New CMA Draft Guidance on Price Transparency: What Businesses Need to Know

Invitations to Purchase (ITP)

On 3 July 2025, the CMA started a consultation on the guidance to help businesses comply with the price transparency provisions of the DMCCA in the context of ITP.

Under section 230 of the DMCCA, an ITP is defined as: ‘a commercial practice involving the provision of information to a consumer which indicates the characteristics of a product and its price, or which enables, or purports to enable, the consumer to decide whether to purchase the product or take another transactional decision in relation to the product’.

This could therefore include:

• price labels on a product in a shop;
• an online marketplace listing;
• a restaurant menu (physical or digital);
• a TV or social media advert; or
• a promotional text message.

The CMA guidance sets out that consumers must be able to calculate the final price at an early point in their purchase journey and it is therefore essential for businesses to provide clear and accurate pricing information in relation to their products.

When businesses leave out essential pricing information it can make products appear cheaper, undermining a consumer’s trust when they find out the total price.

The CMA guidance also considers other areas, such as:

• Drip Pcicing: this is when a product is advertised with a low ‘headline’ price, with additional mandatory charges introduced later. This is now prohibited under the unfair commercial practice provisions in the DMCCA; and
• Partitioned Pricing: this is where consumers are provided with a breakdown of fees and charges but not the overall total price. Again, this is prohibited under the unfair commercial practice provisions in the DMCCA, unless the pricing cannot reasonably be calculated in advance.