Black Friday 2026 arrives after the Competition and Markets Authority's first full year of fining businesses directly over hidden fees, including a £889,200 fine for StubHub in June 2026 for leaving mandatory charges out of its headline prices, according to Slaughter and May. If your sale prices, delivery charges or booking fees only add up at checkout, you have a few weeks to fix them before late November.
The rules are not new. They took effect under the Digital Markets, Competition and Consumers Act 2024, and the CMA published its price transparency guidance, CMA209, in 2025. What has changed is that fines have now landed, price transparency sits on the CMA's year-two priority list, and peak season is when small shops stack promotions, delivery thresholds and fees on top of each other. This post sets out what counts as a hidden fee, how to check your own site and ads, and what to change this week.
What has the CMA actually done in the last year?
Those figures come from the CMA's own one-year review published on 17 April 2026. The largest single penalty was against the AA, whose driving schools admitted liability and agreed to refund learner drivers. Mayer Brown's August 2026 review describes the issue as a mandatory £3 fee added at checkout.
Since then, more cases have closed. Mayer Brown reports that Marks Electrical was fined £720,000 in June 2026 over a default opt-in affecting nearly 40,000 customers. StubHub settled the same month, with refunds of over £590,000 to 51,350 customers, per Slaughter and May.
Why does this matter more on Black Friday than any other week?
The CMA's guidance treats prices a customer sees on the way to buying as "invitations to purchase", from a search advert to a product card to the basket. A Black Friday campaign multiplies those touchpoints: email banners, Instagram stories, Shopping ads, landing pages. If the base price appears in all of them but a £1.50 packaging fee appears only at payment, every one of those touchpoints is a problem.
The CMA's year-two list also says discount claims must be accurate. Black Friday is the week when "was" prices get the most scrutiny from customers and regulators alike, so a sale price shown against a reference price you never charged is a second risk on top of fees.
What counts as a mandatory fee under the guidance?
CMA209 lists the categories plainly. Mandatory charges include purchase taxes such as VAT, "administration fees, however described, such as booking or processing fees", compulsory cover or service charges at a restaurant, delivery where the customer cannot arrange their own collection, and joining fees for gyms and subscriptions. The guidance adds that a charge is still mandatory even if the customer could avoid it by buying a membership or another product.
There are exceptions. The guidance says card pre-authorisations that are automatically refunded if not used do not count as mandatory charges. Genuinely optional extras, such as paid next-day delivery when standard delivery is free, can be shown separately.
How do delivery charges and free delivery thresholds work?
CMA209 is specific here. Its example of a retailer offering free delivery over £40 says "the trader must include the full delivery fee in the total price until the consumer's basket of products reaches the spend threshold". It also warns that advertising free delivery over a threshold without saying what delivery costs below it may be a misleading omission.
For shops selling several items in one order, the guidance accepts three approaches: show the delivery-inclusive total next to the base price, show the base price with a clear rolling basket total that includes delivery, or build delivery into product prices and offer free delivery. One of its worked examples is a homeware retailer with a flat £5.99 delivery fee, a £25 lamp and £30 plates, where the basket pop-up shows £30.99 and then £60.99.
Do Google Ads and Shopping listings have to show the full price?
This is the part most owners miss, because the ad platform handles the price display. The CMA209 example describes an online clothing retailer that does not offer collection, advertising a dress "in a search engine's results page", and concludes the advert should present the total as £24.50 "because that is the price the consumer would have to pay". Small shops running Shopping or Performance Max campaigns should check how their product feed, shipping settings and any price-led ad copy appear to a UK shopper. If paid search drives a large share of your Black Friday revenue, review your ads alongside the website rather than as a separate job.
Which UK small businesses are most exposed?
Use this if/then check against your own pricing:
- If you add a booking, admin, card or "platform" fee that every customer pays, then move it into the headline price or remove it.
- If delivery is compulsory and the same for every order, then show the delivery-inclusive total on product pages and ads, or offer free delivery and adjust prices.
- If you offer free delivery over a threshold, then state the below-threshold charge next to the offer and keep it in the basket total until the threshold is met.
- If your Christmas party menu carries a compulsory service charge, then quote the per-head price including it.
- If you advertise a job price (a boiler service, a deep clean) and charge a compulsory call-out on top, then advertise the combined figure.
- If a Black Friday banner shows a "was" price, then check it is a price you genuinely charged, and keep the evidence.
- If you sell rolling monthly services, then show the total including any joining fee in the first price the customer sees.
CMA209 still lets you offer discounts after the headline price. It confirms that sale discounts and promo codes that bring the final price below the advertised total are fine. The rule is about what you leave out, not about cutting prices.
What does fixing this cost a typical small shop?
Here is a worked example. A Sheffield candle shop sells a candle at £24, adds a £0.99 packaging fee at checkout, charges £3.95 delivery and offers free delivery over £40. Its Black Friday plan is 25% off.
| Approach | Headline on product page | What a single-candle buyer pays |
|---|---|---|
| Current plan | £18 (25% off £24) | £18 + £0.99 + £3.95 = £22.94 |
| Compliant option A | £22.94 total shown, with £18 base price beside it | £22.94 |
| Compliant option B | Drop the fee, list price £25, sale price £18.75, plus £3.95 shown in the basket total | £22.70 |
Option B costs the shop 24p per single-candle order compared with the current plan. Across 300 Black Friday weekend orders, the hidden £0.99 fee would have raised £297. That is a rough guide to the refund exposure if a regulator later treated every one of those orders as affected, before any fine or staff time. In the StubHub case, refunds of over £590,000 across 51,350 customers work out at more than £11 each. Small sums scale fast once they apply to every order.
There is a conversion argument too. A customer who sees £18 and then £22.94 at payment has a reason to abandon the basket, and those are the shoppers you then pay to win back through abandoned cart emails. Showing the real number earlier is the cheaper route. If you want proof for your own store, a simple price-display test after peak season is a good use of A/B testing for small businesses.
What should UK small businesses do this week?
A practical checklist for the next seven days:
- Do a mystery purchase. On mobile, as a logged-out customer, buy your best-selling Black Friday product. Screenshot every price you see from ad to payment.
- List every fee. Booking, card, packaging, admin, service charge, call-out, joining fee. Mark each one mandatory or genuinely optional using the CMA209 test: can the customer buy without paying it?
- Move or remove mandatory fees. Fold them into product prices, or show the inclusive total at the first price point.
- Fix delivery messaging. State the below-threshold charge next to any free delivery offer, and make sure the basket total includes delivery until the threshold is met.
- Check your ads and feed. Review Shopping and Search ads for single products and make sure the price shown is one a customer can buy at.
- Verify every "was" price. Keep a record of when you last charged it.
- Write it down. A one-page note of what you changed and when shows good faith if anyone asks.
Review practices belong on the same list. The CMA's April review says it sent advisory letters to 54 review-related firms after a sweep, and opened investigations into five companies in March 2026. If you collect reviews around Black Friday orders, follow a written policy, and see how to add reviews to your website without editing or filtering them.
Is this a one-off clean-up or an ongoing job?
The CMA's April review also flags contract terms such as exit fees, and new subscription rules expected in spring 2027. A business that runs a price check before each campaign will meet those changes with a habit already in place. Treat the checkout as a page you optimise, not a page you set once. That mindset is the core of good conversion rate optimisation: every surprise at payment costs sales, whether or not a regulator ever notices.
Black Friday 2026 — FAQ
Does the CMA drip pricing ban apply to small businesses or only big brands?
It applies to any business selling to consumers. The rule sits in the Digital Markets, Competition and Consumers Act 2024, and the CMA's price transparency guidance (CMA209) does not carve out small traders. Its worked examples include a florist and an online clothing retailer, which tells you the regulator expects ordinary small sellers to follow it. The headline enforcement cases so far involve larger firms such as the AA and StubHub, but the CMA also says it sent 157 advisory and warning letters in its first year of direct enforcement. A letter is the most likely first contact for a small business, and fixing your checkout before Black Friday costs far less than fixing it after one arrives.
Can I still offer free delivery over a spend threshold?
Yes. The CMA's guidance says a free delivery threshold, such as free delivery over £40, does not make the delivery charge impossible to calculate. You must include the full delivery fee in the total price until the basket reaches the threshold, then you can drop it. You can tell customers the charge will be removed once they pass the threshold. The guidance also warns that advertising free delivery over a set amount without saying what delivery costs below it may be a misleading omission. So state both numbers clearly, for example free delivery over £40 and £3.95 below it, and make sure the basket total reflects the charge at every step.
Is a card processing or booking fee allowed if I show it at checkout?
Showing it only at checkout is the problem. CMA209 lists administration fees, however described, including booking or processing fees, as mandatory charges that belong in the total price. A charge does not become optional because you present it separately or call it an extra. If every customer has to pay it to complete the purchase, it must be in the price from the first time you show one. The simplest fix for most small businesses is to remove the separate fee and build the cost into the product or service price. That keeps your margin, removes the surprise at payment and takes the compliance question off the table.
Do my Google Shopping and Search ads need to show the total price?
If the ad is for a specific product and delivery is mandatory, the CMA's guidance suggests yes. Its own example describes a £20 dress advertised on a search engine results page by a retailer with a £4.50 minimum delivery charge and no collection option, and says the advert should show £24.50. For a small shop running Shopping ads, this means checking how your feed and shipping settings present price, and whether your ad text quotes a base price that a customer cannot buy at. If you offer free collection or free standard delivery, the base price may already be the total, which is the cleanest position to be in.
What happens if the CMA finds a breach?
Under its direct enforcement powers, the CMA can decide a business has broken consumer law and fine it without going to court. Fines can reach 10% of global turnover. In practice, the cases so far pair a fine with refunds. Slaughter and May reports that StubHub was fined £889,200 and agreed refunds of over £590,000 to 51,350 customers. For a small business, the refund element is the part to model, because it scales with how many orders carried the hidden fee during the period under review. A modest fee on every order can add up to a meaningful sum once it is multiplied across a busy trading season.
