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Total price and drip pricing: what your listing must show

If a guest cannot avoid a fee, the 2024 Act treats it as part of the total price, and burying it later in the funnel counts as leaving it out.

The Cotswold Way (Broadway) - geograph.org.uk - 7939973
Photo: The Cotswold Way (Broadway) - geograph.org.uk - 7939973 — Fabian Musto, CC BY-SA 2.0, Wikimedia Commons

The trigger is an invitation to purchase, not a booking

Section 230(10) defines an invitation to purchase as a commercial practice that provides information to a consumer, indicates the characteristics of a product and its price, and enables, or purports to enable, the consumer to decide whether to purchase it or take another transactional decision about it. A listing page with a nightly rate is one; so are a search result card and a priced email. The duty starts long before the payment screen.

Burying it counts as omitting it

Section 226 sits behind it: a practice is a misleading action where it provides false or misleading information, and where its overall presentation is likely to deceive the average consumer about a matter relevant to a transactional decision. Sections 226(2) and 226(3) close the gap: true information presented in a misleading way still counts, and an overall presentation may deceive even if everything in it is true. An accurate fee table nobody reads before committing is inside that language.

The rest of the list, which owners forget

Section 230(2) asks more than price. The main characteristics of the product, to the extent appropriate to the medium. The identity of the trader, which section 230(6) defines as the name and, if different, the trading name, plus anyone on whose behalf the trader acts. The business address, the service address if it differs, and any business email address, each defined by section 230(7). Where a right of withdrawal or cancellation exists, its existence. And under section 230(2)(i), where your actual practice on payment, delivery, performance or complaint handling departs from your published practice, the practice you are currently operating.

Our advice

Rebuild the headline figure to carry every charge a guest cannot refuse, keep optional extras visibly optional, and give any variable element the price's prominence. Then ask whether the first number a stranger sees is the number they pay. We study every request and tell you honestly whether and how we can help.

Markets mentioned

LondonManchesterBirminghamBrighton and HoveBristol & Bath

Sources

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