The UK Competition and Markets Authority (CMA) announced on Wednesday that it has opened three new consumer protection investigations into Trainline, Virgin Atlantic, and RED Driving School over concerns that mandatory fees were not included in the headline prices.[1]

These investigations are a reminder that “drip pricing” remains a top consumer enforcement priority for the CMA.

What Is Drip Pricing and Why Does It Matter?

Drip pricing is the practice of advertising a product or service for a price that excludes additional and inevitable charges that are revealed to customers at a later stage in the purchase process. Drip pricing is always illegal, regardless of whether the consumers actually suffered harm as a result. However, the CMA’s particular focus on drip pricing underscores that this practice is genuinely harmful to consumers and rival businesses:

  • First, it leaves consumers facing unexpected costs and makes it harder to compare options with confidence, which is a particular concern during a cost-of-living crisis.
  • Second, it distorts competition: businesses that hide fees can appear cheaper than rivals who price transparently.

The CMA’s standard is clear: the first price a consumer sees must include all mandatory charges. Any unavoidable charge, including booking fees, digital fees, and mandatory taxes, should be built into the headline figure from the outset, not added later at checkout.

What Is the CMA Investigating?

The three new investigations concern different forms of alleged drip pricing:

  • Trainline. The investigation concerns whether mandatory fees were included in headline prices on Trainline’s website and app. The CMA says it observed dripped fees ranging from £0.59 to £2.79 on train tickets and £1.50 on coach bookings; individually modest, but charges that add up for frequent travelers.
  • Virgin Atlantic. The investigation concerns package holidays and whether resort fees and local taxes (which the CMA says can run into hundreds of pounds) were included in headline prices. The CMA is specifically investigating whether consumers were shown a total price for the package before completing their purchase.
  • RED Driving School. The CMA is looking at whether a mandatory booking fee and “digital” fee were included in the upfront price shown to consumers. These fees together came to £7 or more per lesson. This investigation is notable because it is the second in the same sector: in April 2026, it fined the AA and BSM driving schools £4.2 million and ordered refunds of over £760,000 after finding that they had failed to include a mandatory booking fee in their initial prices. The RED case signals that enforcement against one business within a particular industry can signal broader scrutiny and foreshadow further enforcement across the industry.

All three businesses had previously received advisory letters, which put the businesses on notice of the CMA’s concerns and reminded them of their consumer law obligations. The CMA has now escalated to formal investigations after continuing to monitor their pricing practices.

Key Takeaways

  • Build mandatory fees into your headline price. If a charge is unavoidable and can be calculated, it should be part of the price consumers see from the very first step –whether that is a search result, an advert or a landing page. Revealing it later in the checkout process is the behaviour the CMA is targeting.
  • Take advisory letters seriously. The CMA is actively monitoring businesses after sending advisory letters. While receiving one does not mean the CMA has found an infringement or that practices must change, these investigations show that further action may follow where concerns persist. It is therefore important to seek legal advice on whether pricing practices comply with consumer law and to consider formulating a response, as the CMA may take that response into account when deciding whether future enforcement action is appropriate.
  • No sector is off-limits. These investigations span train tickets, package holidays and driving lessons i.e., a mix of everyday and bigger-ticket spending. The common thread is the CMA’s focus on easing cost of living pressures and ensuring consumers can compare prices with confidence. Businesses across all consumer-facing sectors could be subject to scrutiny.

With the CMA now moving from guidance and advisory letters to formal investigations, businesses should consider auditing their purchasing journey, from initial advertising to final payment flows, to ensure that the price consumers see is the price they pay.

[1] See Trainline, Virgin Atlantic and RED Driving School investigated for drip pricing – GOV.UK.