On 15 April 2026, the Competition and Markets Authority (CMA) issued its first ever financial penalty under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), fining Automobile Association Developments Limited (trading as AA and BSM) £7 million (reduced to £4.2 million under a settlement agreement) for hidden booking fees on driving lesson bookings.

The CMA has now published its Final Infringement Notice in the case, which sets out important detail about the methodology it will apply when calculating penalties under the new regime.

Between April and December 2025, customers booking driving lessons on the AA and BSM websites were shown a headline price that excluded a mandatory £3 booking fee. The fee — which could amount to up to 12% of the price of a single one-hour top-up lesson — was only added to the total at the final payment page, after consumers had selected their lessons and entered their personal details. Approximately 90,000 consumers were affected, paying around £800,000 in undisclosed fees in total.

The CMA opened its investigation in November 2025 and issued a Provisional Infringement Notice in March 2026. The AA settled in April 2026, admitting the breach, agreeing to refund affected consumers, and accepting a 40% settlement discount on what would otherwise have been a £7 million penalty.

Drip pricing is only one of the CMA’s current consumer protection priorities. Its public statements and ongoing investigations span fake or misleading reviews, urgency and scarcity claims, hidden terms and pressure selling, and unfair contract terms more generally.

The DMCCA gives the CMA a single toolkit — directions, redress, and very substantial fines — to tackle all of these. As such, the principles that drove the AA outcome will apply across the board.

• The CMA will use its new powers robustly and at pace. The AA case shows the CMA is willing to open an investigation, issue an infringement notice and impose a multi-million pound fine on facts that previously would have required court action. Businesses should expect the same approach to be taken in respect of any practice the CMA considers harms consumers — not only drip pricing.
• Customer-facing information must be complete and clear at every step. The AA infringement turned on the omission of material information from each “invitation to purchase”. The same logic applies wherever the DMCCA requires information to be given clearly, prominently and in good time — for example pre-contract information, cancellation rights, and the basis of consumer reviews. Fixing the position only at the final stage of the journey will not be enough.
• Penalties are calculated against group turnover. The CMA based its starting point on the consolidated UK turnover of the parent company (£1.45 billion), not the smaller revenue of the infringing subsidiary. The starting point was 15% of that figure — over £217 million — before being reduced for proportionality. Even with a 97% downward proportionality adjustment, a 5% co-operation discount and a 40% settlement discount, the final penalty was £4.2 million. The statutory cap is 10% of worldwide group turnover.
• Published CMA guidance counts as a warning. The CMA placed the AA in the “high culpability” category because relevant guidance had been published before the conduct began. The CMA does not need to show deliberate intent — being on notice through any published CMA guidance is enough. The same logic will apply to the CMA’s guidance on fake reviews, unfair contract terms and other consumer law topics.
• Co-operation and rapid remediation pay off. The AA secured a 5% mitigation for co-operation (volunteering information and answering follow-ups quickly) and a 40% settlement discount for early admission and an expedited process. It also began fixing the customer journey within days of the investigation opening, which the CMA expressly took into account in its proportionality assessment.
• Redress sits alongside the fine. The AA must refund every affected consumer the booking fee they paid, by automated card refund where possible and by cheque otherwise, and donate any uncashed cheque amounts to charity. Reporting obligations to the CMA continue for a year. Enforcement is therefore not just about the headline penalty number.
• A warning shot — but penalties will rise. The CMA noted that fines in the early period of the regime are likely to be lower because infringing conduct can only be penalised from the DMCCA’s commencement date, so durations are necessarily short. Penalties for infringements of any consumer law provision within the DMCCA regime should be expected to be materially higher in future cases.

To reduce the risk of similar enforcement action across any area of consumer law, businesses should consider:

• Carry out widespread consumer law audits. Pricing displays are an obvious starting point, but the same exercise should be applied to online reviews, urgency and scarcity messaging, terms and conditions, and any pre-contract disclosures.
• Track CMA guidance across all consumer law topics. When the CMA publishes guidance on any practice, treat it as the date by which compliance changes must be implemented — waiting risks a “high culpability” finding.
• Keep records that support a co-operation case. Document internal compliance reviews, sign-offs on price displays and any steps taken to remediate quickly, so that mitigation can be evidenced if the CMA does come knocking.
• Plan an investigation response now. Have a playbook in place covering early engagement with the CMA, settlement decision-making and the operational ability to issue mass consumer refunds — the AA had to refund roughly 90,000 customers within 120 days.
• Think at group level. Penalties are calculated by reference to consolidated group UK turnover, so even a relatively small business unit can expose a much larger corporate group to a significant fine.

The AA case is the CMA’s opening move under the DMCCA — and the methodology it’s set out will apply equally to its future investigations, whether the target is drip pricing, fake reviews, unfair terms, or anything else on its agenda.

The CMA’s new direct enforcement powers are very much live, the appetite for robust enforcement is clear, and the discounts available for settlement and co-operation are meaningful. Businesses should treat the AA decision as a warning shot and use it as a prompt to stress-test their compliance across the board, before the CMA does it for them.