27 Jun 2025
by Lewis Walmesley-Browne

Dynamic Pricing: CMA Urges Fairness and Clarity from Tech Firms

New CMA guidance outlines best practices for consumer-facing tech companies to ensure transparency, protect vulnerable users, and build trust in dynamic pricing strategies. 

The UK’s Competition and Markets Authority (CMA) has in June 2025 released an update on the findings of its research into the use of dynamic pricing in the UK, alongside some recommendations for companies to ensure that their pricing practices are compliant with UK pricing transparency regulations. 

Refresh: what is dynamic pricing? 

Dynamic pricing is a technology-enabled pricing strategy that allows companies to adjust prices in real time in response to factors such as market demand, competitor activity, supply fluctuations, and customer behaviour. In the consumer-facing side of the technology sector, dynamic pricing is widely used by platforms such as delivery apps, ride-hailing services, ticketing platforms, and e-commerce marketplaces. 

This data-driven approach enables businesses to be more agile and responsive to shifting market conditions - optimising revenue, enhancing supply chain efficiency, and identifying high-intent or highly engaged customers. When implemented effectively and transparently, dynamic pricing can drive greater competitiveness and innovation across sectors. However, if used without appropriate safeguards or clear communication, it may lead to reduced consumer trust, perceptions of unfairness, or pricing volatility that disproportionately affects certain customer groups. 

The CMA’s dynamic pricing project 

Public interest in dynamic pricing was elevated in late August 2024 following widespread media criticism of the sales process for tickets to the Oasis reunion tour. Prospective buyers reported waiting in lengthy online queues, only to find that the final prices of tickets were dramatically increased from the originally advertised prices, leading to accusations of pricing gouging and making tickets inaccessible to many people. 

In November 2024, the CMA announced the formation of a dynamic pricing project to consider how dynamic pricing is being used across different sectors of the economy. The stated objectives were to identify different scenarios where dynamic pricing strategies are being used, map out the commercial and consumer benefits of dynamic pricing strategies, and consider whether dynamic pricing strategies create challenges for consumers and competition. techUK has been happy to participate in this project alongside a number of our consumer-facing member companies. 

June 2025 project update 

The CMA published an update to the project in June 2025, which can be accessed in full here, and initial findings are summarised below: 

  • The impact of dynamic pricing on consumers and competition depends on how it is applied and the market context. When implemented transparently in competitive markets, it can improve efficiency, smooth demand, and deliver better outcomes—particularly where consumers can flex their behaviour, such as choosing alternative travel times or dates.  
  • However, benefits are limited in markets with few substitutes, like live events, where prices often rise without added consumer value.  
  • Positive outcomes also depend on consumer understanding; awareness of how prices vary enables better planning and fairer access.  
  • Risks arise when pricing is complex, creates pressure to buy quickly, or varies widely across platforms, making comparisons difficult.  
  • Vulnerable groups, such as those with lower incomes or digital skills, may face higher prices and fewer opportunities to adapt.  
  • While dynamic pricing can sometimes stimulate extra supply, concerns grow when consumers lack transparency, face pressure, or when pricing reinforces market power and reduces competition. 

Factors for business to consider when using dynamic pricing 

Alongside the initial findings, the CMA have also published a set of tips for businesses to consider when applying dynamic pricing strategies. These include: 

  • Build consumer trust by being transparent about your pricing strategy 
  • Be clear that upfront prices can change 
  • Provide information about when and why prices may change 
  • Ensure necessary information is presented prominently and clearly, and explain important terms to the customer. 
  • Consider how vulnerable consumers might be affected by your approach to pricing 
  • Don’t pressure consumers into snap decisions, or increase prices towards the end of the sales funnel 

Members are encouraged to get in touch with techUK if you have any questions or areas that need clarification and we will happily raise these to the relevant project team.  

Lewis Walmesley-Browne

Lewis Walmesley-Browne

Head of Market Access and Consumer Tech, techUK

Lewis' programmes cover a range of policy areas within Market Access (international trade regulation, sanctions and export controls, technical standards and product compliance, supply chains) and Consumer Tech (media and broadcast policy, consumer electronics, and connected home technology).

Prior to joining techUK, Lewis worked in government affairs and policy roles for international trade associations in Southeast Asia including the American Malaysian Chamber of Commerce and the European Chamber of Commerce in Cambodia.

He holds an undergraduate degree in Social and Political Sciences from the University of Cambridge and an MSc in Public Policy & Management from SOAS University of London.

Email:
lewis.wbrowne@techuk.org
LinkedIn:
https://www.linkedin.com/in/lewis-walmesley-browne/

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Lewis Walmesley-Browne

Lewis Walmesley-Browne

Head of Programme: Market Access and Consumer Tech, techUK