UK consumer law compliance guide - pricing practices
24 February 2026
This page provides a concise overview of how to ensure your pricing complies with the UK Digital Markets, Competition and Consumers Act (DMCC Act) and the Competition and Markets Authority's (CMA) current expectations. The individual guides provide practical guidance on specific pricing practices to help you assess risk and implement compliant pricing strategies.
What you need to know
- The consumer protection parts of the DMCC Act entered into force on 6 April 2025 and empowers the CMA to enforce consumer law directly through administrative proceedings, aligning its consumer and competition enforcement toolkits (see our April 2025 update).
- The CMA opened its first consumer enforcement investigations on 18 November 2025 (see our November 2025 update) and has published new or updated guidance guidance on businesses' consumer protection obligations, including in respect of pricing.
- Pricing practices are an enforcement priority in the UK. Businesses should therefore ensure their pricing design, presentation and governance meet legal requirements.
- Our pricing practices guidance notes summarise key obligations and provide practical steps for common pricing scenarios.
Pricing practices guidance
Open each PDF guide in the drop-downs below for information on the obligations, risk factors, and practical compliance tips for the following pricing practices: (i) drip pricing and pricing transparency, (ii) reference pricing, (iii) loyalty pricing, (iv) dynamic pricing and (v) unit pricing.
Drip pricing involves showing customers an initial price for a product which is not a total or final price because, for example, additional charges are introduced as the consumer proceeds with the purchase.
Drip pricing is prohibited under UK consumer law. Traders must provide the required information clearly, in a timely way, and in a way that the consumer is likely to see it.
Download Consumer Law Pricing Series: Drip Pricing - PDF 177 KB
Reference pricing is when businesses use price promotions that compare the current price to another price (for example, comparisons to RRPs, competitors' prices, or previous prices ("was / now" prices)).
It is important that any claimed price advantage is genuine and not misleading or unfair.
Download Consumer Law Pricing Series: Reference Pricing and discounted offers - 206 KB
Loyalty pricing refers to promotions that provide consumers who have signed up to a loyalty scheme with a discounted or preferential price on selected products. In effect, this is a form of reference pricing so any comparison between a non-loyalty price and a discounted loyalty price must reflect a genuine price advantage.
Consumer Law Pricing Series: Loyalty Pricing
Download PDF Consumer Law Pricing Series: Loyalty Pricing - PDF 166 KB
Dynamic pricing involves adjusting prices (upwards or downwards) rapidly and frequently in response to changing demand conditions. It typically relies on the use of algorithms or machine learning tools.
While dynamic pricing is not in itself prohibited under UK consumer law, regulators are more likely to have concerns when consumers do not know that dynamic pricing is being used or they feel pressured to make quick decisions because prices may rise suddenly.
Download Consumer Law Pricing Series: Dynamic Pricing - PDF 108 KB
Unit pricing is a labelling system for displaying the cost of different products by reference to standard units of weight or volume.
Traders are required to provide the unit price of goods (e.g. price per kilogram in GBP) on price labels for goods sold in the UK.
Download Consumer Law Pricing Series: Unit Pricing - PDF 184 KB
Why compliance matters
The CMA’s direct enforcement powers include the ability to:
- impose penalties on companies (up to the higher of 10% of global turnover or £300,000) and on individuals (up to £300,000);
- issue infringement notices setting out alleged contraventions; and
- impose directions requiring businesses to cease infringing conduct and/or provide compensation or redress to consumers. Failure to comply with directions or undertakings can trigger separate penalties. The CMA may also seek court orders and, for certain breaches, pursue criminal proceedings.
Public enforcement can cause significant reputational harm and erosion of consumer trust.
Pricing practices are subject to heightened regulatory scrutiny in the UK, with the CMA issuing guidance, conducting reviews, launching investigations, and sending advisory letters.
For tailored advice on pricing design, governance and compliance under the DMCC Act, please contact our Consumer and Antitrust, Regulatory and Trade team.
