On 2 November 2026, the Competition and Markets Authority (CMA) published an open letter to online retailers about delivery fees. With the Christmas shopping period approaching, the CMA reminded businesses that the prices they show UK consumers must include any mandatory delivery charge, and that the full price must be clear from the start rather than revealed at checkout.
The letter is addressed to online retailers, and also to online marketplaces, comparison sites and search engines that display prices from multiple traders. It does not introduce new rules. It restates the price transparency requirements of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) and points businesses to the CMA's price transparency guidance (CMA209, published in November 2025). The CMA acknowledges that many businesses have already made changes, but says some are still presenting delivery charges in ways that do not comply.
Key points
- Where a price is given to a UK consumer, it must be the total price, including all unavoidable fees, taxes and charges.
- A mandatory delivery or collection charge is part of the total price and must be included at every stage where a price appears: adverts, product pages, baskets, checkout and payment pages.
- Where delivery charges are optional, consumers must be told clearly throughout that they may apply; that information must not be hidden behind links, pop-outs or drop-downs.
- The CMA can now enforce consumer law directly and has already fined four businesses a total of more than £5.1 million under the drip pricing rules, securing more than £1.35 million in refunds.
What the law requires
Under the DMCCA, when a business gives a consumer enough information about a product and its price to make a purchase, the price shown must be the total price. That total must include any fees, taxes or charges the consumer cannot avoid paying. This is aimed at "drip pricing", where a lower headline price is shown first and unavoidable extras are added later in the buying process.
For delivery, the position the CMA sets out is straightforward:
- Mandatory delivery fees are charges the consumer must pay in order to buy the product. They must be included in the total price shown, from the first price the consumer sees through to payment.
- Optional delivery fees do not have to be included in the headline price, but the business must make clear throughout the buying process that delivery charges may apply. If the amount cannot reasonably be calculated in advance, the consumer must be told that an additional charge may be payable.
The total price must appear wherever a price is given, including online advertising, product listings, baskets, order summaries, checkout and payment pages. Information about optional charges must be clear, prominent and timely; it should not sit in a separate page, a hidden menu or an expandable section that consumers may never open.
Practices the CMA is looking out for
The letter lists presentation practices that the CMA considers non-compliant:
| Practice | Why it is a problem |
|---|---|
| Product prices shown without a mandatory delivery charge | The headline price is not the total price |
| Basket totals or order summaries that leave out mandatory delivery | The consumer is not shown the total at a key decision point |
| Optional delivery information hidden behind links, pop-outs or drop-downs | Information that must be clear and prominent is effectively buried |
| Delivery charges revealed only late in checkout | The full cost appears too late for an informed decision |
Examples from the letter
A single delivery charge for the whole basket
Some retailers charge one delivery fee per order regardless of how many items are bought, for example a clothing retailer charging a flat fee per basket. The CMA's position is that the total price must still be shown throughout. Retailers can additionally show a breakdown, or display prices both including and excluding delivery, provided the total price is clear.
Marketplaces and comparison sites
Where a marketplace or comparison site shows products from different traders, each with its own delivery charge, the total price for each product should include that trader's delivery charge. A base price excluding delivery can also be shown, provided the total price is clear and given in good time.
What this means for different businesses
- Online retailers should check every place a price appears, not just the product page. Shopping adverts, product feeds, social media promotions, emails, apps and order confirmation pages are all part of the picture.
- Marketplaces and comparison sites need to make sure that prices drawn from third-party traders are displayed with the relevant delivery charges included, which may require changes to how seller data is collected and displayed.
- Overseas sellers should not assume the rules stop at the border. UK consumer law can apply to businesses outside the UK that sell to or target UK consumers, including exporters and e-commerce sellers based in Türkiye or elsewhere. Whether it applies to a particular business depends on how and to whom it sells.
A practical review checklist
The CMA asks businesses to review their pricing practices against the DMCCA and the CMA209 guidance, in particular Chapter 4 on the core requirements and paragraphs 5.2 to 5.21 on delivery fees. In practice, that review may include the following steps.
- List every price touchpoint. Include adverts, price comparison and shopping feeds, product and category pages, apps, baskets, order summaries, checkout and payment pages, and promotional emails.
- Classify each delivery charge. Decide, for each product and delivery route, whether delivery is mandatory or genuinely optional, and record the reasoning.
- Check the totals. Where delivery is mandatory, confirm that the total price, including delivery, is shown at every touchpoint, not only at checkout.
- Surface optional charges. Where delivery is optional, make sure the consumer is told clearly and prominently that charges may apply, without relying on links, pop-outs or drop-downs.
- Test the journey. Go through the purchase process on desktop and mobile, as a new and as a returning customer, and with different basket contents and delivery addresses.
- Check what third parties display. Review how marketplaces, affiliates, comparison sites and advertising platforms show your prices, and how your own platform shows other traders' prices.
- Review automated tools. Where prices, adverts or product descriptions are generated or managed automatically, including by AI tools, make sure the output meets the same requirements. Our article on AI agents and UK consumer law covers the CMA's expectations for AI-driven marketing.
- Keep records. Document the review, the changes made and the dates, so the business can show how it approached compliance.
Enforcement
Since April 2025, the DMCCA has allowed the CMA to decide for itself whether consumer law has been broken and to impose penalties directly, without going to court. Penalties can be substantial, reaching up to 10% of a business's worldwide turnover, and the CMA can require businesses to compensate affected consumers. The letter notes that the CMA has already taken enforcement action against four businesses under the drip pricing rules, with fines totalling more than £5.1 million and more than £1.35 million secured in refunds. The CMA says it will continue to monitor pricing across online retail and will consider using its enforcement powers where problems persist.
Businesses that also sell to consumers in Türkiye should note that Turkish consumer rules on pricing and distance sales are separate and differ in their detail. Recent changes are covered in our article on the amendments to the Turkish Regulation on Distance Contracts. For businesses entering the UK market more generally, see UK market entry.
Do mandatory delivery fees have to be included in the advertised price?
Yes. According to the CMA, where a delivery or collection charge is mandatory, it must be included in the total price shown to consumers wherever a price is given, including in advertising, on product pages, in baskets and at checkout.
What if delivery charges are optional?
Optional delivery charges do not have to be included in the headline price, but the business must make clear throughout the buying process that delivery charges may apply. If the amount cannot reasonably be calculated in advance, consumers must be told that an additional charge may be payable. This information should not be hidden behind links, pop-outs or drop-downs.
Can a retailer show a price excluding delivery as well as the total?
The CMA's letter indicates that retailers can show a breakdown, or prices both including and excluding delivery, provided the total price is clear. The total price must not be obscured by the other figures.
Does this apply to marketplaces and comparison websites?
Yes. The letter is also addressed to online marketplaces, comparison sites and search engines that show prices from multiple traders. Where products from different traders carry their own delivery charges, each product's total price should include its delivery charge.
Is there a deadline to comply?
The letter does not set a new deadline, because the requirements already apply under the DMCCA. The CMA urges businesses to review their practices now, ahead of the Christmas shopping period.
What are the consequences of non-compliance?
The CMA can investigate and impose penalties directly under the DMCCA, of up to 10% of worldwide turnover, and can require compensation for affected consumers. It has already fined four businesses a total of more than £5.1 million under the drip pricing rules.
Source: Competition and Markets Authority, Open letter to online retailers: including mandatory delivery fees in the total price, 2 November 2026. Public sector information licensed under the Open Government Licence v3.0.
Disclaimer: This article is intended for informational purposes only and does not constitute legal advice. It summarises regulatory material at the date of publication; the law and guidance may change, and their application depends on the facts.