CMA warning on need for transparency of delivery fees: practical steps for online sales

If your business sells goods online to consumers in the UK, you should take note of a recent warning from the Competition and Markets Authority (CMA) on the need for transparency of delivery fees.

On 2 November 2026, the CMA published an open letter reminding online retailers that, where a customer must pay a delivery charge to buy a product, the total price including the minimum mandatory delivery charge must be shown to the customer throughout the sales process. With the Christmas shopping period approaching, the CMA encourages any business which has not already done so to review its website, mobile app and online advertising to ensure that its pricing is clear and complies with the law.

The CMA recognises that many businesses have taken steps to comply with the price transparency requirements of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) since it came into force. However, it is concerned that some businesses remain non-compliant in how they present delivery fees to consumers. Where it sees ongoing non-compliance, the CMA says it may use its enforcement powers.

This article summarises what the CMA’s letter says, what the law requires, and the steps businesses should consider taking now.

Background

The DMCCA’s unfair commercial practices provisions and the CMA’s new direct consumer enforcement regime took effect on 6 April 2025. They give the CMA the power to decide itself whether consumer law has been breached and to impose financial penalties, without court proceedings. On 18 November 2025, the CMA published detailed guidance for businesses on price transparency requirements, in CMA209.

“Drip pricing” is the practice of advertising one price and then charging additional mandatory fees before the consumer can complete the transaction. One form of drip pricing is a delivery charge that the customer cannot avoid, but which is disclosed only later in the purchasing journey. Drip pricing remains a focus of the CMA’s enforcement activity. We wrote about the CMA’s first drip pricing penalty, imposed on the AA in April 2026, here.

The CMA has already enforced the rules on drip pricing against four businesses, imposing fines totalling more than £5.1 million and securing more than £1.35 million in refunds for affected consumers.

What the law requires

Under the DMCCA, where a business gives consumers information about a product and its price in a way that enables them to decide whether to buy it or take another transactional decision, this will generally be an “invitation to purchase”. The pricing information must include unavoidable fees, taxes and charges, including mandatory delivery or collection charges, where these can reasonably be calculated in advance. The total price must be provided at every stage of the purchase process where a price is given, including advertising, product pages, carts and baskets, checkout and payment pages.

In the CMA’s words, “the first price consumers see should be the price they pay”.

The CMA’s letter directs businesses to the CMA209 guidance. Chapter 4 of that guidance explains the core requirements of the DMCCA, and paragraphs 5.2 to 5.21 provide additional guidance on the presentation of delivery fees. The guidance includes examples of approaches that different types of businesses, and businesses with different types of delivery fees, can take to comply with the law.

Specific situations addressed in the letter

Flat delivery charges on a basket

Many e-commerce websites and apps allow customers to buy several products together, and a single delivery charge often applies to the order regardless of how many items are purchased. In those situations, the retailer must still provide the customer with the total price of the products, including any mandatory delivery or collection charges, throughout the shopping process. This does not prevent the retailer from also showing other information, such as a breakdown of how the price is calculated or the cost of the delivery charge included within it. The CMA gives the example of automatically displaying the price for a product both including and excluding delivery. Its guidance also permits retailers to display the base product price and information about the delivery charge alongside a clear and prominent running total for the order, including mandatory charges, which updates as products are added to the basket.

Optional delivery fees

A delivery fee is optional where the customer can obtain the product without paying it, for example by choosing free collection, or where it is a premium service such as next-day delivery. Where a retailer offers optional delivery fees, it must tell customers clearly throughout the process that these fees apply and, where reasonably calculable, their amount. If the amount cannot reasonably be calculated in advance, the retailer must explain that an additional fee may be payable. Customers should not have to search through separate pages, hidden menus or expandable sections to find this information.

Online marketplaces, comparison sites and search engines

The requirement to make complete pricing information available to customers applies not only to shops, but also to online marketplace operators, comparison sites and search engines. Where an online marketplace displays a list of items sold by different traders, each of which can be bought individually and has its own delivery charge, the price of delivery should be included in the total price of each product. Traders may also present other pricing information, such as the base cost excluding delivery, provided that the total price is presented in a clear and timely manner and in a way that the consumer is likely to see.

What the CMA is looking for

The letter lists the following examples of non-compliant practices that the CMA is looking out for:

displaying a product price without including a mandatory delivery charge in the total price;
failing to include applicable mandatory delivery charges within basket totals or order summaries;
failing to provide information about optional delivery fees, or placing that information behind links, separate pages, pop-out pages, expandable sections or drop-down menus; and
failing to provide information about delivery charges until late in the checkout stage.

Enforcement

The CMA states that it will continue to monitor pricing practices across the online retail sector and is committed to taking enforcement action if it appears that non-compliance is continuing. If the CMA finds that the law has been broken, the DMCCA gives it the power to impose substantial penalties, and it may also require redress to be paid to affected consumers. Under the DMCCA, the penalty for an infringement of consumer protection law can be up to £300,000 or 10% of a business’s group-wide global annual turnover, whichever is greater. Infringements also carry reputational risks.

Practical implications for businesses

Online retailers, marketplaces, comparison sites and search engines should review their pricing practices against the DMCCA’s requirements and the CMA209 guidance. Any necessary changes should be made so that consumers receive clear, prominent and timely information about the total price they are likely to pay up front.

In particular, businesses should check that:

any price shown for a product, at every stage from advertising to payment, includes the minimum mandatory delivery charge and any other unavoidable fees, taxes and charges;
basket totals and order summaries include applicable mandatory delivery charges;
where a flat delivery charge applies to a basket, the total price including that charge is shown throughout the shopping process, with any breakdown shown alongside it;
optional delivery fees are clearly disclosed throughout the purchasing process, including their amount where reasonably calculable or, otherwise, the fact that they may be payable. This information should not be hidden behind links, separate pages, pop-out pages, expandable sections or drop-down menus;
where a mandatory delivery charge cannot reasonably be calculated in advance, sufficiently prominent information is provided to enable customers to calculate the total price, and the charge is included in the total as soon as it can reasonably be calculated; and
information about delivery charges is not left until late in the checkout stage.

Businesses operating marketplaces, comparison sites or search engines should also check that the delivery charge of each individually purchasable item is reflected in the total price shown for that item.

The CMA’s enforcement action to date shows that it is prepared to impose financial penalties and require refunds where the drip pricing rules are breached. Businesses which have not yet reviewed how delivery fees are presented across their websites, apps and online advertising should consider doing so now.

Find out more about Blake Morgan’s competition and consumer law expertise, and how we can assist, here.