CMA Issues First £473,000 Fine — Is Your Checkout Page Breaking the Law?

The Competition and Markets Authority fined Euro Car Parks £473,000 on 13 February 2026 — the first direct fine ever issued under the Digital Markets, Competition and Consumers (DMCC) Act 2025. Eight live investigations are currently open. More fines are imminent.

If your business has a checkout page, a subscription product, or any promotional pricing — read this before the CMA's next announcement.

---

The Fine That Changed Everything

Euro Car Parks was fined £473,000 for drip pricing — adding mandatory charges to bookings that weren't disclosed at the start of the customer journey.

This is the first time the CMA has used its new direct enforcement powers under the DMCC Act to issue a fine without going through the courts. Previously, the CMA had to litigate every case. Now it can:

• Investigate a business
• Issue a fine directly
• Enforce payment without a court order

The fine ceiling: up to 10% of global annual turnover. For a retailer doing £2 million per year, that's a potential £200,000 fine. For a business doing £10 million, it's £1 million.

No court. No warning letter first. The CMA is using these powers.

---

What Are the Eight Live Investigations?

As of March 2026, the CMA has eight active investigations under the DMCC Act. It has not named all targets, but confirmed the investigation areas include:

• Drip pricing (adding undisclosed fees at checkout)
• Countdown timers that restart when they expire or that apply to stock that isn't genuinely limited
• Fake "was/now" pricing where the "was" price was never genuinely charged
• Subscription auto-renewals without adequate pre-renewal notification
• Pre-ticked opt-in boxes for additional products or services

The sectors being examined include retail, booking platforms, subscription services, and hospitality. The CMA has been explicit: it is targeting online retailers and businesses that sell through a checkout process.

Enforcement is accelerating. The Euro Car Parks fine was issued less than six months after the DMCC Act received Royal Assent.

---

What Practices Are Now Illegal?

Drip Pricing

What it is: Advertising a headline price and then adding mandatory fees — booking fees, admin charges, processing fees, delivery fees — later in the checkout journey.

The rule: Any mandatory fee that is unavoidable must be included in the advertised price from the first time it is shown. A booking fee that applies to every purchase is not optional — it must be in the headline price.

Common violations:

• Parking booking: £10, then £3.50 "booking fee" added at payment
• Concert tickets: face value displayed, then "facility fee" and "booking fee" added
• Hotel rooms: nightly rate shown, then resort fee at checkout
• Furniture delivery: price shown, then a "delivery and handling" charge added before confirming

Countdown Timers

What it is: A timer on a product page or in a shopping basket saying "this price expires in 15:00."

The rule: A countdown timer must represent a genuine, time-limited offer. If the timer resets when it expires, if the same price is available after the countdown ends, or if the "limited" stock is actually unlimited — the timer is misleading.

Common violations:

• Timers that reset when the page is refreshed
• "Sale ends today" banners that run every day
• "Only 3 left" messages that don't reflect real inventory levels

Auto-Renewal Subscriptions

What it is: A subscription that renews automatically without the customer's affirmative action.

The rule under DMCC: Customers must be reminded of an upcoming renewal clearly, with enough notice to cancel. The cancellation process must be as easy as the sign-up process — the DMCC Act specifically requires single-step cancellation to be possible.

This applies to:

• Subscription boxes (beauty, food, fitness)
• SaaS products with annual auto-renewal
• Gym memberships with rolling contracts
• Streaming and content services

Pre-Ticked Boxes and Default Opt-Ins

What it is: Checkout pages that include additional products or services pre-selected, requiring the customer to actively untick to remove them.

The rule: Default opt-in for any additional charge is prohibited.

---

Advisory Letters: You May Already Be on the CMA's Radar

The CMA has confirmed it sent advisory letters to over 100 businesses across 14 sectors before the Euro Car Parks fine was issued. These letters warned businesses that their checkout practices may breach consumer protection law and gave them an opportunity to change.

Businesses that received advisory letters and did not change their practices are now in the active investigation pool.

If your business received a letter from the CMA in 2025 or early 2026, you should treat it as a formal warning.

If you have not received a letter, that does not mean you are clear. The CMA stated that advisory letters were targeted at the most egregious cases it had already identified — not the totality of potential violators.

---

Who Is Most at Risk?

The highest-risk businesses are those operating online checkout processes with:

• Dynamic pricing or promotional pricing structures
• Booking fees or admin charges added at checkout
• Subscription products with auto-renewal
• "Sale" pricing that has been running for extended periods
• Countdown timers or scarcity messaging in checkout flows

Sector breakdown:

Sector	Specific Risk
Online retail	Drip pricing delivery fees, fake was/now pricing
Booking platforms	Hidden booking/admin fees, countdown timers
Gyms and leisure	Auto-renewing contracts, cancellation barriers
Subscription boxes	Auto-renewal without adequate notice
SaaS / software	Pre-ticked add-ons, single-click cancellation not available
Hospitality booking	Room rate + resort fee structures

---

The Compliance Checklist: Audit Your Checkout Page

Work through each of these questions about your checkout or booking process:

Pricing transparency:

• Is the total price (including all mandatory fees) shown at the first opportunity?
• Are there any fees added during checkout that aren't in the original advertised price?
• Is your delivery fee mandatory? If so, is it included in the displayed price?

Promotional pricing:

• Is every "was" price based on a price that was genuinely charged for a meaningful period?
• Do your countdown timers represent real, non-recurring deadlines?
• Are scarcity claims ("only 2 left") accurate at the time they're shown?

Subscriptions:

• Do customers receive pre-renewal notification before auto-renewal?
• Can customers cancel in a single step — as easy as signing up?
• Is the total recurring cost clearly stated at sign-up?

Opt-ins:

• Are all additional products or services opt-in (not pre-ticked)?

If you answered "no" to any of these, you have a compliance gap that the CMA can act on today.

---

What the DMCC Act Changes

Before the DMCC Act, the CMA's consumer enforcement powers required it to go to court to impose penalties. The process was slow and expensive — most businesses calculated it was easier to fight than settle.

The DMCC Act changes this fundamentally:

• No court required for fines up to 10% of turnover
• Decision by the CMA itself — businesses can appeal but the default is enforcement
• Faster investigations — the CMA can issue provisional decisions and final decisions on an accelerated timetable
• Civil penalties that compound — daily penalties can accrue during investigations

The CMA has described the Euro Car Parks fine as "a signal that we will use these powers." Eight open investigations suggest the signal is real.

---

How ComplianceAlert Helps UK Retailers

ComplianceAlert monitors CMA investigations, enforcement announcements, and DMCC guidance updates. When the CMA publishes a new advisory notice, opens a new investigation, or amends its consumer protection guidance, you receive a plain-English alert the same day.

For online retailers, subscription businesses, and booking platforms, staying ahead of CMA enforcement is not optional — it's the cost of operating legally in the UK.

Not sure if your checkout is compliant? Take our free 3-minute Compliance Score quiz — instant results, no sign-up: 👉 compliancealert.co.uk/compliance-score

---

Key Takeaways

• CMA issued its first-ever DMCC fine: £473,000 to Euro Car Parks on 13 Feb 2026
• Eight live investigations currently open — more fines are coming
• Drip pricing, fake countdown timers, pre-ticked boxes, and unfair subscription auto-renewal are all enforcement targets
• The fine ceiling is 10% of global annual turnover — no court required
• Audit your checkout page today — the practices the CMA is targeting are widespread among UK SMBs

👉 Start your free 7-day trial at compliancealert.co.uk — monitor CMA, HMRC, and 14 other UK regulators in one place.

---