Pricing and promotions under the DMCC Act

Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCC) has reshaped how UK businesses must present prices and promotions to consumers.

With the Competition and Markets Authority (CMA) now wielding enforcement powers including fines of the higher of £300,000 or 10% of global turnover, pricing transparency is essential.

This article explores the key changes in pricing transparency and compliance, offering practical guidance on how your business can adapt to meet the new regulations and protect its reputation.

The drip-pricing ban: what must be in your headline price

The DMCC introduces a blanket ban on ‘drip-pricing’ – the practice of showing a headline price upfront and adding mandatory charges later in the purchasing journey. Your total price must include all mandatory charges that apply (for example, compulsory booking fees), so there are no surprises at checkout.

The CMA has narrowed the exceptions. You can’t argue that a fee “can’t be calculated” simply because it applies per transaction or across multiple products. If part of the fee genuinely varies, you must explain how it will be calculated with equal prominence to the headline price.

Legal teams should review how prices are displayed to confirm compliance, while marketing teams must ensure that promotional material reflects the true cost. This clarity builds trust and helps avoid margin leakage caused by retrospective fee adjustments or customer complaints.

How to present mandatory charges

The CMA explains that a charge is mandatory if it’s unavoidable in order for the customer to buy, receive or use the product. The guidance clarifies what is considered a mandatory charge versus an optional one. This tightens the definition, as a charge is still mandatory even if a consumer could, in theory, avoid it by buying something else, signing up for an additional product or paying for a membership.

The CMA’s example: if your café charges for disposable cups but offers a discount for reusable cups, the disposable cup charge is the baseline – you can’t disguise it as an optional add-on.

Delivery charges have been restructured with specific sections relating to:

• Mandatory delivery charges – these must be included in your total price
• Optional delivery charges – there is some flexibility here, as these charges can be presented separately if they are genuinely optional
• Variable mandatory delivery charges – there is general guidance on handling multiple delivery zones, but where a minimum delivery charge always applies (for example, standard postage), this must be included in the total price.

‘Was/now’ claims: substantiating price reductions

‘Was/now’ pricing remains a common promotional tactic, but under the DMCC Act, these claims must be substantiated. The ‘was’ price should reflect a genuine selling price for a reasonable period prior to the promotion. For example, you shouldn’t advertise a weekend break using cheaper midweek prices. Accurate substantiation is essential to avoid regulatory action and reputational harm.

Review claims in marketing

The DMCC bans submitting, commissioning or facilitating fake reviews, concealing incentivised reviews and publishing consumer reviews without taking reasonable steps to identify and remove fake ones.

While the CMA allowed an initial three-month grace period, businesses must now implement robust procedures to police review authenticity. Regular monitoring and prompt removal of fake or misleading reviews are essential for compliance.

Key takeaways for legal and marketing teams

Businesses should look to foster collaboration across legal and marketing functions for ongoing compliance.

Conclusion

The DMCC Act 2024 sets a new standard for pricing and promotional practices in the UK. By prioritising transparency and clear communication, businesses can minimise regulatory risk, protect margins and build consumer trust.

Legal and marketing teams must review current practices, implement robust compliance processes and ensure that all pricing and promotional activity meets the Act’s requirements to be successful in the evolving digital markets landscape.