The DMCC Act is no longer a future risk for travel businesses. It is here, it is being enforced, and the CMA has made clear it expects compliance now—not later.
While the Act came into force in April 2025, the turning point has been the shift from guidance to action. Over the last few months, the CMA has moved decisively into enforcement mode, and recent commentary suggests that approach is only going to intensify.
Price transparency: the headline issue
At the centre of the regime is one simple principle: the price you see must be the price you pay.
Drip pricing—where mandatory charges are added late in the booking journey—is now expressly prohibited. Businesses must include all unavoidable fees, taxes and charges in the upfront price.
For travel, that includes the difficult areas:
- Resort fees
- Local taxes
- Compulsory charges payable on arrival
The CMA has been clear that these are not optional extras. They must be disclosed prominently from the outset, even where they are payable locally.
The CMA’s crackdown: what has happened so far
The CMA’s November 2025 crackdown was the start. Following a review of more than 400 businesses, the CMA:
- Opened investigations into eight companies
- Issued warning letters to around 100 businesses (including in travel)
- Identified widespread concerns around drip pricing and hidden fees
That alone would have been enough to focus minds. But since then, enforcement has quickly escalated.
In April 2026, the CMA issued its first major financial penalty, fining a business £4.2 million and ordering refunds for drip pricing failings.
The key takeaway? This was not a complex or technical breach—just a mandatory fee not included upfront. The message now is that enforcement will be real—and visible.
More recent developments have sharpened the picture further.
- The CMA has confirmed that pricing practices are a priority enforcement area, particularly online journeys and add-on fees.
- Travel has already been a focus sector, with a significant proportion of warning letters issued to travel businesses.
- The regulator has publicly framed this as a consumer trust issue, with a clear expectation of upfront, accurate pricing across all sectors.
And crucially, in recent industry commentary and conference discussion, the CMA has indicated that it will take a firm approach to enforcement, particularly where businesses have had time to adapt but have not done so. In other words, the CMA has moved beyond education. It now expects delivery.
Why this matters: a changed enforcement landscape
The real shift under the DMCC Act is not just the rules—it is the CMA’s powers. The CMA can now:
- Decide breaches itself
- Impose fines directly (up to 10% of global turnover)
- Require refunds to consumers
All without going to court. Combined with targeted enforcement on pricing, this creates a significantly higher risk environment for consumer-facing businesses.
What travel businesses should be doing now
The position is clear. If not already completed, businesses should be:
- Auditing pricing journeys end-to-end
- Ensuring all mandatory charges are included upfront
- Reviewing treatment of local taxes and resort fees
- Removing any “drip” or staged pricing practices
- Training commercial and marketing teams on compliance
This is not about technical perfection. It is about avoiding obvious, consumer-facing issues—because those are exactly what the CMA is targeting first.
Final thought
For many in the travel industry, the question over the past year has been: how strictly will this be enforced? We are now starting to see the answer.
The CMA has the powers. It has started using them. And it is signalling—both publicly and privately—that it intends to do so more often. And for travel businesses, the takeaway is a simple one: Price transparency is no longer guidance. It is enforcement
The above article is based on our ‘Travlaw Chat Law’ podcast from earlier this year, with Katherine Peatfield and Matt Gatenby – if you’d like to listen to the full episode use the player below, and don’t forget to subscribe!
This article was originally published on: 14 May 2026
