Mandatory delivery fees: what online retailers must show in the price
In short: A UK online retailer must include mandatory delivery fees in the total price it shows in adverts, on product pages and in basket totals, under section 230(4) of the Digital Markets, Competition and Consumers Act 2024. The Competition and Markets Authority restated the rule in an open letter of 2 November 2026 and said it will continue to monitor online retail.
An online retailer that charges every buyer of a product for delivery must include that charge in the price it shows for the product, from the first advert to the order summary. The Competition and Markets Authority (CMA) wrote to online retailers on 2 November 2026 because some still give delivery charges only late in checkout, and it encouraged them to review their websites, apps and online advertising as the Christmas shopping period approaches.
The CMA’s Senior Director for Consumer signed the open letter, which does not name any business. The CMA gives four examples of non-compliant practices it is looking out for: a product price shown without a mandatory delivery charge; basket totals or order summaries that leave the charge out; information about optional delivery missing or placed behind links, separate pages, pop-outs, expandable sections or drop-down menus; and delivery information given only late in checkout. The CMA has already enforced the drip pricing rules against four businesses, with fines of more than £5.1 million and refunds of more than £1.35 million (open letter, 2 November 2026).
The total price rule in section 230 of the DMCCA
A trader making an invitation to purchase must give the consumer the total price of the product, and section 230(4) of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) defines that total to include any fees, taxes, charges or other payments the consumer will necessarily incur on buying the product. An invitation to purchase is any commercial practice that gives the consumer a product’s characteristics and price and enables, or purports to enable, the consumer to decide whether to buy (section 230(10)). A social media advert, a marketplace listing, a product page and a basket each qualify where they show a price and the characteristics of a product (CMA209, paragraph 2.2).
A practice that omits the total price, where it is not already apparent from the context, is unfair under section 225(4)(b) without any need to show that a consumer would have decided differently. Under section 230(9), a trader that gives information in an unclear or untimely way, or where the consumer is unlikely to see it, is treated as having omitted it. A mandatory delivery fee that first appears at the payment step has therefore been left out of every price shown before it. The CMA opened its most recent drip pricing investigations in August 2026.
When a delivery fee is mandatory
A delivery charge is mandatory where the consumer cannot buy the product without paying it, according to the CMA’s price transparency guidance (CMA209, paragraph 5.3), first published on 18 November 2025. Where the retailer offers free collection in store or from a local collection point, paid home delivery is optional (paragraph 5.8), although the CMA says the answer may depend on the context and on how the product is marketed (paragraph 5.9). A choice between paid options does not make delivery optional, and the CMA’s guidance is that the price shown at the outset should include the cheapest option, with later totals reflecting the option the consumer picks (paragraph 5.10).
The CMA applies the rule to the common delivery models as follows (paragraph references are to CMA209 as published on GOV.UK on 11 November 2026).
| Delivery model | What the CMA expects the retailer to show | CMA209 |
|---|---|---|
| Charge per item, or a fixed charge on an item bought on its own | Each product’s price including its delivery charge, or the base price with the total including delivery shown clearly beside it | Paragraphs 5.4 and 5.6 |
| One charge per order covering several items | The total shown beside a base price, or the base price with delivery information and a visible running total that includes the charge, or prices that absorb the delivery cost | Paragraphs 5.17 and 5.18 |
| Paid options only (standard or next-day) | A total including the cheapest paid option until the consumer chooses another | Paragraph 5.10 |
| Free delivery above a spend threshold | A total including the full fee until the basket reaches the threshold | Paragraph 5.14 |
| Free collection available | Paid delivery disclosed in the invitation to purchase, which may be shown outside the total price | Paragraphs 5.8 and 5.9 |
| Charge depends on the address | A statement that delivery is payable and how it is calculated, then the charge in the total once the address is known | Paragraphs 5.12 and 5.13 |
Optional and variable delivery charges
A retailer may show an optional delivery charge outside the total price, but must still give it in the invitation to purchase. Under section 230(2)(g) of the DMCCA, any freight, delivery or postal charges that are not in the total price but which the consumer may choose to incur are material information, and where they cannot reasonably be calculated in advance the fact that they may be payable is material. The CMA said in its letter that customers should not have to search separate pages, hidden menus or expandable sections to find this information.
In the CMA’s view, where a mandatory delivery charge depends on the address and cannot be calculated in advance, the retailer must say that delivery is payable and explain how the charge is calculated, with as much prominence as the calculable part of the price, so that the consumer can work out the total (CMA209, paragraph 5.12, applying section 230(2)(c) and (5)). Once the consumer has given the retailer the information it needs, the charge can be calculated and later prices should include it (paragraph 5.13 and the examples after paragraph 5.21, which include a customer signing in to an account). Where the retailer cannot calculate a fully inclusive total, the CMA treats a mandatory charge that varies with factors outside the consumer’s knowledge and control as not permissible, because the consumer cannot work out the total either (paragraph 5.12).
Since 6 April 2026 a trader has also had to make any indication of freight, delivery or postal charges, including any taxes on them, unambiguous, easily identifiable and clearly legible (Price Marking Order 2004, article 7(3), as substituted by the Price Marking (Amendment) Order 2024).
Marketplaces, comparison sites and search engines
The CMA addressed its letter to online marketplaces, comparison sites and search engines as well as to retailers. A trader that promotes another trader’s product to a consumer is engaged in a commercial practice under section 225(3) of the DMCCA, and CMA209 paragraph 2.10 names price comparison sites and marketplace operators as responsible for their own invitations to purchase; the seller may be responsible as well (paragraph 2.11). Where a marketplace lists items that can be bought individually from different sellers, each with its own delivery charge, the CMA’s guidance is that each product’s total price should include that seller’s charge (paragraph 5.4). In one of the CMA’s worked examples, a £10 frame with £2.99 delivery costs £12.99 and an £8 frame with £5.50 delivery costs £13.50, so the product with the lower base price costs more.
A marketplace can show a correct total only if its seller terms require sellers to give it the delivery charge in a form it can add to the product price. Seller terms of that kind are among the platform terms and policies Bratby Law drafts.
Enforcement and penalties under the DMCCA
The CMA enforces section 230 directly, without needing a court order. After a provisional infringement notice, it may give a final infringement notice under section 182 of the DMCCA that directs the trader to comply, and those directions may include enhanced consumer measures such as compensation or other redress (sections 182(4)(a), 183 and 221(2)(a)). The notice may also impose a penalty of up to £300,000 or, if higher, 10% of the trader’s turnover, which includes turnover outside the UK and that of its group (sections 182(6) and 204(1)). The trader may appeal a final infringement notice to the High Court (section 202). The CMA said in its letter that it will continue to monitor pricing across online retail and will take enforcement action if non-compliance continues.
Viewpoint
The total price rule in section 230(4) has applied since 6 April 2025, and since November 2025 the CMA has set out in CMA209 how it applies to delivery charges. In this letter the CMA has given four examples of the presentation it is looking out for, and each can be tested against a retailer’s own product pages, baskets and checkout.
A free delivery threshold changes what a product page must show. Under CMA209 paragraph 5.14, the CMA’s guidance is that the product price should include the full delivery fee until the basket reaches the threshold, so the product page shows a higher figure than a customer who buys more will pay. Paragraph 5.17 lists three ways to present a single charge that covers a whole order: the total beside a base price, a base price with a running total that includes delivery, or product prices that absorb the delivery cost. A retailer that shows product prices without delivery, and relies on the threshold to make that figure accurate for most customers, uses none of them.
Frequently asked questions
Are mandatory delivery fees part of the total price?
Yes. Section 230(4) of the DMCCA defines the total price to include any fees, taxes, charges or other payments the consumer will necessarily incur on buying the product. A delivery charge the consumer cannot avoid, because the retailer offers no free collection or delivery, is one of those charges and must appear in every invitation to purchase, including adverts, product pages and basket totals.
Can a retailer show a product price without delivery?
Yes, alongside the total. Under CMA209 paragraph 5.6 a retailer may show the base price, even as the headline, provided the total price including the mandatory delivery charge is clear, timely and likely to be seen. In its letter of 2 November 2026 the CMA gave showing a product’s price both with and without delivery as an example of compliant presentation.
Does free delivery above a spend threshold change the rule?
No. Under CMA209 paragraph 5.14, a delivery fee waived above a spend threshold can still be calculated, so the CMA’s guidance is that the retailer should include the full fee in the total price until the basket reaches the threshold. It may then remove the fee from the total and tell customers that it will do so.
What can the CMA do if a retailer leaves delivery out of the price?
Under section 182 of the DMCCA the CMA may give a final infringement notice that directs the retailer to comply, which may include enhanced consumer measures such as compensation, and may impose a penalty of up to £300,000 or, if higher, 10% of the retailer’s turnover. The retailer may appeal to the High Court under section 202. The CMA has enforced the drip pricing rules against four businesses, with fines of more than £5.1 million.
For advice on pricing presentation or marketplace seller terms under the DMCCA, contact Rob Bratby at Bratby Law.
This post was researched and drafted with the help of Claude, Anthropic’s AI model. Rob Bratby chose the topic and thesis, and reviewed and edited the final post. Rob takes full responsibility for its content.
