enabling the CMA to impose direct administrative penalties, rather than pursuing lengthy court action; and
• creating a new enforcement regime capable of issuing fines up to £300,000 or 10% of global turnover.

As part of its implementation work, the CMA reviewed the practices of more than 400 businesses across 19 sectors and identified concerns in 14, including high-risk issues such as drip pricing and artificially urgent countdown timers.

The development

On 18 November 2025, the CMA unveiled a “package of action” comprising both enforcement and updated guidance.

First DMCCA investigations launched

The CMA has opened formal investigations into eight businesses for suspected breaches of consumer protection law:

• StubHub, viagogo, AA Driving School and BSM Driving School - suspected drip pricing, specifically whether mandatory fees were excluded from headline prices;
• Gold’s Gym - whether joining fees were disclosed only late in the sign-up journey rather than in the advertised membership price;
• Wayfair - whether time-limited sales ended when advertised;
• Marks Electrical - whether customers were automatically opted into add-on services; and
• Appliances Direct - suspected misleading time-limited sales and automatic opt-ins for additional services.

These investigations represent the first formal enforcement actions under the DMCCA’s enhanced consumer protection powers.

In parallel, the CMA has issued 100 warning letters to businesses across sectors such as homeware, fashion, and food delivery, raising concerns about additional fees and online sales tactics. The CMA has emphasised that early action will target the most harmful practices, especially failures to disclose mandatory charges.

Finalised DMCCA price transparency guidance

The CMA has also issued its final price transparency guidance, clarifying how businesses must present prices and fees. Key updates include:

• Invitation to purchase - the definition is now broader: an invitation to purchase may arise at much earlier stages than previously understood, including search results and early-stage listings. This means pricing obligations may apply before consumers actively engage with a product page;
• Delivery charges: The guidance clarifies how mandatory, optional and variable fees must be displayed:
• mandatory delivery charges must be included in the total headline price;
• optional charges (e.g. paid delivery where free collection exists) must be presented clearly but may be separate from the headline price;
• where all delivery options are paid, the headline price must include the cheapest available option.
• variable mandatory delivery fees (e.g. location-based) must still be disclosed with sufficient prominence and detail for consumers to calculate the final price themselves.
• Periodic pricing: For subscription and minimum-term contracts:
• businesses may present either the total cumulative cost for the full minimum term or the total cost per period, provided minimum commitment periods and fees are stated prominently;
• any additional mandatory charges must be included in the total cumulative or periodic price;
• presenting monthly prices is still permitted, provided the total payable is clear and transparent.

Why is this important?

The CMA’s actions confirm that price transparency is an immediate enforcement priority. Businesses that have not updated their pricing displays, checkout journeys and promotional practices since April 2025 are exposed to significant regulatory and reputational risk. The finalised guidance sets clear standards for compliance, while the new DMCCA regime gives the CMA powerful tools to impose substantial penalties for misleading pricing practices.

Any practical tips?

Businesses should:

• review all pricing journeys - from search results through to checkout - to ensure mandatory charges are included at the earliest stage;
• avoid drip pricing, hidden fees and late-stage disclosures;
• audit time-limited promotions to ensure they end when advertised and do not create artificial urgency;
• check that optional extras are truly optional, and that no consumers are auto-opted into paid services;
• ensure third-party sellers and marketing intermediaries also comply, as brands remain accountable for pricing information provided on their behalf.

Conducting a proactive compliance review now will reduce the risk of enforcement action as the CMA continues to scale its DMCCA activity across the economy.

Winter 2025