Pricing transparency: all-in prices & order fees

This article is about pricing, and transparency. And the law.

If you are in the business of selling tickets, you might be familiar with ticket fees, order fees, service fees, transaction fees, etc. Although these can all be handled during the purchase process, they are sometimes complex to communicate on your website. Furthermore, there are laws that regulate exactly this.

This document summarises the key legal requirements in each jurisdiction and highlights the practical implications for ticketing operations. It ends with some practical tips and examples.

Here’s a spoiler for the core principal that will be discussed:

This is the general backbone for pricing. It governs consumer protection by preventing businesses from engaging in unfair, misleading, or aggressive commercial practices, and drip pricing (adding additional unavoidable costs later in the order process) could be seen as misleading if it deceives the consumer about the true cost of a product or service, leading them to make a decision they would not have otherwise made. This is the law that catches a low headline ticket price with mandatory fees revealed only at checkout. Source: Aimondo

This requires showing the total price for a ticket before purchase. The obligation to show the total price of a product – inclusive of taxes and, where applicable, all additional freight, delivery or postal charges – falls under the pre-contractual information requirements of the CRD. Mandatory booking or transaction fees are a CRD issue as much as anything else. Source: Osborne Clarke

This is still in development, not yet law but relevant to watch. The Commission's 2025 consultation on the Digital Fairness Act specifically targets drip pricing, for example,  failing to disclose upfront mandatory costs and adding them later during booking and dynamic pricing practices. Source: Osborne Clarke

Whenever you make an "invitation to purchase”, you must present the total, all-in price upfront. All fixed, mandatory charges must be included in the first price shown. In an invitation to purchase, traders must tell consumers the total price of the product, which includes any fees, taxes, charges, or other payments that the consumer will necessarily incur if they purchase the product. Source: Charles Russell SpeechlysMondaq

Effective May 12, 2025, the FTC's Rule on Unfair or Deceptive Fees, 16 C.F.R. Part 464, prohibits bait-and-switch pricing and other tactics used to obscure and misrepresent total prices and fees for live-event tickets and short-term lodging.

“Live-event tickets” are defined as tickets for concerts, sporting events, music, theater, and other live performances that audiences watch as they occur. This is one of only two industries this federal rule targets by name. Source: Federal Trade Commission

The key requirement is that any displayed ticket price must include all unavoidable costs in a single amount, not just the base ticket price. This is more nuanced than simply showing a basket total. The rule breaks down into two things: the price shown per ticket must be all-in, and the total order cost must be shown clearly before payment.

The ACL applies to all ticket sales and requires the total price to be shown clearly and upfront. This is the "no drip pricing" rule — businesses can't advertise an attractively low headline price and then reveal mandatory fees (like booking fees) later in the checkout process.

The ACCC has been actively enforcing this in the ticketing/entertainment space. The ACCC has said it will scrutinise pricing practices across the cinema sector more broadly. source: Lexology.com

A bigger change is coming: on 2 July 2026, Parliament passed amendments introducing a general prohibition on unfair trading practices, plus new requirements to reduce harm from drip pricing and subscription traps, commencing 1 July 2027. Businesses will need to show mandatory transaction fees prominently and upfront when displaying prices. Penalties are steep: corporations face the greater of $100 million, three times the benefit gained, or 30% of adjusted turnover during the breach period, while individuals face up to $2.5 million. Source: Ashurstperkinscoie.com

Where a supplier displays a base price for goods or services to which a transaction based charge applies, the supplier must also display the following information:

The relevant information must be displayed while the base price is displayed, in a legible, prominent and unambiguous way, and in close proximity to the base price. It must not be included in fine print or on a different web page.

Note that this does not mean all costs should be combined in one all-in price.

This applies nationwide, regardless of province. In June 2022, drip pricing provisions were added to the Competition Act, defined as advertising a price that's unattainable due to fixed obligatory charges or fees other than those imposed by federal or provincial legislation, such as sales tax. Promoting a price that's unattainable due to mandatory fixed charges is against the law unless the charge is a government-imposed tax. Fees can be disclosed as long as they're shown alongside the initial price rather than added later in the purchase flow. Sources: oba.org, competition-bureau.canada.ca/

Penalties are serious: individuals face up to CAD$750,000 for a first violation (CAD$1 million for repeats), or three times the benefit gained if that can be calculated.

Total price (fees included, taxes excepted) must be shown upfront. Unavoidable fees must be included in the total price displayed from the start, but may be shown separately.

We can break the core principle down into two areas:

When charging an extra fee per ticket, it is generally a good idea to include this fee directly in your ticket price. Some ticketing systems can combine different amounts into a ticket price to keep them separate for your administration, while communicating the total to visitors.

The challenge is bigger when you work with transaction fees, which are typically charged per order, not per ticket. When these fees are unavoidable, they should be part of the all-in ticket price, as this is the price a visitor will pay when buying (at least) one ticket.

So if a ticket is £15 and the transaction fee is £5, UK law requires you to show £20 per ticket. (This is the same in the US).

This makes automated price display on the website genuinely complex, as you cannot simply show the price of a ticket. You need a way to include all mandatory costs in this price. This option is not always available on a technical level.

This is technically more simple, as costs can be separated and calculated in real time when items are added to an order. The need for an all-in price disappears, as different prices and costs can be laid out in an overview, with a grant total at the end. Most ticketing systems offer solutions for true cost overviews that do exactly this, while the core price per ticket is respected and additional fees can be added as separate items, to be resolved in the grand total.

For now we will ignore the purchase process, as this will usually comply with legislation and costs are allowed to be broken down and added up as you go about your business.

Following the legislation, below is how we should expect ticket prices to show on your website when using a fixed order fee. The examples all use a base price per ticket of 20 and a fixed fee of 5 per order:

(Price example in euro’s)

Minimal:

Ticket price €20,00 We charge an additional booking fee of €5.00 per order.*️⃣

Better:

Ticket price €25,00 (This includes a booking fee of €5.00 per order) *️⃣

Minimal:

Ticket price £25,-

Better:

Ticket price £25,- (This includes a booking fee of £5.00 per order) *️⃣

Mimimal:

Ticket price $25,-

Better:

Ticket price $25,- (This includes a booking fee of $5.00 per order) *️⃣

The extra text is not to be used to mention extra costs on top of the ticket price. It’s meant to explain that the order fee is already calculated in the ticket price.

The solution can end up being a technical one, but it starts with an organisational challenge, and an effort on your part to work on price transparency for your visitors. The main goal of price transparency is to keep it simple and communicate clearly to your visitors at all times what the cost of a ticket is. In our opinion, fixed order fees are not easy to communicate, can lead to frustration (“why these extra costs?”) and should be avoided if you can.

Fixed order fees in the all-in price of a single ticket can also deter visitors from the purchase, as they might struggle with the concept, and may make the mistake of multiplying the all-in price by the number of tickets they look to purchase, calculating a higher amount in their head than they actually need to pay. This concern is also highlighted in a response to the pricing regulation, as written by the Society of Ticket Agents and Retailers (STAR, UK).

Read the full response (pdf)

On the other side, promoters might object to the idea of including extra fees in the price per ticket, and might think they prefer a fee per order to keep the base price per ticket low. This reasoning is no longer valid.

In order to comply with legislation, especially in the UK and US, an extra fee per ticket actually works out better for all parties. Prices will appear lower when the fee is calculated in the price per ticket instead of having to include a higher general order fee in the all-in price for one ticket.

Example:

Current situation with fixed order fee

New situation with fixed order fee

New situation with fixed fee per ticket

This topic can be a starting point to look at your pricing structure with fresh eyes. Not only from the perspective of the business, but also from the perspective of the visitor, the consumer. They encounter all sorts of prices, offers and costs all the time on their online journeys, and their experiences can be positive or negative, depending on what they expect, and how (and if) those expectations are met.

It is about being transparent, and also about being clear in your communication and about providing easy to understand user journeys with the visitor in mind. Visitors understand ticket prices, they have no trouble with extra costs when tickets will be printed and send by post. They pay extra for a gift wrap.

But there is a looming frustration when these costs are not reflecting extra value. Order fees, administration fees, service fees can all trigger this feeling, and influence the way your business is perceived.