The CMA has issued updated guidance on price transparency which has real practical implications for travel businesses, particularly around headline pricing and local taxes/resort fees payable in resort. Some businesses may not yet be aware of the detail, so Themis Advisory have pulled together a short bulletin with a simple breakdown of the key points and what to do now.
CMA guidance on price transparency – headline travel prices must include local taxes and resort fees
The CMA published new guidance on price transparency in November 2025 under the Digital Markets, Competition and Consumers Act 2024.
For travel businesses, the message is clear – if a charge is unavoidable, it should be part of the advertised price. This applies even if it is not collected by the agent/operator and is instead paid by the customer at the hotel or destination. This is a significant shift for many travel and accommodation providers whose pricing models have historically treated ‘local taxes’ or ‘resort fees’ as separate from the headline price.
The guidance applies to any business advertising prices to UK consumers. This includes agents, tour operators, cruise lines, OTAs and airlines. If you make the consumer facing price available, you may be liable if the headline price omits mandatory charges or otherwise misleads. Bed banks and wholesalers can also be drawn in where their pricing feeds/content drive how prices are presented downstream, or where they make consumer facing prices available themselves.
What’s changed for travel businesses?
1) Headline prices must reflect the true total cost
The CMA expects consumers to be shown the total price upfront i.e. a fully inclusive price, including mandatory fees, taxes and charges that the consumer will necessarily have to pay.
2) Local taxes/tourist taxes/resort fees are in scope
The CMA is explicit that local taxes, resort fees and other unavoidable charges payable on arrival/departure are normally mandatory and reasonably calculable. In most cases, that means they should be included in the price you advertise, including ‘from’ prices.
This applies even where the charge is paid locally (not at booking stage), is paid to a hotel/local authority (not the travel business), and/or is charged in a foreign currency.
If a charge cannot be reasonably calculated in advance, the non-calculable element should be displayed with equal prominence next to the headline price, together with enough information for the consumer to calculate it.
3) ‘Pay-now’/’pay-later’ pricing should be reviewed
Where part of the cost is paid later (for example, local tourist taxes at check-in/check-out), the CMA expects the customer to be shown a clear, consolidated total and an explanation of what is payable when. Presenting ‘pay-now’ and ‘pay-later’ elements in different currencies without a clear total creates obvious compliance risk.
4) Drip pricing is prohibited
The guidance reinforces that businesses should not show an attractive headline price and then introduce mandatory charges later in the booking journey.
Enforcement is live
The CMA has publicly signalled that price transparency is a priority. The CMA has confirmed it has already begun direct engagement with businesses about compliance, including issuing advisory letters and opening investigations in late 2025.
In our view, travel businesses should assume this will be an active enforcement area given the historic consumer sensitivity around travel pricing and the CMA’s focus on mandatory ‘add-on’ charges. We do not expect an extended grace period for compliance with the updated guidance, although the CMA has indicated that they will proactively work with businesses to comply rather than seek enforcement action immediately. Given that the CMA has new powers to make decisions regarding breaches of consumer law and impose fines without Court action, it is important to take proactive steps towards compliance now.
Recommended immediate actions
We recommend travel businesses urgently review:
- Headline prices and ‘from’ prices including ads, search results, brochures, email marketing and product listings to ensure local taxes/resort fees and other mandatory charges are included wherever they can be calculated.
- Booking flows/processes to ensure mandatory charges are not being added later in the journey (minimising any drip pricing risk).
- How ‘pay-later’ charges (including foreign currency charges) are displayed, ensuring consumers can see a consolidated total and a clear breakdown of what is paid now versus later.
- Third-party channels and affiliates, where pricing presentation is often constrained, but still needs to be compliant.
- Supplier information/agreements to ensure that all mandatory charges are properly communicated and captured for pricing purposes.
How we can help
Depending on the business model you operate, there will undoubtedly be additional considerations and nuances to navigate to ensure compliance. We understand how difficult this can be and the operational constraints that must be overcome.
We can support with a review of advertising and booking journeys, practical guidance on how to incorporate the new headline price requirements across all sales channels and provide support responding to any approach by the CMA.
Please contact us if you would like to discuss the impact of the guidance on your pricing, booking journeys and customer communications.
For further information, please contact:
Joanna Kolatsis
Director
Themis Advisory
M: +44 (0)7768 695 797
DD: +44 (0)203 950 6961
E: joanna@themis-advisory.co.uk
W: themis-advisory.co.uk