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Showing the full price: delivery charges, fees and the CMA's price transparency guidance

What the CMA's price transparency guidance (CMA209) covers, and a practical way to audit your own price journey against rivals'. Not legal advice.

By Audience Intel876 words

A product looks good value on the listing page. Then the number grows on the way to payment: a booking fee, a service charge, a delivery cost that appears at the last step. The buyer is annoyed, and the seller has a regulatory question.

The Competition and Markets Authority published guidance on price transparency, known as CMA209, on 18 November 2025. It covers what businesses should include in the pricing information they show consumers. Below: what the guidance is about, and a five-step audit of your own price journey against rivals'. It is not legal advice; if you are unsure how the rules apply to your business, speak to a solicitor or your trade body.

What the guidance covers

CMA209 deals with the pricing information a consumer sees. Three ideas in it matter most for online shops and service firms:

  • Mandatory fees, taxes and charges. The guidance covers including these in the headline price, rather than leaving the consumer to discover them later.
  • Drip pricing. This is the practice of adding charges as the consumer proceeds through a purchase, so the price they first saw is not the price they pay.
  • Partitioned pricing. This is where a price is split into separate parts, such as a base price and a separate charge.

Read the guidance itself rather than relying on a summary, including this one. The useful habit is to ask one question of every charge on your site: could a customer buy this product or service without paying it? If the answer is no, it belongs in the conversation about the headline price.

Where extra charges tend to hide

Extra charges tend to sit in the same five places. None is automatically a problem; check each one:

  • Delivery. Is the delivery cost shown on the product page, or only in the basket? If delivery is optional (click and collect exists), say so clearly. If every order must be delivered, think carefully about how the cost is presented.
  • Service, booking or admin fees. Common in events, hospitality, clinics and some trades. If every customer pays it, it is hard to call it optional.
  • VAT. Business-to-consumer prices shown without VAT, or with VAT added at the end, are a classic source of complaints.
  • Add-ons ticked by default. Insurance, gift wrap or extended warranties that the customer has to remove.
  • Service firms' quotes. A solicitor's or accountant's fixed fee that later picks up unavoidable extras. If you publish a fee, check whether the number a client first sees is the number they will be asked to pay.

Audit your own price journey

Do this on a phone, because that is where most of your visitors will see it.

  1. Pick three representative products or services: a cheap one, a typical one and an expensive one.
  2. Screenshot the price as it first appears on a listing or category page.
  3. Screenshot the product page, the basket and the final step before payment. Stop before you pay.
  4. Write down every number that changes between the first screenshot and the last, and why.
  5. For each change, decide whether the charge is avoidable. If it is not, ask whether it could be shown earlier or included in the headline figure.

This takes discipline more than skill. The point is to see your prices the way a stranger does, without the context you carry around in your head.

Compare what rivals show

Repeat the same walk-through on the sites of three rivals you actually lose sales to. Use public pages only, add items to the basket, and stop before payment. Record where each rival first shows delivery and fees, and how they word them.

Hypothetical example: a garden furniture shop finds that two of its three rivals show a delivery estimate on the product page, while it only reveals delivery in the basket. That is an observation, not proof that the rivals sell more because of it. It is still a clear, low-effort change worth testing, and it brings the shop closer to the spirit of the guidance at the same time.

Our free shipping threshold tool helps if the comparison shows you need to rethink how delivery is charged rather than just where it is displayed.

What to do with what you find

Sort what you find into two lists. The first is presentation: charges that are fair but shown too late. These are usually quick to fix in your theme or booking system. The second is structure: charges that exist because of how your pricing was built. These need a commercial decision, often about folding a fee into the base price and accepting that the headline number goes up.

Showing the full price early can feel risky when rivals do not. A price that stays the same from the listing to the payment step gives the shopper nothing to doubt at the moment they decide.

Next step

If you want an outside view of how your basket and checkout compare with up to three rivals, an Intel loop scores cart and checkout and trust signals side by side, with quoted evidence for each score. For a first read of your own site, run the free Insight Report. Our guide to pricing benchmarking goes further on comparing prices themselves.

Sources

  1. The CMA published its price transparency guidance (CMA209) on 18 November 2025; it covers what to include in pricing information, including mandatory fees, taxes and charges in the headline price, drip pricing and partitioned pricing. gov.uk/government/publications/price-transparency-cma209 · checked 13 October 2026

Compare your site with three rivals.

An Intel loop scores your store and three competitors you choose on the same eight categories, with the evidence quoted and a specialist check.