UK law and a CMA decision, read at the source
What is drip pricing? The UK rule, and the gym fined £45,000 for it
Drip pricing is showing customers one price and adding fees they can’t avoid later in the purchase. In the UK it has been illegal since 6 April 2025: a price you show a consumer must already include every fee, tax and charge they will have to pay. On 14 October 2026 the Competition and Markets Authority (CMA) fined three businesses £6 million for misleading sales tactics. The smallest of the three fines is the one to read if you run a small business: a franchise that runs four gyms in London, fined £45,000 for leaving its joining fee out of its advertised prices. We read the CMA’s full decision. The joining fees it had taken that way came to £9,220.
The short version
- Drip pricing is a headline price followed by unavoidable extras: booking fees, admin fees, joining fees, VAT, compulsory delivery.
- It’s illegal for prices aimed at consumers, under section 230 of the Digital Markets, Competition and Consumers Act 2024, in force since 6 April 2025. The CMA can fine up to 10% of global turnover, or £300,000 if that is higher.
- The rule: the first price a customer sees must be the total they will pay, shown clearly, where they’ll see it. That covers adverts, social posts and your home page, not just the checkout.
- Optional extras are different. They can sit outside the total, but they must be shown, and a paid extra can’t be ticked in advance.
- Monthly memberships with a joining fee: show the total for the whole minimum term, or the monthly price with the number of months and a first month that includes the fee.
- The gym: £9,220 of joining fees, a penalty worked out at £75,000 and cut to £45,000 for settling, and every fee refunded. The CMA had written to it twice before.
- Check your own prices with the CMA’s free 3 Step Pricing Check.
What is drip pricing?
The CMA’s summary of its pricing guidance puts it in one sentence: "It’s illegal to hide additional fees, taxes or other charges that the customer will have to pay until later in the purchase process (sometimes called ‘drip pricing’)." Its decision on the gym names a close relative too: showing a fee separately from the rest of the price, "a practice known as ‘price partitioning’". Both break the same rule.
The rule is section 230 of the Digital Markets, Competition and Consumers Act 2024. When you show a consumer a product and its price, you must give them "the total price of the product", and the Act says that total "includes any fees, taxes, charges or other payments that the consumer will necessarily incur if the consumer purchases the product". Mentioning a fee somewhere isn’t enough: the section counts information given "in a way that is unclear or untimely" or "in such a way that the consumer is unlikely to see it" as left out. Section 230 came into force on 6 April 2025.
It applies wherever you show a product with its price, which the law calls an "invitation to purchase". The CMA’s examples include a price on a product in a shop, an advert, an email or social media post, and a page on your website, and it adds: "An invitation to purchase does not need to include an opportunity for the customer actually to buy the product." A price in an Instagram post counts as much as the price at your checkout.
The CMA’s 3 Step Pricing Check gives the simplest example. Joe sees a gig advertised at "£20 per ticket" and finds a £5 booking fee at the checkout. The CMA’s fix is to advertise "From £25 (£20 per ticket plus a £5 booking fee per order)". The breakdown can stay. The total has to come first.
The three businesses fined on 14 October
The CMA’s announcement named three businesses. Only one of them was fined for drip pricing.
| Business | What the CMA found | Fine | Refunds |
|---|---|---|---|
| Wayfair | "Daily Deals" and 24-hour "Flash Deals" with countdown timers, where "many products remained available at the same price or lower after the stated deadline" | £4.8 million | None in the announcement |
| Appliances Direct | Customers automatically opted in to paid extras (taking away and recycling the old appliance, and installation on delivery), and pop-up countdown banners for discounts where "the same discount codes appeared repeatedly over many days" | £1.2 million | About £432,000, on average £25 per customer |
| Gold’s Gym | Left the joining fee out of the total price shown for its annual and Direct Debit memberships, or showed the total in a way that was unclear and unlikely to be seen | £45,000 | £9,220 to 726 customers, either £50 or £10 each |
All three "admitted to breaking the law" and settled early, which took 40% off each fine. The business fined is Gold’s Gym (UK) Limited, which the CMA describes as "a UK franchise that operates 4 gyms in London", operating "independently and autonomously from Gold’s Gym International".
The other two broke different rules, and both are worth knowing. Wayfair’s offers fall under a list of practices the Act bans outright, which includes "Falsely stating that a product will only be available for a limited time, or that it will only be available on particular terms for a limited time, in order to elicit an immediate decision and deprive consumers of sufficient opportunity or time to make an informed choice." The same list bans fake reviews, which we covered in can you remove a Google review? Appliances Direct’s pre-ticked extras break an older rule, regulation 40 of the Consumer Contracts Regulations 2013, which says there is no express consent "if consent is inferred from the consumer not changing a default option (such as a pre-ticked box on a website)", and that money taken without it must be repaid.
Inside the gym case: what the £45,000 was for
With the announcement, the CMA published its Final Infringement Notice on the gym: 64 pages, covering 6 April 2025 to 7 May 2026, with screenshots of the sign-up pages and the arithmetic behind the fine. Here is what it says, in the CMA’s figures.
The prices. On the annual membership, the CMA’s example shows £359.88 on the first three steps of signing up. The £50 joining fee was shown separately on one of them, and the total, £409.88, first appeared on the payment page. The monthly membership was advertised at £29.99 a month for a minimum of 12 Direct Debits, with a £10 joining fee kept apart from the monthly price, and no total that included the fee until the third step.
People typed in their details first. The CMA noted that customers weren’t shown a clear total until after they had entered personal details, "including, in some cases, health information".
A new website undid a fix. By 28 November 2025, eleven days after the investigation opened, every step of the annual-membership sign-up showed the total with the fee in it. Then a new website went live, on 7 January 2026. On it, the total with the fee was there from the first step that showed a price, but "not displayed sufficiently prominently and was unclear and/or unlikely to be seen by consumers" until the third. On the new site’s monthly memberships (£34.99 a month with a £10 joining fee), none of the three steps the CMA examined gave a total that included the fee.
The booking software. The gym told the CMA that one gap, a "Total Due Now" line that didn’t include the joining fee, "arose due to an error by third party booking website provider". The fine was still the gym’s.
The letters. The CMA wrote to the gym on 28 November 2025 and again on 8 April 2026, pointing it to the pricing guidance and encouraging it to review how it showed its Direct Debit memberships. Its verdict: "These letters were not adequately acted upon." That, together with guidance published before the rules began, is why it rated the gym’s culpability "high".
The arithmetic. The CMA sets its starting point as a share of turnover, here the turnover of the gym’s parent company, then adjusts it.
| Step | Amount |
|---|---|
| Starting point: 7.5% of the parent company’s UK turnover (£7,688,529, for the year to 31 March 2024) | £576,640 |
| Cut to keep the penalty proportionate | £75,000 |
| Less 40% for admitting it and settling | £45,000 fine |
| Plus a refund of every joining fee taken (49 annual members at £50, 677 monthly members at £10) | £9,220 |
The CMA cut the starting point because, at over £576,000, it was "significantly greater than any likely gains". But it stopped at £75,000, the bottom of the range it was using ("£75,000 or 7.5% (whichever is higher)"), and said those minimums exist so that penalties deter "even for smaller businesses". So the gym pays £54,220 over £9,220 of joining fees. The fine alone is nearly five times what the fees brought in.
How to check your own prices
The CMA’s 3 Step Pricing Check is one page, written for small businesses, and it starts: "The first price customers see should be the price they pay." Its three questions:
- "Do you show the total price up front?" Everywhere you show a price: adverts, emails, social posts, every page of your website.
- "Do you include all mandatory charges?" The CMA names delivery or booking fees and VAT. On VAT it is blunt: "Always include them in the price if marketing to customers – even if you use the same ads for trade customers." Its example is Helen, who quotes £280 of work at a total of £336 that "includes VAT (£56)".
- "If you can’t give the total price, is it clear how customers can work it out?" Its example is Tom, a carpenter, whose website shows made-to-measure flooring from £25 per square metre, with his £200 fitting fee directly below. Whatever the customer needs to work out the total has to be as prominent as the part of the price you do know.
The page adds that passing "isn’t a formal accreditation". Then check the charges that catch people out:
- Joining or set-up fees on a membership. The CMA’s own example: "a gym could offer a membership as £70 per month for 12 months, plus a £30 joining fee (‘total annual membership: £870’)". Its full guidance allows one other way for a minimum term: the monthly price with the number of months, with any one-off fee at the start included in a total for the first month. If customers can cancel any time, show what they pay each month, including any mandatory charges.
- Booking, admin and per-order fees. They go in the headline price: "Include mandatory per-transaction charges in the total price of the product, even in early-stage advertising." That includes "from" prices.
- Delivery. Compulsory delivery goes into the total wherever you can work it out. "Optional delivery charges (for example, next-day delivery) must also be included in the invitation to purchase, but they do not have to be part of the total cost".
- Optional extras. Let the customer choose them. A box ticked in advance isn’t consent, and money taken that way has to go back.
- Countdowns and “today only”. Use them only if the offer really ends when you say it does.
- Every step, not just the checkout. The gym’s problems started on its home page. For the annual membership, the payment page itself showed the right total; the steps before it didn’t.
What argues the other way
- Selling only to businesses. These rules protect consumers, which the Act defines as "an individual acting for purposes that are wholly or mainly outside the individual’s business". A price list only for trade customers falls outside them. But if the same advert reaches the public, the CMA says to include VAT anyway.
- Not every price can be worked out in advance. For made-to-measure work or a job priced by the hour, the law asks you to say how the price will be calculated, as prominently as the part you can state. A "from" price is allowed too, as long as it includes every mandatory charge and doesn’t mislead about what it covers.
- You can show other prices as well. The CMA’s summary says you can also show, for example, the price without delivery, as long as the total is clear, timely and likely to be seen.
- The early fines are small, and may not stay small. The CMA says penalties are likely to be lower while the regime is new, because it can only fine for conduct after the rules began, and that "the same proportionality considerations may not all apply in future cases". The ceiling is "up to 10% of its global turnover (or £300,000 where this is higher than the 10% figure)".
- These were settlements. Each business admitted breaking the law in exchange for 40% off. The gym also agreed not to appeal, so its case won’t be tested on appeal.
- We have an interest. Lola Squared builds websites and apps, including booking and sign-up pages, so a post telling you to check yours suits us. The CMA’s check is free and takes a few minutes. Do it yourself first.
Sources, and what we checked
- CMA: CMA fines firms £6 million for misleading sales tactics (press release, 14 October 2026), the Gold’s Gym case page and its Final Infringement Notice (dated 29 September 2026, published 14 October 2026), from which every figure about the gym is taken.
- CMA: 3 Step Pricing Check (a campaign page with no published date), Providing clear and accurate information about prices: summary (7 January 2026) and the full guidance, Price transparency (CMA209) (18 November 2025).
- Law: section 230, section 225 and Schedule 20 of the Digital Markets, Competition and Consumers Act 2024, and regulation 40 of the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, read from legislation.gov.uk’s XML text.
- Every page above was read on 14 October 2026 and again on 16 October 2026, the morning we published. The announcement, the case pages, the 3 Step Pricing Check and the Act were fetched twice on 14 October, and the two copies matched. On 16 October the text of every page was unchanged, and the gym’s notice and the full guidance were the same files.
- Our own arithmetic: the £54,220 total, "nearly five times" (£45,000 against £9,220) and the 49 and 677 split, which we checked against the notice’s own figures (£2,450 and £6,770 of joining fees).
- Every quotation above was tested automatically against the text of its source before publication.