CMA issues open letter to online retailers warning that mandatory delivery fees must be included in total prices under the Digital Markets, Competition and Consumers Act 2024
The Competition and Markets Authority published an open letter to online retailers on 2 November 2026, warning that mandatory delivery charges must be included in the total price shown to consumers at every stage of the purchasing process. The letter explicitly cites the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), which requires that any 'invitation to purchase' (any moment a price is presented to a consumer) must display the full total price inclusive of unavoidable fees. The CMA states that while many businesses have already adjusted their practices since the DMCC Act came into force, some remain non-compliant in how they present delivery charges. The obligations apply not only to individual online shops but also to online marketplace operators, comparison sites, and search engines. The total price must appear at every stage: advertising, product pages, baskets, checkout, and payment screens. Consumers must not have to search through hidden menus or expandable sections to find delivery cost information. The CMA warns that where ongoing non-compliance is identified, it may use its enforcement powers. The letter references the CMA's published price transparency guidance (CMA209) and notes the timing is deliberate, issued as the Christmas shopping period approaches. The letter follows the CMA's detailed guidance published in November 2025.
Why this matters
The DMCC Act marked a significant expansion of the CMA's direct enforcement powers over consumer-facing businesses, giving the regulator the ability to impose fines without going to court. This open letter is an early signal of how the CMA intends to use those powers: targeted pre-enforcement pressure timed to the highest-stakes retail period of the year. The scope of the obligation is wider than many retailers may appreciate, extending to marketplaces and price comparison platforms, not just direct sellers. Retailers who fail to act now face heightened enforcement risk precisely when transaction volumes, and therefore potential consumer harm from opaque pricing, are greatest.
On the Ground
This activates regulatory compliance, consumer law, and digital platform practice areas. In-house retail and platform clients will need advice on whether their current pricing presentation complies with the DMCC Act's requirements, including a review of advertising, product pages, basket flows, and checkout screens. Firms with consumer regulation practices will be fielding instructions from marketplaces and comparison sites, which face the same obligations as direct retailers. No law firms are named in the source. A trainee would assist by drafting a compliance gap analysis memo mapping a client's current pricing disclosure against the CMA's guidance (CMA209), and by preparing a regulatory notification summary setting out the enforcement risk and recommended remediation steps.
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“What enforcement tools does the CMA have under the Digital Markets, Competition and Consumers Act 2024, and how does this open letter fit into that framework?”
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- https://www.gov.uk/government/publications/online-retailers-including-mandatory-delivery-fees-in-the-total-price
- https://www.gov.uk/government/publications/online-retailers-including-mandatory-delivery-fees-in-the-total-price/open-letter-to-online-retailers-including-mandatory-delivery-fees-in-the-total-price
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