The Competition and Markets Authority (CMA) is currently consulting on new draft guidance for businesses on price transparency requirements under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).
The aim is to help traders comply with the law by changing how prices are presented to consumers - ensuring clarity, fairness, and transparency, which will, in turn, increase consumer trust and confidence in the markets.
Our Commercial Lawyers explain everything you need to know about the consultation.
The Draft Guidance
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.
What This Means for Your Business
There are certain steps you will need to take as a trader, following the guidance.
For example, you will need to ensure that you are no longer using practices like drip pricing and partitioned pricing. You will also need to consider how you are presenting any additional charges, for exampl,e delivery charges.
The draft guidance recommends using a persistent ‘floating’ shopping basket, so that customers can easily view and update their cart while browsing the website.
It is important that businesses start to consider these new processes and systems so that the necessary changes can be made. Conversations with systems providers and marketing teams should be organised in order to properly understand the costs involved and expected timelines for implementing these.
The DMCCA now provides the CMA with enforcement powers such as the ability to issue fines.
This means that they will be able to decide whether consumer protection laws have been breached without needing to take businesses to court.
It is expected that they will focus their early action on banned practices, so it is crucial that businesses make any necessary changes in order to avoid breaching the new price transparency rules.
Opportunities to Consult with the CMA
During the consultation period, the CMA is inviting comments on the draft guidance from businesses and other stakeholders, as well as engaging with industry bodies and trade associations through roundtables, webinars, and online events.
Feedback will influence the final guidance, so if you are a business which has any concerns with the draft guidance, you should submit a written response. The final guidance is likely to arrive in Autumn 2025.
Contact Our Commercial Team
If you would like to discuss the consultation in more detail or how this may affect your business, please do get in touch with our Commercial Solicitors, who would be happy to assist.
0161 941 4000
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