UK Tightens Scrutiny of Hidden Fees in the Travel Sector

Travel companies in the UK are now under stricter regulatory scrutiny regarding how "complete" the prices they show to customers are.

The Competition and Markets Authority (CMA) launched two separate consumer law investigations into Virgin Atlantic and Trainline on August 18, 2026. The central question in both cases is: Does the customer see the actual total price they must pay at the beginning of the purchasing process?

This question is directly significant for hospitality. Because items such as resort fees, mandatory facility charges, local taxes, or booking fees added later to the reservation price are not only a matter of customer experience in the UK market but now also a serious area of legal risk.

Investigating resort fees and local taxes in the Virgin Atlantic Holidays case

The CMA's investigation into Virgin Atlantic covers the company's package holiday sales.

According to the authority, the investigation focuses on whether unavoidable fees such as resort fees and local taxes are included in the total price shown at the very beginning of the purchasing process. The CMA will also investigate whether the true total cost of the package holiday is clearly presented to the customer.

According to Skift, such additional items can add hundreds of pounds to the total cost of some holidays.

The critical point here is not whether the fee is collected by the hotel or another third party. If the customer cannot purchase the service without paying this fee, the price presentation must be made accordingly.

However, the CMA has not yet determined that Virgin Atlantic has violated the law. The investigation is in the information and evidence-gathering phase, with the first update planned for January 2027.

Trainline's booking fees are also under investigation

The separate case regarding Trainline examines how mandatory fees applied when purchasing train and bus tickets are presented.

The CMA will investigate whether these fees are included in the total price seen by the consumer at the beginning of the purchasing process.

Skift reports that Trainline charges up to £2.79 for train booking fees and £1.50 for bus transactions on some tickets. Since these fees are a revenue stream for the company, the case is commercially different from the third-party resort fee or tax discussions at Virgin Atlantic.

Again, this investigation does not imply a violation decision.

What exactly is "drip pricing"?

The term "drip pricing" used by the CMA refers to showing the customer a low initial price while unavoidable additional fees emerge later in the purchasing process.

According to the UK's current price transparency guidance, the fees, taxes, and other mandatory costs that the consumer must pay should be included in the initial total price.

In cases where the customer cannot actually purchase a product or service at the stated price, adding the mandatory fee later may be illegal.

This regulation was clarified with the new consumer provisions under the Digital Markets, Competition and Consumers Act, which came into effect on April 6, 2025. The law prohibits the practice of "drip pricing," which excludes unavoidable fees from the total price.

Not every additional fee is prohibited

This regulation should not be interpreted as "hotels or airlines can no longer sell extra services."

Services that the customer can genuinely choose to opt for can be priced separately.

For example, additional baggage, optional seat selection, spa services, paid transfers, or optional food and beverage packages can be separate additional products depending on the basic conditions of the reservation.

The critical distinction is whether the customer is obligated to pay that fee to complete the purchase.

The focus of the CMA guidance is to prevent unavoidable fees from appearing later.

The resort fee model is becoming riskier for hotels

Especially in the US hotel market, the resort fee model may create new compliance issues for tour operators and booking platforms selling from the UK.

If a hotel presents a room price of £200 per night and also charges a mandatory £40 resort fee, it could pose legal risks for an intermediary selling to UK customers if they only highlight the £200 fee.

This is a different issue from changes in the pricing system in the hotel's own country.

Travel platforms selling to customers in the UK are expected to accurately show the unavoidable total cost of the product sold.

Therefore, it may no longer be sufficient for hotels to provide price data to OTAs, tour operators, and package holiday partners that consists only of the room rate.

Indirectly affects hotels in Turkey as well

Although the regulation pertains to UK consumer law, it has indirect effects for hotels in Turkey that receive bookings from the UK.

Especially, hotels working with UK tour operators, OTAs, or package holiday companies need to clearly communicate which fees are mandatory to their partners.

If there is a service charge, mandatory facility fee, or another cost that is an integral part of the reservation, it is crucial to define this correctly in the sales systems.

Otherwise, while the hotel may believe it has provided its price correctly, the total price presented to the customer by the intermediary platform may be incomplete.

Thus, price transparency becomes a shared concern not only for the legal or marketing department but also for revenue management, distribution, reservations, finance, and contract management.

The CMA can now impose heavy penalties directly

One of the most important aspects of the new regime for the industry is its enforcement power.

If the CMA determines that consumer law has been violated, it can now impose penalties directly without having to go to court in every case.

In cases of price transparency violations, a company can face fines of up to 10% of its global annual revenue or up to £300,000 — whichever is higher. Compensation for consumer harm may also be sought.

This is not merely a theoretical power, as seen in 2026.

The CMA fined StubHub UK approximately £889,200 for not including mandatory fees in the starting price and ordered refunds totaling over £590,000 to more than 50,000 customers.

In April, AA and BSM driving schools received a £4.2 million fine due to similar drip pricing practices, and refunds were requested for over 80,000 customers.

The message to travel companies is therefore quite clear: price presentation is now not just a UX design issue but a compliance matter that could lead to financial penalties.

What points should businesses check?

Hotels and travel businesses selling in the UK market need to review the following areas in their booking flow:

• Is the price shown in the initial search result truly the unavoidable total cost?

• Are taxes and mandatory facility fees included at the initial stage?

• If a "From" price is used, is there an option available for the customer to actually purchase at that price?

• Are the fee codes between the booking engine and PMS/CRS the same?

• Does the rate feed sent to OTAs and tour operators include all mandatory fees?

• Are new mandatory items being added to the price shown at the payment screen?

• Is the optional service clearly separated from the mandatory fee in the system?

This check is particularly important for hotels using multiple channels. Even if the price on the hotel's own site is correct, missing fee mapping in OTA or tour operator integration could show the customer a different total.

Stafflink's View

In our opinion, the most significant outcome of the hidden fee scrutiny in the UK for HORECA is that pricing and distribution technology can no longer be managed separately.

Hotel management may say, "Our room price is correct"; however, if the resort fee, tax, or mandatory service charge is not accurately communicated to the booking engine, OTA channel, or tour operator, the customer may still see an incomplete price.

Therefore, price transparency is not just a control that can be left to the legal department. Revenue management must define which fees are mandatory, the technology team must process this correctly in the system, sales channels must show the correct price, and the finance team must compare collections with the price on the screen.

For hotels and tourism companies serving British guests in Turkey, the lesson is clear: systems that allow the customer to see the true cost at the moment of the first price comparison, rather than at the last step, will increasingly become a legal obligation as well as a competitive advantage.