The long-awaited final guidance on price transparency under the UK’s Digital Markets, Competition and Consumers Act 2024 (DMCC) has arrived. Superseding the earlier draft, the final guidance supplements the main Unfair Commercial Practices Guidance.

Following a consultation and much industry speculation, we finally have the definitive text, meaning we can officially retire the phrase “subject to change” from our pricing compliance updates, at least for now.

The guidance reinforces the Competition and Markets Authority’s (CMA) campaign against “drip pricing” and “partitioned pricing”. While these practices were previously governed by the interpretive framework of the Consumer Protection from Unfair Trading Regulations 2008, the DMCC establishes firmer rules and sends an unmistakable message: the full price must be provided upfront.

Getting online pricing right is critical as the CMA intensifies its consumer protection drive. The DMCC introduces direct enforcement powers, including fines of up to 10% of global turnover for the most serious breaches (as detailed in our previous article), creating significant financial risk for non-compliance. The authority is already actively targeting misleading fees, drip pricing, and pressure-selling tactics, having opened investigations into eight companies and commenced reviews of sectors such as ticketing, food delivery, and fashion.

Shared responsibility for compliance

The guidance clarifies that responsibility for a compliant invitation to purchase (ITP) extends beyond the seller to any trader in whose name, or on whose behalf, it is made. This creates shared liability for price comparison sites, influencers, and, crucially, online marketplace operators. In practice, this means both the marketplace and the individual seller can be held responsible for non-compliant listings. Online marketplaces must therefore take proactive due diligence steps; this could include re-architecting platforms to include mandatory fields for sellers to disclose all price components, building user interfaces that automatically display the compliant total price, and updating seller terms to require provision of this information and to secure indemnities for non-compliance.

An important boundary is drawn: traders are not responsible for independent third-party resellers. Beyond this specific carve-out, the compliance net is broad, confirming that any party involved in presenting the price to the consumer may share responsibility for its compliance. However, given the CMA’s objectives in imposing penalties, namely, deterring infringements, incentivising compliance with consumer law, and reflecting the seriousness of breaches, we can expect that enforcement in cases involving multiple traders will follow these principles. In practice, this hopefully means enforcement should remain proportionate: breaches that affect multiple traders or services are likely to be addressed in a way that reflects the relative contribution and responsibility of each party.

STATUS → Clarification. The final guidance provides greater clarity on shared liability but does not change the underlying principle from the draft.
 

A broader concept of an “invitation to purchase"

The CMA also widens the scope of what constitutes an ITP. It is legally defined as a commercial practice that indicates a product’s characteristics and price and enables a consumer to make a transactional decision (Section 230(10) of the DMCC). This widens the net beyond individual product listings to include items in a shopping basket, mobile app banners for in-app purchases, and even search result pages on an online marketplace. For app stores, an app’s main listing page will likely be an ITP if it advertises subscriptions or in-app purchase prices. For all online traders, this means price transparency obligations apply much earlier and across more digital touchpoints in the consumer journey than previously understood.

STATUS → Minor expansion. The final guidance confirms the broad interpretation from the draft and provides further examples, solidifying its wide application.

Overseas traders are still caught

The CMA is unambiguous about the DMCC’s territorial reach. An ITP directed at UK consumers must comply with the DMCC, even if the trader is located overseas. The CMA has express powers to enforce against non-UK traders who carry on business in the UK or target UK consumers. These powers have been tested, with the CMA previously securing undertakings from overseas-based traders, demonstrating its willingness to act globally.

STATUS → Clarification. The final guidance clarifies the position on extraterritorial reach.

No more “limited time and space” excuses

The final guidance closes the door on the justification of limited space or time. Although certain formats like small packaging or brief radio ads have inherent limits, this is not a “get-out-of-jail-free card”. This is particularly true for digital media; character limits on search engine ads or space constraints in social media posts will not justify omitting mandatory charges from a headline price. If any pricing information is provided, the mandatory elements of Section 230 of the DMCC must also be included. When assessing claims of space or time limitations, the CMA will scrutinise a trader’s own choices; optional marketing claims cannot be prioritised over mandatory pricing information.

The total price (or how it will be calculated) is considered especially important under Section 230. Where a price cannot be calculated in advance, Section 230(5)(b) requires that the method of calculation must be given “as much prominence as” the rest of the price. For online traders, this means information about variable elements must be immediately adjacent to, and as visually distinct as, the calculable part of the price, rather than hidden in footnotes or behind hyperlinks.

STATUS → Significant strengthening. While the draft guidance already signalled a narrow interpretation, the final guidance reinforces this position significantly. It explicitly states that the threshold for omitting the total price due to space or time limitations will be high and that mandatory pricing information cannot be sacrificed for optional marketing claims.

Mandatory delivery charges

There is no ambiguity when it comes to mandatory delivery charges: they must be included in the total price. No excuses. Whether the charge is a fixed amount (e.g., £4.99 for delivery) or applied on a per-product basis (e.g., £2 per item), it must be part of the total price presented to the consumer. This even applies to online marketplaces where multiple traders sell items with individual delivery charges. Each trader’s delivery charge must be included in the price shown for their product.

That said, the guidance now allows a bit of wiggle room, letting traders present extra pricing details in the ITPs. But here’s the important part: the total price must still be shown clearly and in a way that catches the consumer’s eye. For example, a trader might show the base price (excluding delivery) upfront, with the total price listed right underneath, or they could break it down step by step. The key takeaway here is that the total price has to be just as prominent, if not more so, than the headline price.

STATUS → New practical concession. This marks a welcome departure from the draft, offering traders more flexibility when displaying mandatory delivery charges. However, the emphasis on clear, upfront pricing remains unchanged.

Order-level charges

While fixed per-item charges must be in that product’s total price, the guidance elaborates on how to handle order-level charges where including them in each item’s headline price would be impractical. It confirms that traders can comply by presenting the total price in another clear and prominent way, for example, by:

• displaying the total price below or alongside a base price, ensuring both are given equivalent prominence;
• presenting the base price and delivery charge, with a clear, real-time rolling total; or
• incorporating the delivery fee into the base price (effectively offering “free delivery”).

If a running total is used, it must be clearly visible to the consumer throughout their shopping journey. This total must include any mandatory order-level delivery fees from the outset. The CMA provides practical examples of compliant user interfaces, such as a “floating basket” that remains on screen, a dynamic “add to basket” button that shows the item’s cost impact on the total, or an automatic basket pop-up after each item is added.

The guidance also warns that offers like “free delivery over £40” do not make the delivery charge non-calculable; the full delivery fee must be included in the total price until the basket reaches the threshold.
 
The key points in the guidance on delivery charges are as follows:

• If multiple paid delivery options exist and no free collection option is available, the cheapest mandatory delivery charge must be included in the total price unless the consumer selects another.
• Optional charges (e.g., paid delivery when free collection is available) must be disclosed but do not need to be in the total price.

STATUS → Clarification. The final guidance reinforces the stance on running totals and offers new, practical examples for better understanding.

Service fees: seller beware

The guidance is stricter on booking and administration fees than on delivery charges because such fees are typically an inherent part of the service’s pricing structure. For online platforms like ticket marketplaces, this means the fee must be included in the headline price from the first ITP. It is not compliant to show a “ticket price” and add a “service fee” later. For transactions involving multiple items, a running total that incorporates these fees from the outset is a compliant way to present the final cost.

STATUS → No change. The final guidance maintains the draft’s strict approach, requiring service fees to be included in the headline price as they are considered standard and unavoidable.

Membership discounts must not obscure the real price

The guidance clarifies that mandatory charges must be included in the price shown to the public, even if a consumer could avoid them by signing up for a membership. While traders can advertise discounts to existing members, the price shown to a general, non-logged-in user must be the standard, non-discounted total price. Any member-specific price should only be displayed once the consumer is identified as eligible (e.g., after logging in), or be clearly presented as a separate benefit of joining the scheme. This aligns with broader subscription rules in the DMCC, which require pre-contract information on minimum total commitments.

STATUS → Clarification. The guidance maintains the draft position that the standard non-member price must be shown to the general public. The final guidance also makes clear that a charge is still mandatory even if consumers could avoid it by taking out an additional product or service.

Periodic contracts must present the total cost meaningfully

For subscriptions and other periodic contracts, traders have some flexibility. For a 12-month membership, for instance, they can show either the total annual or monthly cost, as long as it is fully inclusive of all mandatory charges for that period and clearly indicates the minimum commitment. The new guidance appears to give preferential weight to providing a total cumulative price, i.e., the full amount the customer will be required to pay over the minimum contract term, including all mandatory charges. It notes that traders who provide this total cumulative price “can be confident they comply with total price requirements” under the DMCC, regardless of the payment structure used. Traders may still offer additional information, such as a breakdown of monthly payments.

Traders will in any case be required to disclose both the cumulative price and the monthly breakdown at some point in the purchase flow to meet the DMCC’s new subscription rules, coming into force in 2026. As a result, many businesses may choose to adopt this approach from the outset for most ITPs relating to periodic products or services.

What is very clear is that traders cannot separate out costs in a way that requires consumers to perform calculations to understand the total commitment.

STATUS → Clarification and evolution. While the draft outlined options for presenting periodic pricing, the final guidance evolves this position by introducing a “safe harbour”. It explicitly states that showing the total cumulative price is a surefire way to comply, giving traders a clear and risk-free path, which represents a significant evolution from the draft’s more neutral stance.

Payment arrangements remain unaffected

Finally, the CMA confirms that the transparency rules do not restrict how traders collect payments or structure instalments. Businesses can continue using their preferred payment models, provided the pricing information is transparent and compliant.

STATUS → Clarification. The final guidance confirms that price transparency rules do not regulate payment mechanics.