The Competition and Markets Authority (CMA) clearly has travel in its sight as it looks to enforce new Continued from page 48


also what they will have to pay in resort.” So, if the taxes in resort


will amount to £20 per person for the period of a holiday, the ‘total’ price should include that £20 per person, along with a note explaining that the fees will need to be paid in the local currency along with the exchange rate used to calculate the charges in sterling, and a note that the exchange rate could change. Lo Bue-Said suggested “it’s


a recipe for confusion”, adding that “there is no experience yet” of what the CMA guidance means in practice. But there is considerable


work going on to try to clarify the best practice. Lo Bue-Said reported “regular meetings with members, particularly larger operators” to discuss compliance and said: “We’re learning from each other. Everybody wants to do the right thing. “We’re working with


Abta, with bed banks and with suppliers to ensure we understand what we have to do. It’s in everybody’s interests to ensure compliance and that there are no breaches.” She argued: “The industry


needs to work together because some businesses will have more information. The more we can work collaboratively, the better. We can learn from one another.” However, Lo Bue-Said also


insisted: “From a consumer point of view, we understand this has to be done.” She told Travel Weekly: “I’m


confident the industry will do the right thing for consumers and do everything it can to comply.”


Businesses advised to review pricing to meet CMA rules


Themis Advisory director Jo Kolatsis issued guidance last week, noting the CMA’s new rules apply to “any business advertising prices to UK consumers including agents, operators, cruise lines, OTAs and airlines”. Kolatsis said: “You may be


liable if the headline price omits mandatory charges or otherwise misleads [and] bed banks and


wholesalers can be drawn in where their pricing feeds drive how prices are presented.” Kolatsis


recommends businesses review: QHeadline prices and ‘from’ prices, including in ads, search results, brochures, email marketing and product listings to ensure local taxes/resort fees and other mandatory charges are included.


QBooking flows and processes “to ensure mandatory charges are not being added later in the journey”.


QHow ‘pay-later’ charges (including foreign currency charges) are displayed, ensuring consumers can see a clear breakdown of what is paid now versus later.


Jo Kolatsis


QThird-party channels and affiliates, “where pricing presentation is often constrained”.


Q Supplier information and agreements “to ensure all mandatory charges are properly communicated and captured for pricing purposes”.


‘Trade faces difficulty to factor in overseas taxes’


Industry lawyers have rushed to update businesses on Competition and Markets Authority (CMA) guidance as to how mandatory payments in destinations must now be included in headline prices. The guidance, issued in


November, sets out how travel businesses must present prices under the Digital Markets, Competition and Consumers Act. Fox Williams partner Farina


Azam noted: “The landscape has changed. Prices shown to consumers must be clear, accurate and genuinely reflect what they will pay. The CMA has made clear it will be watching the sector closely (Travel Weekly, December 11). “Local tourist taxes, resort fees


and similar compulsory charges must be included in the headline price, even when they are charged by a hotel, car rental desk or other local supplier, are paid locally and charged in a foreign currency.” These charges must be included


46 15 JANUARY 2026 Farina Azam


“in the first price consumers see – in adverts, emails and search results”. When a charge is levied in foreign currency, businesses should convert the amount to sterling to include it in the headline price, with details of the exchange rate conversion, and provide a breakdown of what the customer will have to pay and when. As Azam told business attendees


on a recent webinar: “Intermediaries and platforms will be liable if mandatory charges are not included in headline prices. It won’t be a defence to say the supplier didn’t provide that price.”


Abta senior solicitor Paula


Macfarlane warned last week via Travel Weekly online that the new requirements “mean fundamental changes to price displays”, noting: “There is a huge number of local taxes and it’s very difficult to know accurately what they are.” Alan Bowen, legal advisor to the


Association of Atol Companies, warned of “confusion all around” in a note to members last week. He argued: “The issue [the


CMA] has with agents and operators – and it seems they may have some difficulty in telling the difference – is the cost of overseas taxes that have to be paid by the consumer. “They expect these to be included


in the price quoted at the time of booking even though they cannot be collected in advance in the UK.” Bowen warned: “Providing a


price with the ‘pay now’ and ‘pay later’ charges in different currencies without also providing a consolidated total price is likely to breach the Act.”


travelweekly.co.uk


PICTURE: Karla Gowlett


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