Since receiving new powers under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), the UK Competition and Markets Authority (CMA) has pursued an aggressive consumer protection agenda. As previously reported, this began with a series of pricing investigations launched in November 2025, the first of which concluded in April 2026.

The initial investigations have focused on unlawful pricing practices and in particular “drip-pricing.” This practice, which is explicitly identified as unlawful under the DMCCA, involves disclosing mandatory fees (such as booking and delivery fees) late in a payment process.

On June 11, 2026, the CMA announced an investigation into Ryanair’s pricing practices and the extent to which the airline’s terms and conditions created unlawful mandatory charges payable by parents traveling with children under the age of 11. Before the investigation could begin in earnest, Ryanair announced a policy change allowing parents to sit next to their children without paying a seat reservation fee. The change delivered immediate, tangible relief for consumers while the CMA’s investigation continues.

On June 18, 2026, the CMA announced a negotiated settlement with Marks Electrical resolving allegations that the company automatically opted consumers into voluntary charges. Marks Electrical was fined £720,000 (approximately $950,000) and ordered to refund impacted customers £600,000 (approximately $800,000).

Finally, on June 23, 2026, the CMA also imposed a £900,000 (approximately $1.2 million) fine on StubHub UK and ordered the company to repay customers over £590,000 (approximately $780,000) in hidden fees.

Following these decisions, the CMA has concluded by way of negotiated settlements four of the eight pricing investigations launched in November 2025.

In this alert, we provide a brief update on each of these investigations and highlight the key considerations for businesses to ensure compliance with UK consumer protection rules.

Ryanair

The CMA is investigating the extent to which Ryanair’s terms and conditions in effect require parents to pay additional charges and are therefore unfair and unlawful. In particular, the CMA has identified that:

• Ryanair’s terms and conditions require at least one parent to be seated with children aged between 2-11, but its automatic seat allocation process does not group travelers on the same booking in adjacent seats unless they have paid for assigned seating.
• In practice, parents are therefore required to book a “mandatory family seat” through Ryanair’s standard seat selection process and incur an additional charge of between £4 and £12 per flight.
• Such charges are payable on the majority of Ryanair flights, but, following action from the Italian Civil Aviation Authority, Ryanair was prohibited from applying such charges on all flights departing from or arriving at Italian airports.

The CMA will consider whether Ryanair’s terms and conditions requiring parents to purchase a mandatory family seat are unfair. This is likely to take into account why such a system is required and whether alternative means could be used to ensure that children are seated with their parents.

The CMA will also consider whether the existence of this de facto mandatory charge for passengers traveling with children is fully and appropriately included in the headline price for travel itineraries including children.

On June 25, 2026, although Ryanair had publicly expressed its intention to defend the policy, it announced a policy change allowing parents to sit next to their children without paying a seat reservation fee. The CMA will actively monitor the effectiveness of that change and indicated that it will continue its investigation to seek redress for customers harmed by the original policy. This is consistent with the CMA’s approach in previously resolved cases where, notwithstanding the businesses concerned taking steps to quickly resolve the CMA’s concerns, the CMA has used its power to pursue sanctions and order consumer redress.

Pricing Investigations into Marks Electrical and StubHub UK

This month, the CMA has also demonstrated its ability to progress consumer protection cases at pace, concluding two further investigations into online sales tactics and “drip-pricing.”

Marks Electrical

The CMA fined Marks Electrical £720,000 (approximately $950,000) and ordered the company to refund customers impacted by its online sales practices £600,000 (approximately $800,000). The CMA found that Marks Electrical had infringed UK consumer protection law by automatically opting consumers into receive optional services, including “Recycle Old Appliance” services and “Unwrap & Recycle Packaging.”

UK consumer protection laws require customers to have a genuine choice as to whether to pay for optional products or services. In practice, this means that businesses must:

• Provide clear information about the available extras; and
• Obtain express consent from consumers for any add-on services.

CMA guidance is clear that requiring customers to take any active step to opt out of an additional service does not amount to express consent, thereby breaching UK consumer law.

StubHub UK

The CMA found that StubHub UK breached its obligation to display the full price upfront and had instead engaged in unlawful “drip-pricing.” StubHub UK was fined £900,000 (approximately $1.2 million) and ordered to issue refunds exceeding £590,000 (approximately $780,000).

These are the CMA’s second and third decisions following the launch of a series of pricing probes in November 2025 and, like its first decision (see here), were concluded by way of settlement. In return for the admission of guilt, Marks Electrical and StubHub UK each received a 40 percent reduction to their financial penalty.

Both companies will also be required to contact affected customers and refund them for any optional services provided or hidden fees issued during the relevant period. Impacted customers do not need to take any action and will be contacted by the respective companies to arrange a refund.

Takeaways for Business

The CMA remains committed to exercising its consumer protection powers. The initiation of the case against Ryanair sees the CMA continue to pursue its consumer protection agenda, taking on high-profile businesses as it seeks to use its new powers under the DMCCA to drive improved consumer outcomes.

Not only does the Ryanair case demonstrate the CMA’s willingness to extend its enforcement agenda to larger international companies active in the UK, it also illustrates the CMA’s intention to look beyond the explicit conduct and consider the de facto effects of the conduct in question. Businesses therefore need to consider not only whether their payment journeys in isolation give rise to unlawful pricing practices but also whether, when coupled with their commercial contract terms, they have the effect of making additional charges unavoidable, and therefore risk facing scrutiny from the CMA.

As discussed in more detail in our recent alert, businesses must take steps to ensure their practices remain compliant with the UK’s evolving consumer protection landscape.

For more information, please contact Deirdre Carroll, Andrew Morrison, Tom Evans, or any member of the firm’s Antitrust and Competition or Data, Privacy, and Cybersecurity practices.