The Competition and Markets Authority (CMA) has written to every online retailer selling to UK consumers with a blunt reminder ahead of Christmas: if a shopper has to pay for delivery, that charge belongs in the price from the very first screen. The open letter, published on gov.uk on the morning of 2 November 2026, says some businesses are still showing delivery fees too late, too quietly or not at all, and warns that the regulator is prepared to use its fining powers under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act).
The timing is deliberate. Black Friday falls on 27 November this year, and the busiest weeks for UK online orders are about to begin. For shoppers, the letter is a useful checklist of what a lawful product page, basket and checkout should look like. For retailers, marketplaces and price comparison sites, it is the last clear warning before the regulator starts looking for cases.
In short
- The CMA open letter (2 November 2026) tells UK online retailers that mandatory delivery fees must be included in the total price wherever a price is shown.
- Every stage counts: adverts, product pages, baskets, order summaries, checkout and payment pages all have to show the full price.
- Marketplaces, comparison sites and search engines are covered too, not just retailers selling their own stock.
- Four named problems are on the CMA’s watch list, from leaving delivery out of basket totals to hiding optional delivery prices in drop-down menus.
- The penalties are real: the CMA has already fined four businesses more than £5.1 million for drip pricing and secured more than £1.35 million in refunds.
What has the CMA told online retailers?
The letter is short and practical. It reminds traders that the DMCC Act requires the total price, including mandatory delivery or collection fees, to be shown whenever a business makes an “invitation to purchase”. In plain terms, that means any time a product and its price are presented in a way that lets a consumer decide to buy it.
The CMA says it recognises that many businesses changed their websites after the Act’s consumer provisions came into force, and it welcomes those changes. But it adds that it is “concerned” that some businesses “remain non-compliant in how they present delivery charges”. The letter sets out what the regulator has seen, what the law requires, and what traders should do now to “reduce the risk of enforcement action”.
Its central line is a single sentence that is likely to be quoted back at retailers for months: “The first price consumers see should be the price they pay.” According to Financial News, which reported the letter shortly after publication, it was signed by Sorcha O’Carroll, senior director for consumer at the CMA.
The regulator points businesses towards its price transparency guidance, published as CMA209 in November 2025. It singles out Chapter 4, which covers the core legal requirements, and paragraphs 5.2 to 5.21, which deal specifically with delivery fees. The full text of the CMA open letter to online retailers is available on gov.uk.
Why a letter rather than a fine?
Open letters are a familiar CMA tool. They are used when the regulator believes a practice is widespread and wants to give an entire sector notice before it opens individual cases. The CMA says it always seeks to use its enforcement powers “in a fair and proportionate manner”, but that where it sees “ongoing non-compliance” it may act.
The practical effect is that no online retailer can now claim it was unaware of how the CMA reads the law on delivery fees. That matters because the DMCC Act regime allows the regulator to decide cases and impose penalties itself, rather than having to go to court first.
Which delivery charges must be in the headline price?
The letter draws a sharp line between mandatory and optional delivery fees. A delivery charge is mandatory when a shopper cannot buy the product without paying it, for example because the retailer offers no free collection option. In that case, the CMA says, “the total price including the minimum mandatory delivery charge must be shown to the customer throughout the sales process”.
The word “minimum” is important. The CMA’s guidance explains that delivery is not optional just because a retailer offers a choice between standard and next-day services. If every route to the product costs money, the total price shown at the outset should include the cheapest delivery option. If the shopper later picks a dearer service, the price shown from that point on should include it.
Optional charges are treated differently. Where a shopper can avoid delivery fees altogether, for example by collecting in store or from a free collection point, those fees do not have to be built into the total price. But the retailer must still tell customers clearly, throughout the process, that the charges exist. If the amount cannot reasonably be calculated in advance, the retailer has to explain that an additional charge may be payable.
One of the most common UK pricing models is free delivery above a spend threshold, such as orders over £40. The CMA’s guidance says this does not make the delivery cost impossible to calculate. The retailer must include the full delivery fee in the total price until the basket reaches the threshold, and can then remove it. Retailers are allowed to tell customers that the charge will disappear once the order passes the threshold.
The guidance also warns that advertising “free delivery on orders over” a set amount without telling shoppers what delivery costs below that level may amount to an omission of material information. For bargain hunters building small Christmas baskets, that is one of the most relevant parts of the rules.
What does a lawful basket and checkout look like?
The CMA accepts that a single flat delivery fee charged once per order cannot sensibly be added to the price tag of every item in a large basket. The letter says retailers must still give the total price, including mandatory delivery, throughout the shopping process, but they can do this in several ways. Showing a breakdown, or the delivery fee itself, alongside the total is allowed; the letter suggests retailers could, for example, “automatically display the price for a product both including and excluding delivery”.
CMA209 lists three broad approaches. A retailer can show the total price below or beside a more prominent base price. It can show the base price plus delivery information and a clear, prominent running total for the basket that updates as items are added. Or it can drop the separate delivery fee and build the cost into product prices, in effect offering free delivery.
Where a running total is used, the guidance says it must be clearly visible and include the mandatory delivery charge from the outset. It gives examples of compliant designs: a “floating basket” or “sticky banner” that stays on screen and updates in real time; a dynamic “add to basket” button that shows how much adding an item will actually cost, fees included; or a basket that opens automatically after each item is added and shows the full total.
When a shopper opens the basket, the total price for the products selected must be shown. If delivery charges change as the basket changes, the CMA says the total and the charges “should update automatically”. What is not acceptable is a basket that shows only the product subtotal and leaves delivery to the final payment page.
Worked examples from the CMA guidance
The CMA’s guidance includes several worked examples that translate the law into everyday shopping. The table below summarises the delivery scenarios most relevant to UK online shoppers.
| Scenario in CMA209 | What the shopper sees | Why it is compliant |
|---|---|---|
| Online clothing retailer advertises a £20 dress in search results; no collection, £4.50 minimum delivery | Advert shows a total of £24.50 | Delivery is unavoidable, so it is in the advertised price |
| Online homeware retailer with a flat £5.99 delivery fee; shopper adds a £25 lamp, then £30 plates | Pop-up basket shows £30.99, then £60.99 | Flat fee explained beside prices and included in a prominent running total |
| Marketplace selling personalised gifts from different traders | £10 frame with £2.99 delivery listed at £12.99; £8 item with £5.50 delivery listed at £13.50 | Each seller’s delivery cost is built into each product’s headline total |
| Department store with regional charges (mainland GB free, Northern Ireland £5, Scottish Highlands and Islands £10, Isle of Man £10, Channel Islands £15) | Charges listed on product page; logged-in shopper sees their own charge in the running total | Variable charge becomes calculable once the address is known |
| Perfume retailer with free standard delivery and £5 next-day option | Banner explains free delivery and the £5 next-day option | Next-day delivery is optional, so it can sit outside the total if clearly flagged |
Online grocery and minimum orders
Online supermarkets operate differently from most retailers. Many require a minimum basket value before delivery is available, and slot prices can vary by day, time and postcode. The CMA’s guidance accepts that in these situations it may not be possible to give a total price for each individual item, because a single item cannot be bought on its own.
Instead, the guidance says grocers and food delivery services need to give customers the information required to calculate the total price of the order, and make them aware of minimum order thresholds. A running total with a breakdown of how it is calculated is one way of doing this. Variable mandatory charges that depend on factors “outside the consumer’s knowledge and control” are not allowed, because shoppers would be unable to work out the true cost.
With supermarkets opening Christmas delivery slot bookings this week, as set out in shopappy’s round-up of Tesco and other supermarket Christmas delivery slots, households booking a slot can expect the delivery charge to appear in the running total as soon as a slot is chosen, rather than as a surprise on the payment page.
Does this apply to Amazon, eBay and price comparison sites?
Yes. One of the most significant parts of the letter is its reach beyond ordinary retailers. The CMA says the requirement to make complete pricing information available “applies not just to shops, but also to online marketplace operators, comparison sites and search engines”.
Its example is aimed squarely at marketplace search results. Where a marketplace lists items from different traders, each sold individually with its own delivery charge, “the price of delivery should be included in the total price of each product”. Traders and platforms can still show the base price excluding delivery, but only if the total price is presented clearly, in good time and in a way the consumer is likely to see.
That has obvious implications for UK marketplaces where independent sellers set their own postage, from large general platforms to craft and second-hand sites. A search results page that ranks items by base price, with postage revealed only after clicking through, is precisely the kind of layout the CMA describes as a risk. Comparison sites that show the cheapest base price without postage face the same question.
For UK sellers on third-party platforms, the immediate responsibility for layout sits with the marketplace operator. But sellers control the postage figures they enter, and listings that rely on low item prices and high delivery charges are likely to look less competitive once totals are shown. Sellers who have used “item price low, postage high” tactics to climb price-sorted search results may find that advantage shrinks as platforms adjust.
The four practices on the CMA watch list
The letter lists four examples of non-compliant practices the CMA says it is “looking out for”. They are worth quoting in full because they are, in effect, the regulator’s audit checklist for Christmas 2026:
- Displaying a product price without including a mandatory delivery charge in the total price.
- Failing to include applicable mandatory delivery charges within basket totals or order summaries.
- Failing to provide information about optional delivery fees, or placing that information behind links, separate pages, pop-out pages, expandable sections or drop-down menus.
- Failing to provide information about delivery charges until late in the checkout stage.
The third point will catch a large number of UK websites. A “Delivery information” link in the footer, a collapsed “Shipping and returns” tab on a product page, or a pop-out that only appears when a shopper hovers over an icon are all common design patterns. The CMA’s letter says customers “should not have to search through separate pages, hidden menus or expandable sections” to find delivery information.
The fourth point is the classic form of drip pricing: the product price looks attractive, and the delivery charge appears only once the customer has entered an address and card details. In its StubHub decision, the CMA said drip pricing can leave people “caught out by extra charges” and lead them to buy things they might not otherwise have chosen, had they been able to compare prices accurately from the start.
How hard has the CMA hit hidden fees so far?
The DMCC Act’s consumer enforcement powers came into force in April 2025. Since then, the CMA has moved from warnings to fines. The open letter says the regulator has “already enforced the rules on drip pricing against 4 businesses, imposing fines totalling more than £5.1 million and securing more than £1.35 million in refunds for affected consumers”.
Drip pricing has been one of several targets. According to a CMA press release on 14 October 2026, the regulator had by then imposed fines of more than £12 million and secured nearly £2.4 million in refunds across all its cases under the new powers in the previous 18 months. Those cases also covered false countdown offers and pre-ticked boxes for paid extras, both of which are relevant to online shopping in the run-up to Black Friday; shopappy covered the countdown rules in its report on early Black Friday sales and fake countdown deals.
| Case (CMA announcement) | Practice | Fine | Refunds ordered |
|---|---|---|---|
| AA Driving School and BSM Driving School (15 April 2026) | Mandatory £3 booking fee left out of upfront price | £4.2 million | More than £760,000 to over 80,000 learners |
| Marks Electrical (18 June 2026) | Automatic opt-in to paid recycling and packaging removal | £720,000 | Around £600,000 |
| StubHub UK (23 June 2026) | Mandatory fees, including delivery and service fees, added at final checkout stage | Close to £900,000 | More than £590,000 to over 50,000 fans |
| Wayfair (14 October 2026) | False time-limited offers | £4.8 million | Not applicable |
| Appliances Direct (14 October 2026) | False time-limited offers and pre-ticked paid extras | £1.2 million | Around £432,000 |
| Gold’s Gym UK (14 October 2026) | Joining fee not shown clearly in total membership price | £45,000 | Around £9,000 |
All of the businesses fined so far admitted breaking the law and settled early, which the CMA says earned each of them a 40% reduction in their penalty. The StubHub case is the closest precedent for online retail: the CMA found that between 6 April and 7 December 2025 some fans were required to pay mandatory costs “such as delivery and service fees” that were added only at the final stage of checkout.
How large can fines get?
Under the DMCC Act, the CMA can fine businesses up to 10% of their global turnover for breaching consumer law, and can also order redress for affected consumers. The fines handed out so far are well below that ceiling, in part because of early settlement and in part because the cases involved relatively small fees. A large online retailer that systematically hid delivery charges across millions of orders would be in a very different position.
The CMA has several drip pricing investigations still running. In August 2026 it opened cases into Trainline, Virgin Atlantic and RED Driving School over the presentation of mandatory fees, and in June it began investigating Ryanair over charges for parents to sit with their children. None of those businesses is an online goods retailer, but the open letter makes clear that the same principles are now being applied to delivery fees on retail sites.
Why is the CMA acting now, before Christmas?
The letter opens with the regulator’s reasoning: “As we approach the Christmas shopping period, we are reminding traders of the importance of ensuring that they make prices, including delivery fees, clear to customers up front.” The peak season brings a surge of first-time customers to retailers they have never used before, which is exactly when an unexpected delivery fee is most likely to mislead.
Online spending is also accelerating. Recent figures show UK online sales running well ahead of high street sales, as shopappy reported in its analysis of October online sales growth of 10.1%. More orders placed online means more delivery charges, and more scope for those charges to be presented badly.
Delivery itself is also under pressure. Parcel carriers are adding capacity for the peak, and the cost of meeting Christmas deadlines can push retailers towards premium delivery tiers. Shoppers planning gifts by post can check the cut-off dates in shopappy’s guide to Royal Mail’s Christmas 2026 last posting dates, but the CMA’s point is that whatever the delivery option, its cost must be visible before the customer commits.
Black Friday on 27 November and Cyber Monday on 30 November are likely to be the first big tests of compliance. Discount banners and “lowest price” claims are only meaningful if the price shown is the price paid. A heavily discounted product that attracts a large compulsory delivery fee at checkout is precisely the scenario the letter targets, and the CMA has already shown, through its October fines on Wayfair and Appliances Direct, that it is watching sales tactics closely.
How can shoppers spot a hidden delivery fee?
The open letter is addressed to businesses, but it doubles as a guide for consumers. Shoppers can use the CMA’s four warning signs to judge whether a retailer is playing fair. If the product page shows a price with no mention of delivery, and the retailer does not offer free collection, that is a red flag.
Other warning signs include a basket total that does not include delivery even after a postcode has been entered, a “free delivery” claim with no explanation of what smaller orders cost, and delivery information that only appears behind a “more info” link or a collapsed tab. Comparing two retailers on base price alone can be misleading if one of them adds a large delivery charge late in the process.
A simple checklist before you pay
- Check whether the product page shows a total including delivery, or at least a clear delivery price beside the item.
- Open the basket before entering card details and confirm the delivery charge is already included in the total.
- If a free delivery threshold is advertised, check what delivery costs below it.
- When comparing marketplace listings, compare item price plus postage rather than item price alone.
- Take a screenshot of the price shown on the product page in case you need to complain later.
The CMA does not handle individual complaints, but it uses consumer reports to decide where to investigate. Shoppers who believe a retailer has hidden a mandatory delivery fee can report it to Citizens Advice, which passes information to Trading Standards and the CMA. In the cases the CMA has concluded so far, refunds were paid automatically to affected customers, who did not need to take any action.
What should UK online retailers do now?
The letter asks businesses that have not already done so to review their website, mobile app and online advertising against the DMCC Act and CMA209, and to make “any changes necessary” so that consumers receive “clear, prominent and timely information about the total price they are likely to pay up front”. That review needs to cover every point at which a price appears, not only the checkout.
For most retailers, the work falls into a handful of areas. Paid search and shopping adverts need to show delivery-inclusive prices where delivery is unavoidable. Product pages need either a delivery-inclusive total or a prominent base price plus delivery information and a running basket total. Order summaries and mini-baskets need to include delivery as soon as it can be calculated.
| Touchpoint | Common risky practice | What the CMA guidance points towards |
|---|---|---|
| Search and shopping ads | Item price only, delivery unmentioned | Total price including minimum mandatory delivery |
| Product page | Delivery details in a collapsed tab or footer link | Delivery price shown alongside the headline price |
| Mini-basket or basket page | Subtotal excluding delivery | Running total including mandatory delivery, updating automatically |
| Free delivery offers | “Free over £40” with no below-threshold price | Full fee in total until threshold met; state the fee below it |
| Checkout | Delivery charge first revealed after address entry | No new mandatory charges at the final stage |
| Marketplace results | Sorting by base price with postage hidden | Each listing’s total includes that seller’s delivery charge |
The rules apply to businesses of every size. Independent shops selling online through their own websites often rely on off-the-shelf ecommerce templates, many of which show a product subtotal in the basket and calculate postage only at checkout. Those businesses may need to change theme settings, switch on running totals or move to clearly priced flat-rate delivery to comply.
The simplest route, which the CMA’s guidance explicitly recognises, is to absorb the delivery cost into product prices and offer free delivery. That is not always possible for small traders on thin margins, but a clearly stated flat fee shown on every product page and included in the basket total from the start is likely to meet the requirement.
How does this fit the wider UK consumer law shake-up?
The delivery fees letter is one part of a broad tightening of UK consumer law under the DMCC Act. The Act gave the CMA direct enforcement powers, banned fake reviews, and set out rules on drip pricing and misleading sales practices. Further measures are on the way, including the new regime for subscription contracts, which shopappy covered in its report on UK subscription rules taking effect on 1 January 2027.
The regulator is also looking ahead to new ways of shopping. On 30 October 2026 the CMA published guidance on how consumer law applies to businesses using AI agents, setting out that firms remain responsible for what automated tools tell customers. If shoppers increasingly ask AI assistants to find the cheapest version of a product, accurate total prices including delivery become even more important, because a tool comparing base prices would reach the wrong answer.
For UK shoppers the direction of travel is clear. The price shown at the start of an online purchase is supposed to be the price paid at the end, unless the customer chooses to add something. The CMA has now said so in writing to every online retailer in the country, weeks before the busiest shopping period of the year, and has made clear that the next step for businesses that ignore it could be a fine.
Frequently asked questions
What did the CMA announce on 2 November 2026?
The CMA published an open letter reminding online retailers in the UK that mandatory delivery fees must be included in the total price and shown up front, at every stage where a price is given. It also listed four practices it is looking for and warned it may take enforcement action.
Is drip pricing illegal in the UK?
Yes. Under the Digital Markets, Competition and Consumers Act 2024, a price given in an invitation to purchase must be the total price, including mandatory fees, taxes and charges such as unavoidable delivery fees. Adding those charges late in the buying process is known as drip pricing and breaches the law.
Do retailers have to include optional delivery charges in the price?
No. Optional charges, such as next-day delivery when free standard delivery or free collection is available, do not have to be in the total price. However, retailers must clearly tell customers that the charges apply, and must not hide them behind links, drop-down menus or expandable sections.
What about free delivery over a certain amount?
The CMA’s guidance says the full delivery fee must be included in the total price until the basket reaches the free delivery threshold. Retailers can then remove it, and can tell customers the charge will disappear once they spend enough. Advertising free delivery over a threshold without saying what delivery costs below it may be misleading.
Do the rules apply to Amazon, eBay and other marketplaces?
Yes. The CMA says the requirements apply to online marketplace operators, comparison sites and search engines as well as retailers. Where a marketplace lists items from different sellers, each with its own delivery charge, delivery should be included in the total price of each product.
How much can the CMA fine a retailer?
Under the DMCC Act, the CMA can fine businesses up to 10% of global turnover for breaking consumer law and can order refunds to affected customers. It has already fined four businesses more than £5.1 million in total for drip pricing and secured more than £1.35 million in refunds.
What should I do if a retailer added a delivery fee at checkout?
Keep a screenshot of the original price, and report the retailer to Citizens Advice, which shares information with Trading Standards and the CMA. In concluded CMA cases so far, affected customers received refunds automatically without having to claim.
Does the guidance apply to online supermarkets with minimum orders?
Yes, but the CMA accepts that a total price for each item may not be possible when items cannot be bought individually. Grocers must give shoppers the information needed to work out the total order price, including delivery, and make them aware of minimum order thresholds, for example through a running total.