On 10 June 2026, the Competition and Markets Authority (CMA) confirmed that it has launched an investigation into some of the pricing practices of Ryanair, and its potential lack of compliance with consumer protection law, namely the Digital Markets, Competition and Consumers Act 2024 (DMCCA).
The CMA investigation
To reserve a seat on a Ryanair flight, a consumer must usually pay an additional fee. While this is not necessarily an issue in consumer law, Ryanair’s terms and conditions require at least one parent to sit with their children aged 2-11. In order to do so, the parent must usually pay to reserve the seat next to their child, at a cost of around £8 per flight.
As such, there are two strands to the CMA investigation:
- Whether Ryanair used and relied on a potentially unfair contract term, by putting customers at an unfair disadvantage.
- Whether the presentation of that fee during the booking process on Ryanair’s website could be considered an example of drip pricing (where a trader shows a low initial price but adds mandatory fees at a later stage).
Comment
More broadly, this investigation reflects the CMA’s continued focus on pricing transparency following their new enforcement powers under the DMCCA. The outcome may have implications beyond Ryanair, especially in similar situations where there is a mandatory fee for only a subset of consumers and whether this should be presented at the outset for all consumers. This will certainly be one to watch for any further clarification on the boundaries between legitimate ancillary pricing and unfair commercial practices. The CMA has indicated that it expects to provide an update on the status of the investigation within the next six months.
For more information on the CMA’s recent enforcement action, pricing transparency and the CMA’s new powers please see our articles below:
- CMA vs Emma: Discount pricing and consumer law risks
- £4.2m fine signals imperative for businesses to clearly communicate their prices to consumers
- CMA steps up enforcement on fake and misleading reviews
- Price transparency: The CMA’s final guidance and why it matters even more now
Mills & Reeve's advertising team will continue to monitor these developments closely. In the meantime, if you require support, please get in touch.
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