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CMA cracks down on 'drip pricing': a lesson on transparency for businesses with add‑on fees

The Competition and Markets Authority (CMA) has delivered a clear message that pricing transparency is no longer a ‘nice to have’: it is being actively enforced, with real financial consequences.

In a landmark decision, the CMA has ordered AA Driving School and BSM Driving School (both owned by Automobile Association Developments Limited - the AA) to refund more than 80,000 learner drivers and imposed a £4.2 million civil penalty for illegal ‘drip pricing’ practices. This is the first time the CMA has used its new consumer enforcement powers under the Digital Markets, Competition and Consumers Act 2024 to impose financial penalties, and it sets the tone for how aggressively those powers will now be deployed.

What prompted the investigation?

The CMA investigated the online booking journeys used by AA Driving School and BSM Driving School between April and December 2025. The issue was not the amount charged, but how it was presented. While lesson packages were advertised at an upfront price, a mandatory £3 booking fee was only revealed later in the checkout process, after customers had entered their details. The practice of advertising a headline price and then adding unavoidable charges further down the funnel is known as drip pricing. Under UK consumer law, where a fee is unavoidable, it must be included in the price shown from the very start of the customer journey.

The CMA's findings and enforcement action

The CMA concluded that:

  • more than 80,000 learners were misled because they were not shown the total price upfront.
  • the booking fee was mandatory, not optional, and therefore should have been included in the initial advertised price.
  • this constituted a breach of consumer protection law, regardless of whether the fee was mentioned later in the process

The outcome has been costly. The AA has been ordered to pay £760,000+ in refunds, averaging around £9 per customer. The CMA has also imposed a £4.2 million penalty, reduced by 50% because the AA admitted the breach and settled early.

For chief finance officers, this is a reminder that consumer law risk is a genuine balance‑sheet risk. The AA’s early admission cut the fine almost in half. That discount may not be available where a business contests the facts or delays corrective action. 

For marketing directors, it underscores that conversion‑optimised pricing journeys are under regulatory scrutiny. Pricing design is no longer just a marketing issue. Penalties, refunds and remediation programmes land firmly with finance – often long after the campaign has ended.

Key themes for all businesses using add-on pricing

This decision goes far beyond driving lessons. The CMA has been explicit that it is targeting illegal online pricing practices across the economy. The themes to take away are highly relevant to any business that:

  • builds pricing from a menu of options;
  • applies administrative, booking, processing or onboarding fees; or
  • uses online sign‑up or checkout journeys where pricing changes during that process

If the customer cannot avoid the charge, it must be included in the first price they see. Calling it ‘small’, ‘standard’ or ‘administrative’ makes no difference in law. Highlighting fees on a separate page, in FAQs, or just before payment does not fix the problem. The CMA is focused on what the customer sees at the price comparison stage.

Next steps and action points

With the CMA now armed with stronger enforcement tools, this case is unlikely to be the last. Businesses should treat it as a prompt to review pricing architecture end‑to‑end, not just headline claims. To support its work, the CMA has launched a Clear Pricing campaign, which provides businesses with a practical 3-step checklist to make sure their prices are clear and upfront – as well as detailed guidance to help companies stay on the right side of the law.  
 
If your commercial model relies on layered pricing, optional extras or onboarding fees, now is the time for marketing, finance and legal teams to stress‑test whether customers truly see the total price upfront. The CMA has made clear that getting this wrong will be expensive.

For further information or advice, please contact me.
Sarah Cardell, Chief Executive of the CMA, said: If a fee is mandatory, the law is clear: it must be included in the price from the very start – not added at checkout – so consumers always know what they need to pay. At a time when people are watching every pound, dripped fees can tip the balance. And when it comes to something as important – and costly – as learning to drive, people deserve clarity. With our new powers, it will never pay to break the law or treat consumers unfairly. Where the rules are ignored, we’ll step in to put things right.

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consumer rights, competition and markets authority, booking fees, additional fees, drip pricing, terms of business, commercial contracts, regulation compliance, charities, education, health and social care, housing, local government, social business