Mandatory fees need to be built into the pricing architecture
The CMA is investigating whether Trainline’s mandatory fees were hidden from the headline price. No finding has been made, but the enforcement pattern now applies well beyond travel.
The CMA has opened an investigation into whether Trainline includes mandatory fees in the total price shown at the beginning of the purchase process. No infringement finding has been made, but the case is a live enforcement signal for pricing design.
What the CMA is actually investigating
Whether charges every customer has to pay were included in the price shown at the start.
The Competition and Markets Authority opened a formal investigation into Trainline, published 19 August 2026, examining whether mandatory fees are properly included in the total price displayed at the beginning of the purchase process.
The CMA observed fees ranging from 59 pence to 2.79 pounds on advance train bookings made through Trainline’s app and website, and a 1.50 pound fee on coach bookings.
This followed earlier warnings to the firm that had not resolved the CMA’s concerns, which is why it escalated to a formal investigation.
What has and has not been decided
The investigation is open. Trainline says it has engaged with the CMA and is adjusting fee presentation.
No infringement has been established. Trainline has stated it proactively engaged with the CMA over several months and is taking steps to enhance how certain fees are presented.
The exposure that matters here is not a finding against Trainline specifically. It is the enforcement pattern: drip pricing is now an active investigation target, not a theoretical risk.
If the CMA finds against a business on drip pricing, it can order compensation and fine up to 10 percent of global turnover, without a court finding the infringement first.
Why this reaches well beyond travel
A mandatory fee revealed partway through checkout is the practice under scrutiny, not the industry.
Drip pricing is not specific to ticketing. Any consumer-facing platform that charges a mandatory fee, a service charge, a platform fee, compulsory insurance, and does not include it in the price shown before the customer starts buying, sits inside the same enforcement logic.
SaaS and subscription businesses with mandatory add-on charges at checkout should read this investigation as directly relevant, not adjacent.
What to actually check on your own checkout
Every fee every customer must pay needs to be visible before the purchase journey starts.
Walk your own purchase journey as a customer would and note every charge that is mandatory, not optional, then check whether it appears in the price shown at the very start or only later in the flow.
Anything mandatory that only appears at a later step is exactly the pattern under CMA scrutiny right now.
- List every mandatory charge across advertisements, the purchase journey and your customer terms.
- Check where each one first appears, at the headline price or buried in checkout.
- Assess margins using the price the customer actually ends up paying, not the advertised one.
- Fix the display first, since that is cheaper than an enforcement investigation.
What resellers and marketplace agreements should say
A marketplace showing an incomplete price is a shared risk unless the contract says otherwise.
If you sell through a reseller, marketplace, or payment provider, your agreement should allocate responsibility for accurate price feeds and for communicating fee changes, so an incomplete price displayed by a third party does not become your unmanaged exposure.
This matters as much for the platform showing the price as for the business setting it, since both can be inside the CMA’s enforcement scope depending on who controlled what the customer actually saw.
Questions this raises
Six questions the Trainline investigation tends to prompt, answered directly.
What is the CMA actually investigating Trainline for?
Whether Trainline includes mandatory fees, such as booking charges, in the total price shown to customers at the start of the purchase process, or whether those fees are separated out or added later, a practice known as drip pricing. The formal investigation was published 19 August 2026.
Has the CMA found Trainline broke the law?
No infringement finding has been made. The CMA observed fees ranging from 59 pence to 2.79 pounds on advance train bookings, and 1.50 pounds on coach bookings, and is examining whether those were properly reflected in the headline price.
What happens if the CMA finds against a business in a case like this?
The CMA can order compensation to affected customers and impose fines of up to 10 percent of global turnover, without needing a court to establish the infringement first.
Does this only affect travel and ticketing businesses?
No. Drip pricing is a general pattern, any mandatory charge not reflected in the price a customer sees before starting to buy. Any consumer-facing platform with mandatory fees applied during checkout is inside the same enforcement logic.
What should we check on our own pricing pages?
Whether any charge that every customer must pay, platform fees, service charges, mandatory insurance, is included in the price shown before the customer begins the purchase journey, not revealed partway through checkout.
What should our contracts with resellers or marketplaces say about pricing?
They should allocate responsibility for accurate price feeds and for how fee changes are communicated and reflected, so a marketplace displaying an incomplete price is not left as the seller’s unmanaged liability.
Sources
- Competition and Markets Authority, Trainline consumer protection investigation, published 19 August 2026.
- GOV.UK, Trainline consumer protection enforcement case.
Selling to consumers with mandatory checkout fees?
Eliga provides embedded commercial and technology counsel to scaling businesses. We can review your pricing display and marketplace agreements against the CMA’s current enforcement focus before it becomes your investigation.
This page is general information about commercial law and technology. It is not legal advice and does not create a solicitor-client relationship. Take specific advice on anything you are about to negotiate or sign.