On April 15, 2026, the UK Competition and Markets Authority (CMA) issued a Final Infringement Notice to two major UK driving-school businesses owned by British motoring association, the AA. The notice—which was issued following a settlement with the AA—marks the CMA’s first direct enforcement action for a substantive breach of consumer law under the UK’s new enforcement regime. The investigation, opened in November 2025, concluded swiftly. The CMA ordered the AA to refund more than £760,000 (approximately $1 million) to its customers and pay a fine of £4.2 million (approximately $5.7 million) for “drip” pricing practices, representing the first use of the CMA’s new powers to impose direct fines and order consumer redress for breaches of UK consumer law.

Background: The Digital Markets Competition and Consumer Act (DMCCA) Powers and the CMA’s Focus on Pricing Practices

Since the direct consumer enforcement regime under the DMCCA came into force in April 2025, the CMA can impose sanctions for breaches of consumer law without going through the courts, including fines of up to 10 percent of global turnover and ordering consumer redress.

In November 2025, the CMA launched a major consumer protection initiative targeting online pricing and “pressure-selling” practices, opening investigations into eight businesses across four sectors and sending advisory letters to 100 businesses across 14 sectors (see Wilson Sonsini Alert here). The CMA built on this by opening further investigations into misleading advertising and unfair subscription terms and has also shown a willingness to use the DMCCA’s procedural powers to address non-cooperation by businesses under investigation, fining Euro Car Parks £473,000 (approximately $645,000) for failing to comply with an information notice (see Wilson Sonsini Alert here).

The CMA has made championing consumers through effective use of its new consumer protection powers a core objective of its 2026-2027 Annual Plan, with the CMA targeting what it considers the most egregious practices, such as drip pricing, fake reviews, and pressure selling.

The AA Decision

The CMA found that learners who booked lessons with the AA online between April and December 2025 were not shown the full price upfront; instead, a mandatory £3 booking fee was added later in the purchase journey.

The DMCCA explicitly requires businesses to include all known mandatory fees in the initial advertised price. The CMA therefore found that the AA’s inclusion of additional booking fees was in breach of UK consumer law, fining the business £4.2 million (approximately $5.7 million) and ordering it to refund 80,000-plus customers over £760,000 (approximately $1 million).

Takeaways for Businesses

  • Mandatory fees must be included in the initial price.
    The compliance message is clear: where a fee is unavoidable—such as a booking or processing charge—it must be included in the headline price from the outset. Businesses must be careful to ensure that all mandatory fees are included in the headline prices and only genuinely voluntary fees are added during the check-out process.
  • Engagement and settlement materially shape outcomes.
    While more detail has not yet been published, it appears that the AA engaged cooperatively with the CMA, including by bringing the conduct to an end in December 2025. This engagement, together with the business admitting breaking the law and settling the case led to a swift resolution of the investigation in just under five months and a 40 percent early-settlement discount, reducing the penalty from an initial £7 million (approximately $9.5 million). Today’s decision therefore illustrates the CMA’s willingness to reward early cooperation and settlements through swift resolution and meaningful reductions in penalties.
  • Online pricing practices remain a top enforcement priority.
    Government research cited by the CMA suggests that nearly half of online businesses use hidden or dripped fees, with these practices estimated to cost UK consumers £3.5 billion (approximately $4.7 billion) annually. Against that backdrop and with the CMA’s enforcement focused on key consumer spending sectors, the AA decision reinforces that online sales practices obscuring the true cost of products or services will remain a core CMA priority.
  • Businesses must ensure consumer protection is built into compliance activities.
    Businesses selling to UK consumers should:
    • review online customer journeys end-to-end to ensure all unavoidable charges are included in headline prices and any optional extras are clearly identified;
    • align internal policies and user experience design with the CMA’s pricing guidance and consumer law; and
    • integrate consumer law risk more fully into broader compliance frameworks.

With two consumer protection decisions already this year, the CMA has made clear that it is prepared to use its new powers decisively—both to penalize non-cooperation and to impose fines and consumer redress for infringements. Where they haven’t already, businesses are advised to ensure that their business practices comply with the CMA’s pricing and fake reviews guidance, and to prepare for implementing stricter rules on subscription renewals and cooling-off rights, which are expected later this year.

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