United Kingdom: Competition and Markets Authority issued update on its inquiry into dynamic pricing

On 20 June 2025, the Competition and Markets Authority (CMA) issued an update on its inquiry into dynamic pricing. The CMA’s update outlined various risks, including the potential for consumers to be misled, disadvantaged, or unfairly treated, especially when pricing algorithms are opaque or when consumers are unaware that prices are fluctuating based on their behaviour or other factors. The CMA found that some consumers may not realise they are being charged different prices for the same product or service depending on when and how they shop, which can erode confidence in markets. In response, the CMA has issued guidance for businesses that use or are considering using dynamic pricing. These recommendations are designed to help firms comply with consumer protection law and maintain fair treatment of customers. The guidance highlights the importance of transparency, with businesses urged to clearly communicate when prices are subject to change, explaining the factors that influence those changes. Companies are also encouraged to assess the impact of their pricing strategies on different consumer groups, particularly vulnerable individuals who may be disproportionately affected. The CMA emphasises that businesses should avoid practices that could be seen as discriminatory or that exploit consumers’ lack of awareness. The guidance also advises firms to regularly review their pricing algorithms and data inputs to ensure they are functioning as intended and not inadvertently causing harm.