Designing Transparent Pricing Journeys Practical steps for retailers under CMA scrutiny

Most online shoppers know the feeling. After investing time in finding the right product, flight or hotel at a fair price, you advance to the next screen only to watch the price jump. What felt like a great deal suddenly leaves you questioning whether you've been misled. mIt's customer experiences exactly like these that the Competition and Markets Authority (CMA) is now investigating across a range of UK retail sectors, backed by the Digital Markets, Competition and Consumers Act 2024. Investigations are zeroing in on tactics such as drip pricing, artificial scarcity claims and other pressure-selling tactics.

If the threat of a fine up to 10% of global turnover doesn't spur action, the hidden commercial costs should. An 'always on' countdown timer or a small service fee may feel like minor adjustments from the retailer's perspective. But for customers, it triggers a sense that something isn't quite right and pushes the brain out of buying mode and into risk assessment. From there, trust begins to fall away. The recent CMA crackdown is both a regulatory wake-up call and an opportunity to turn transparency into a tool to strengthen customer trust. It starts with a few practical changes to how pricing is structured and surfaced.

Remove hidden fees and reveal the real price early
Drip pricing is where unavoidable fees are revealed late in the purchase journey. It's both a regulatory misstep and it disrupts the customer's initial sense of what the price should be, triggering distrust and higher abandonment.

Instead, surface all unavoidable fees upfront. If a fee is mandatory, it should never appear as a surprise or be positioned as an optional add-on. Showing delivery fees, service charges, or other surcharges up front reduces friction later in the journey.

Aim for price consistency across every step. We've worked with retailers who were unintentionally showing different prices at different points in the journey, creating confusion they never intended. The closer the first price – and every price that follows – is to the final price paid, the more trustworthy the experience feels.

Consider this your reminder to run through your entire pricing journey end to end. Watch for anything inconsistent, unclear or unexpected that appears at the last moment. Better yet, speak directly with customers. Interviews often reveal friction points that back-end teams simply don't see.

Rethink false urgency and scarcity messaging
Countdown timers that are always on and messages like "Only 2 left in stock – order now!" that appear regardless of actual stock levels are two examples of practices that fall squarely into misleading pressure selling. Of course, these are prohibited by the CMA.

These tactics may create short-term nudges to buy, but they quickly erode trust once shoppers realise the urgency isn't real. Always-on discounting has the same effect: it undermines your brand's value and trains customers to wait for a deal rather than trust your everyday price.

Instead, use scarcity only when stock levels validate it and shift to a strategic discounting calendar. Align urgency with genuine deadlines and make the fine print of the offer easy to find and understand. Some retailers, like Shutterfly, publish a single promotions page that outlines every current offer in plain language. It's a simple design choice that signals transparency and builds trust.

Audit the urgency signals customers see across their buying journey. Look for timers that never expire, scarcity messages that don't reflect real stock levels, or promotions that appear time-limited but run indefinitely.

Fix the root cause: fragmented pricing ownership
While some of the tactics under CMA scrutiny are undoubtedly deliberate, many of the issues we see when working with both local and global businesses aren't driven by malicious intent. They stem from fragmented ownership of pricing across teams. For many retailers, pricing is fragmented. Marketing owns promotions, e-commerce owns the interface, finance owns the margin, and legal owns the terms. Nobody owns the end-to-end customer pricing journey.

The fix is clearer ownership. Retailers need someone with the mandate to look across the entire pricing journey – from the first price a customer sees to the final price they pay – and ensure it hangs together. This individual is accountable not just for margin or promotions, but for coherence, clarity, and fairness of pricing. We call this a Pricing Champion: a senior leader who aligns marketing, trading, e-commerce, finance, and legal teams and acts as the customer's advocate within the organisation.

Without a Pricing Champion, even well-intentioned teams introduce friction in the purchase journey they never meant to create. With it, retailers build the internal muscle to keep pricing transparent and compliant.

The CMA has already forced the industry to act, issuing notices to 100 businesses across 14 sectors. But the opportunity goes far beyond compliance. Retailers that redesign their pricing journeys for transparency now can avoid hefty fines and build brands that customers trust, return to, and recommend.

Ann Padley and Jenny Millar lead Untapped Pricing, a consultancy trusted by leadership teams and investors worldwide to sharpen positioning, unlock profit, and accelerate growth through pricing. They are also the co-authors of The Pricing Sprint, to be published by Bloomsbury in May 2026.