In August 2026 the Competition and Markets Authority opened investigations into Trainline, Virgin Atlantic and RED Driving School over drip pricing: advertising one price, then adding an unavoidable fee before the customer can pay. These are investigations, not findings, and none of the three has been found to have broken the law.
Every law firm client alert and compliance vendor circulating a "DMCC readiness" checklist is telling advertisers the same thing: this is a disclosure problem for the legal team. That is the expensive misread. For any business buying paid search or Shopping clicks, drip pricing is first a media leak: you pay Google or Microsoft for a click on the price you advertised, and when a compulsory fee appears at checkout the customer walks, so you carry the full media cost and take none of the revenue. Fix the advertised price so it holds all the way to the till and the breach disappears as a by-product of plugging that leak. Route it to compliance alone and you stay legal while still paying for clicks you cannot convert.
Drip pricing drains paid media long before it risks a fine
The compliance-first advice is "show all the fees." It is not wrong, but it sizes the problem wrongly. The consumer rules under the DMCC Act 2024 took effect on 6 April 2025, and under the CMA's unfair commercial practices guidance a fee a customer cannot avoid should sit in the advertised headline price from the start. Genuinely optional extras can still be added later. Under Part 3 of the Act the CMA can impose penalties of up to 10% of global annual turnover on a business, and up to £300,000 on the individuals responsible, directly rather than through the courts.
For most advertisers the fine is the smaller number. When you pay Google or Microsoft for a visit, you buy a customer who believes the figure in your Shopping feed, your ad copy and your landing page. If a compulsory fee then appears at the payment screen, you have already bought that click and the person leaves. Across the paid media accounts we track in the Crane Index, this leak does not read as a broken campaign. Impressions hold, clicks hold, the dashboard looks healthy. The loss concentrates at the final step, in baskets you paid to fill and then lost to a price you could have shown from the start. It hides in checkout-step abandonment, not in landing-page bounce, which is why it survives most reporting.
Smart Bidding learns the wrong lesson from a checkout price jump
Google's Smart Bidding uses machine learning to optimise toward the customers who convert, reading conversion data at auction time. When a price jump at checkout sends paid clicks away empty-handed, those visitors are logged as non-converting traffic. The system then pulls bids and reach away from the very queries and audiences that would have converted at an honest price. So a drip at the final step does not just lose one basket. It teaches the algorithm to stop chasing your best customers, and the account narrows over time even though nothing in the campaign settings changed.
A feed price mismatch throttles free and paid Shopping
Google Merchant Center's price accuracy policy requires the product price in your feed to match the price on the landing page and at checkout. Google verifies this by crawling your pages and reading the price from your product markup and the Content API feed, not from a booking screen. A mismatch triggers product disapproval, which pulls the listing from both free and paid Shopping. Note the scope: this compares the product price, carried by the feed's price attribute. Delivery is separate, carried by the shipping attribute, and is not what the crawl compares.
Delivery and tax vary by destination, so split the fixed price from the stated fee
Here is the objection a sharp operator raises: shipping and tax change by location, so how can the headline price ever be one fixed number? Keep two things apart. The product price is a single figure, VAT included for consumers, and it should match across ad, feed and checkout. Delivery counts as an unavoidable fee under the DMCC only where the customer must pay it, and where it genuinely varies you state clearly how it is calculated rather than saving it for the end. Merchant Center already models this split: product price in the price attribute, delivery in the shipping attribute. The compliant structure and the technical structure line up. What breaks both is a surprise, not a variable.
Three questions find the leak before the regulator does
You do not need to run the checkout yourself. Ask for a plain answer to each:
- Does the number in our ads and feed match the product price at the till?
- Are compulsory fees ever revealed only at the final step?
- Is checkout-step abandonment materially higher than landing-page bounce, meaning we win the click and then lose the sale to a total the customer never saw coming?
Where an answer is uncomfortable, you have found a leak you are paying to fill. Most pricing problems in a paid account are not strategy. They are honesty of presentation, and they cost you at the auction long before they cost you at the tribunal.
