Key takeaways
All inclusive pricing is now mandatory
Cruise lines must display total prices upfront, including all unavoidable fees.
Drip pricing and misleading urgency claims are high risk
The CMA is actively enforcing against hidden charges and false scarcity messaging.
Fake reviews trigger severe penalties
Misleading, incentivised or manipulated reviews can lead to fines of up to 10% of global turnover.
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) is reshaping the UK consumer protection landscape. For the cruise industry, the impact is significant. With provisions effective 6 April 2025, the Competition and Markets Authority (CMA) now wields direct enforcement powers - including the ability to impose fines of up to 10% of global annual turnover.
In November 2025, the CMA began applying its new DMCCA enforcement powers, signalling a decisive shift toward stricter consumer protection. The regulator publicly confirmed that its early enforcement focus includes aggressive sales tactics, hidden fees, misleading pricing practices, and unfair commercial practices, now backed by its ability to impose fines of up to 10% of global turnover. Alongside the commencement of the new regime in April 2025, the CMA also published its Approach to Consumer Protection, outlining priority areas and emphasising early action against egregious breaches, including hidden or unclear mandatory charges and unfair online choice architecture. Travel and hospitality operators remain a key focus as the CMA intensifies scrutiny of sectors where drip pricing and misleading urgency practices are common.
This marks a decisive shift towards stricter pricing transparency and authentic consumer engagement.
Pricing transparency: what cruise lines must do now
Displaying the total price upfront
Under the DMCCA and the CMA’s Price Transparency Guidance (CMA209), any invitation to purchase must clearly show the total price, meaning all charges a consumer will necessarily incur.
For cruise lines, unavoidable charges typically include:
Port charges and government taxes
Non optional booking or administration fees
Mandatory gratuities or service charges
Resort or tourist taxes (with a reasonable currency conversion method)
Mandatory transfer fees (e.g. tender boats or port shuttles required for disembarkation)
Unless it is genuinely impossible to calculate these costs in advance, they must be reflected in the first price the consumer sees.
The end of drip pricing
The DMCCA prohibits presenting a low initial price and adding unavoidable fees later in the booking flow. Cruise operators must avoid:
Hidden mandatory charges revealed only at checkout
Partitioned pricing that obscures the real total cost
The headline fare must be fully inclusive at the earliest point in the journey - not only once a cabin is selected or passenger details are entered.
Providing a clear breakdown
On the checkout page, CMA209 requires:
The total price
A transparent breakdown (fare, taxes, charges, conversion basis)
A clear distinction between mandatory and optional extras
This is especially important for cruise pricing, where ancillary components are often complex.
Urgency and scarcity messaging: higher risk under CMA scrutiny
The CMA is actively targeting misleading urgency tactics, including:
Countdown timers without real deadlines
False scarcity claims such as “only 2 cabins left”
Inflated discounts based on artificial reference prices
All urgency and scarcity messages must be truthful, evidence based and verifiable.
For cruise lines, this applies across websites, mobile apps, call centres, OTA listings, and affiliate marketing.
High value itineraries and packaged products
The combined effect of DMCCA obligations means cruise operators must ensure that:
Package and fly cruise prices reflect all unavoidable surcharges
Currency conversions in international itineraries are clearly explained
Optional extras (Wi Fi, drinks packages, insurance) are not pre selected
Discount and comparison pricing enables a like for like assessment
Luxury and expedition cruise products - often involving multi currency and multi component pricing - must be especially careful.
Fake reviews: one of the most impactful changes for cruise lines
New legal prohibitions
Under Schedule 20 of the DMCCA, the following are automatically unfair and unlawful:
Submitting or commissioning fake reviews
Concealing incentives behind reviews
Presenting review information in a misleading way
Selectively removing or suppressing negative reviews
Providing services that enable fake review practices
Both positive and negative non genuine reviews are captured, including AI generated or influencer content that fails to disclose incentives.
Practical obligations for cruise operators
Under CMA208, cruise lines must take reasonable, proportionate steps to:
Prevent fake or non disclosed incentivised reviews
Detect and remove misleading or unlawful reviews
Publish a clear anti fake review policy
Ensure influencers and hosted guests disclose incentives
Monitor OTA platforms and third party sellers
Given the industry’s reliance on guest reviews and ratings, the compliance burden is substantial.
Enforcement and penalties
Key milestones for cruise executives to note:
DMCCA review rules took effect: 6 April 2025
CMA grace period ended: July 2025
CMA contacted 54 companies: 25 July 2025
Maximum fines: up to 10% of global annual turnover
This is among the most severe penalty regimes outside competition law.
What cruise lines should do next
Pricing compliance
Include all mandatory charges in the headline price
Remove pre selected optional extras
Verify urgency claims and discount references
Audit all marketing touchpoints, including OTAs
Document currency conversion methods
Review governance
Implement and publish an anti fake review policy
Require clear influencer/hosted trip disclosures
Ensure aggregate star ratings include all reviews (no filtering)
Keep logs of moderation decisions
Monitor external platforms for misleading reviews
Internal governance and training
Train staff on new DMCCA obligations
Update call centre and sales scripts
Review loyalty programmes and referral incentives
Update contracts with marketing agencies and affiliates
How Hill Dickinson can support
At Hill Dickinson, we help cruise operators navigate DMCCA compliance with sector specific insight. Our team advises on:
Transparent pricing and booking flow compliance
Review governance and influencer marketing controls
Regulatory and contractual risk assessments
Dispute resolution related to consumer protection issues
As the CMA intensifies activity across the travel and hospitality sector, our specialists can help future proof your commercial, digital and consumer facing practices.
For further support, please contact Ezequiel T. Condoluci Santa Maria.
