Hidden fees and fake reviews: what the CMA's first fine means for small businesses

If you sell anything through a website, a booking form or an ordering app, two rules in consumer law now apply to you directly: show the full price from the start, and keep your reviews honest. Both came in on 6 April 2025 under the Digital Markets, Competition and Consumers Act (the DMCC Act), and in 2026 the Competition and Markets Authority (CMA) showed it is prepared to use its new powers. This post explains what the rules say, what the first fine looked like, and what a small business can check this week.

What drip pricing means

The CMA's unfair commercial practices guidance describes drip pricing as showing consumers an initial headline price and then introducing additional mandatory charges as they move through the purchase. The guidance treats it as leaving out material information from an invitation to purchase.

The test is whether a charge is mandatory. If the customer has to pay it to buy the product, it belongs in the price you show at the start. The guidance says you must show either the total price, including any mandatory fees, taxes, charges or other payments, or, where the total cannot reasonably be worked out in advance because of the nature of the product, the way the total will be calculated so the customer can work it out.

Optional extras are treated differently. The guidance allows optional freight, delivery or postal charges that are not included in the total price to be shown separately, as long as you make clear that they are not included or that they may apply. It also says that limits of time and space will generally be unlikely to justify leaving out required pricing information, so "there was no room on the button" is not a defence.

The first fine: a £3 booking fee

The clearest example is the CMA's first financial penalty under the new regime. According to law firm Blake Morgan's summary, the CMA published the outcome on 15 April 2026 after investigating the AA Driving School and BSM Driving School, both owned by Automobile Association Developments Limited. A mandatory £3 booking fee had not been included in the lesson price shown at the start of online booking and was added later in the checkout.

The result was a £4.2 million fine, reduced by 40% from an initial £7 million because the company settled, and refunds of more than £760,000 to more than 80,000 learner drivers. The CMA's chief executive, Sarah Cardell, is quoted as saying that if a fee is mandatory, it must be included in the price from the very start, not added at checkout.

The lesson for a small business is the size of the gap between the fee and the consequence. A £3 charge sounds trivial. Multiplied across tens of thousands of bookings, it became a seven-figure problem. The same summary says the CMA opened investigations into the online pricing of eight businesses in November 2025, and that the other seven were still pending when it was written.

What the CMA can do

The CMA does not now need to go through the courts to penalise a breach. The guidance footnotes monetary penalties of up to the higher of £300,000 or 10% of worldwide turnover. Local trading standards officers also enforce these rules, and the guidance sets out criminal offences too, including, on conviction on indictment, a fine or imprisonment of up to two years or both. For most small businesses the practical risk is not the maximum but an investigation, a refund order and the damage to customer trust.

The fake reviews rules

The same guidance lists, among the banned practices, submitting a fake consumer review and submitting or publishing a review that hides the fact it was incentivised. Traders must also take reasonable and proportionate steps to prevent fake reviews and incentivised reviews that conceal the incentive from being published, to remove them, and to avoid presenting review information in a misleading way.

The CMA has a separate, longer guide on reviews (CMA208) on GOV.UK. Its page says it covers incentivised reviews, hiding negative reviews, the responsibilities of review platforms and a section for small businesses. If you collect reviews on your own site, or ask customers to leave them on Google or elsewhere, read that guide rather than relying on a summary, including this one.

Some plain-sense implications follow from the rules as written. Do not write reviews for your own business or ask friends to. Do not pay or reward customers for reviews without making the incentive clear. Do not hand your review management to an agency without asking how they get the reviews.

A checklist for this week

• Walk through your own checkout. Start from the first page where a price appears, such as a product page, a quote form or an ordering menu, and write down every charge that appears afterwards.
• Sort each charge into mandatory or optional. If the customer cannot complete the purchase without paying it, it is mandatory and should be in the headline price.
• Fix the display, not just the wording. Booking fees, service fees, admin fees and card fees are common candidates. Move them into the price shown at the start.
• Check variable pricing. If the total genuinely depends on something the customer chooses, such as a size or a number of hours, show how it will be calculated.
• Treat delivery honestly. Optional delivery or postage can be shown separately if you say that it is not included or may apply. Make sure it really is optional, for example collection is available.
• Review your review process. Know where your reviews come from, whether anyone was rewarded, and who on your team or at your agency can publish or remove them.
• Check third-party platforms. If your prices appear on a booking or marketplace page you control, apply the same test there.
• Keep a record. Note the date you checked and what you changed. It is useful if a customer or trading standards ever asks.

Where your website comes in

Many drip pricing problems are built in by the way a checkout was set up, with a fee added by a plugin, a payment add-on or a booking system's default settings, and nobody noticed. If your shop or ordering system adds charges automatically, ask whoever built it exactly where in the journey each one appears. If you need help reviewing or rebuilding a checkout, our ecommerce team can look at it, and our web design work covers how prices and fees are displayed.

What to do if you find a problem

If your audit shows a mandatory fee that is not in the headline price, fix it now rather than waiting. The guidance is about what is shown to customers from when they first see a price, so a change takes effect for future customers straight away. This post is general information, not legal advice. If you are unsure whether a particular charge is mandatory, or you have a more complex pricing model, take advice from a solicitor or your local trading standards service, and read the CMA's guidance in full.