On 3 July 2025, the Competition and Markets Authority (CMA) launched a public consultation inviting comments from stakeholders on its draft guidance for businesses (CMA209con) (the Draft Guidance) which covers the price transparency provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCCA). This article will look at the reasoning behind the consultation, what is covered within the Draft Guidance and when we might expect to receive final guidance in this area. However before we do, lets first rewind back to how this consultation first came about.

Background to the consultation

The topic of online drip pricing has been a talking point for some time. Back in March 2025, Sarah Cardell (Chief Executive of the CMA) announced that following an earlier consultation run by the CMA, the most substantive feedback received from businesses was in relation to drip pricing. The term describes the practice by businesses whereby consumers are shown an initial headline price for a product and then confronted with additional mandatory charges later on in the checkout journey. Given the increasing levels of dialogue from stakeholders within this area, the CMA announced that they would be taking a considered and phased approach to releasing guidance on the topic.

This consultation forms the final stages of this phased approach. The Draft Guidance aims to supplement the already published CMA guidance (CMA207) back in April 2025 covering the protection from unfair trading provisions in the DMCCA. The guidance on material pricing information that is currently found in Chapter 4 of CMA207 will be replaced with a cross reference to the finalised guidance released following this consultation.

What does the consultation seek to achieve?

The Draft Guidance seeks to provide clarity on the price transparency provisions of the DMCCA. These provisions seek to address longstanding concerns over online drip pricing and partitioned pricing (providing the component parts of a price without giving the overall total price). The DMCCA makes explicit that, when making invitations to purchase  - i.e. any form of marketing material which indicates the characteristics of a product and its price, and therefore enabling a consumer to make a transaction decision -  traders need to inform consumers of the full cost of their products throughout the purchase process, including any mandatory fees, taxes, charges or other payments that the consumer must pay. If, owing to the nature of the product, the total price cannot be calculated in advance, then how the price will be calculated must be shown instead with equal prominence. These changes were brought about to promote price transparency and consumer trust by making it easier for consumers to compare prices and trust the information being presented to them.

What does the Draft Guidance set out?

The Draft Guidance explains:

• What an invitation to purchase is and when the new rules will therefore apply (Chapter 2).
• What pricing information needs to be included in an invitation to purchase and what to avoid (Chapter 3).
• What traders need to do to ensure compliance with the new requirements to provide the total price of the product in their invitations to purchase and the alternative approach if this is not possible (Chapter 4).
• How the new requirements apply to specific types of charges and pricing practices, including the steps that traders can take to ensure compliance (Chapter 5).

Further to this, the Draft Guidance also provides further information covering when charges are mandatory and must be included in the total price. The CMA provides examples throughout the Draft Guidance that cover what lawful practices look like in different contexts.

The deadline for responses to the consultation

The CMA aims to produce finalised guidance in this area in Autumn 2025. In a bid to meet this timeframe, the CMA therefore invites responses from anyone with an interest in the application of the price transparency provisions of the DMCCA before the consultation closes at 11:59pm on 8 September 2025.