The Competition and Markets Authority (CMA) published an open letter to online retailers on Monday 2 November. The message is simple: if delivery is mandatory, its cost must be included in the price shown to the customer – in advertising, on the product page, in the basket and at checkout. The regulator issued the reminder ahead of the Christmas shopping season and says it will keep monitoring the sector.
What the regulator said
The CMA says some businesses still present delivery charges in a way that does not comply with the law. The legal basis is the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) and the CMA’s price transparency guidance (CMA209), published in November 2025.
Key points from the letter:
- When a retailer gives a price, it must be the total price, including mandatory delivery and any other unavoidable fees.
- The total price must appear at every stage: advertising, product pages, baskets and checkout. A breakdown – for example, price with and without delivery – is allowed.
- If delivery is optional, customers must be told so clearly from the start. This must not be hidden behind separate pages, drop-down menus or pop-ups.
- Marketplaces and comparison sites must include each product’s delivery charge in its total price.
The CMA also lists practices it is watching for: product prices shown without mandatory delivery, basket totals without delivery, and delivery information given only late in checkout.
Fines are already being imposed
According to the letter, the CMA has already taken action against four businesses over drip pricing, with fines totalling more than £5.1 million and over £1.35 million refunded to consumers. In one case, Marks Electrical agreed in June 2026 to pay £720,000 and refund customers who had been automatically opted in to extra services.
Since 6 April 2025 the CMA has been able to fine businesses directly for breaching consumer law, without going to court. According to law firm CMS, penalties can reach up to 10% of annual global turnover.
What it means for Polish businesses in the UK
Many Polish online shops operate in the UK, selling food, cosmetics, books and car parts, some via marketplaces. For them, the letter is a practical checklist before December.
Our view: small shops that add a flat delivery fee only in the basket are most exposed. That model was long standard practice. Under the guidance the CMA refers to, a small-print “+ delivery” note is no longer enough.
The evidence: the CMA says that with a flat basket delivery charge, retailers should show the product price including mandatory delivery throughout the shopping process – for example by automatically displaying the price both with and without delivery.
What to check now:
- does the product page show the price including mandatory delivery;
- do the basket and order summary include delivery;
- is information about optional charges hidden away under a “Delivery” tab;
- do social media adverts give the total price.
The rules apply to businesses selling to consumers in the UK, so a Polish company shipping to UK customers should also review its website. If in doubt, seek advice from a lawyer familiar with UK consumer law.
And for shoppers?
For buyers this is good news. Where delivery is mandatory, the price shown at the start should be the price you pay. If a shop adds it only at checkout, this can be reported. The rules have applied since April 2025, and the CMA now says it will enforce them during the Christmas peak too.
Sources:
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