Key takeaways
- Advertising a price nobody can actually pay, because a mandatory fee gets added later, is a false or misleading representation under the Competition Act.
- Only amounts charged to the buyer by federal or provincial law, in practice sales tax, can sit outside the advertised price. A 2024 amendment closed the wider reading.
- There is no small business exemption. The rule is the same for a Kootenay campground and a national cinema chain.
- Since June 2025, customers and competitors can bring their own applications, so the Competition Bureau is no longer the only one watching.
- The most common source of hidden fees is not your page. It is the booking, ordering, or ticketing tool bolted to it.
On this page
Is drip pricing against the law in Canada?
Yes. Since June 23, 2022, advertising a price a customer cannot actually pay, because fixed mandatory fees get added later, counts as a false or misleading representation under the Competition Act. Only amounts charged to the buyer directly by federal or provincial law, in practice sales tax, are allowed to sit outside the advertised price.
Drip pricing is the industry name for a familiar experience. You see a number, you decide, and then the number grows on the way to the payment screen. A booking fee here, a cleaning fee there, a service charge that appears on the last page. Nothing was technically concealed. It was just revealed too late to matter.
The rule sits in two places. Section 74.01(1.1) of the Competition Act covers it on the civil side, and section 52(1.3) covers the criminal side. Both were added on June 23, 2022. Then in 2024, Parliament tightened the exception, because businesses had started reading it as permission to pass along all sorts of costs as separate fees. Now the only charges that can sit outside your advertised price are the ones a statute imposes on the buyer.
I want to be clear about my lane here. I build websites, I am not a lawyer, and this guide is a plain-English summary with links to the primary sources at the bottom so you can read them yourself. For a specific fee on a specific invoice, ask a lawyer. What I can tell you is where this rule collides with the way most small business websites are built.
The test is not whether the fee was disclosed. It is whether the price you advertised was one a customer could actually pay.
What did the Cineplex ruling actually settle?
It settled that a fee can be fully disclosed later in the purchase and still break the rule. Cineplex advertised online ticket prices that excluded a mandatory $1.50 booking fee. The Competition Tribunal ordered a penalty of roughly $38.9 million in September 2024, and on January 21, 2026 the Federal Court of Appeal dismissed the appeal.
The number gets the headlines, but the useful part for a small business owner is the shape of the conduct. The fee was one dollar and fifty cents. It was not buried in a footnote written in grey. It appeared later in a normal-looking checkout, the way fees appear on thousands of sites right now.
That is the part worth sitting with. The case did not turn on trickery. It turned on sequence. The advertised price came first, the unavoidable fee came second, and the law treats that order as the problem regardless of how politely the second part is explained.
The Competition Bureau puts it in almost plain web design terms on its own guidance page: customers should not have to scroll down or read the fine print to find the total price. If you have ever argued with someone about whether a disclosure counts when it lives below the fold, that sentence settles it.
Which fees can stay outside the advertised price?
Very few. Only amounts charged to the purchaser by or under an Act of Parliament or a provincial legislature, which in practice means GST and PST. A fee charged to your business and then passed along is a cost, not an exempt charge, and 2024 amendments closed that reading on purpose.
Most owners get sales tax right without thinking about it. The trouble starts with everything in the middle: the charges that feel like taxes, get printed like taxes, and are not taxes. Here is the sorting rule.
- GST and PST
- Sales taxes are charged to the buyer by law, so they can sit outside the advertised price. This is the clearest case and the one almost everyone already handles correctly.
- Anything else, by default
- If the fee is not charged to the buyer by a federal or provincial statute, treat it as part of the price. The 2024 amendments narrowed this on purpose, because businesses were reading the exception far too generously.
- A cost you pay, not the customer
- A levy charged to your business, then passed along, is not a fee charged to the buyer by law. It is one of your costs. Costs belong inside the price, the same way rent and wages do.
- When you are unsure
- Ask a lawyer about the specific fee, or put it in the price. Putting it in the price is never the risky choice. Leaving it out might be.
Practically, if a customer cannot complete the purchase without paying it, treat it as part of the price. The list below covers the fees I run into most often on small business sites in this region.
- Booking fees, reservation fees, and online order fees.
- Cleaning fees, resort fees, and property fees a guest cannot decline.
- Service charges added automatically to a bill rather than chosen by the customer.
- Shop supply fees, disposal charges, and levies your business pays and passes along.
- Trip charges, fuel surcharges, and minimum call-out fees on service work.
- Processing, handling, and administration fees of any name.
One nuance worth naming, because it comes up constantly in restaurants: a tip a customer chooses is not a mandatory fee. A service charge that lands on every bill of six or more, without anyone agreeing to it, is a different thing entirely. The dividing line is whether the customer has a real choice.
Where does this show up on a small business website?
Almost always at the seam between your pages and your tools. Your rates page says one number, and the booking engine, online ordering system, or ticketing platform adds another at the last step. Here is what that looks like across the trades I build for most often.
- 01
Hotels, lodges, and cabins
Cleaning fees and property fees are the classic case, and the Competition Bureau names cleaning fees directly. If a guest cannot book the room without paying it, the nightly rate on your site should already include it. I build hotel and lodge websites so the rate a guest sees on the first screen is the rate they pay on the last one.
- 02
Campgrounds and RV parks
Reservation fees and per-booking service charges are the usual offenders here, especially when the booking engine adds them at the final step and the rate on your own page never mentioned them. Worth checking on any campground and RV park website, because the tool bolting on the fee is often not the tool you built the page in.
- 03
Restaurants and cafes
A gratuity a customer chooses is not a mandatory fee. A service charge added automatically to every table of six, or a kitchen fee applied to every bill, is a different animal. If it lands on the bill without the customer agreeing to it, it belongs in the menu price or somewhere just as visible. Same logic applies to online ordering on a restaurant and cafe website.
- 04
Auto repair and tire shops
Shop supply fees and disposal charges get added to a lot of invoices. Some environmental levies are charged to the buyer under provincial rules, and some are your cost of doing business wearing a fee-shaped hat. The two are treated very differently. If a posted rate on your auto repair shop website quietly grows by the time the invoice prints, that gap is worth a look.
- 05
Trades and contractors
Trip charges, fuel surcharges, and minimum call-out fees are all mandatory if the customer cannot get the work done without them. Advertising a rate per hour and then adding an unavoidable charge is exactly the pattern the law is aimed at. On a trades and contractor website, the fix is usually one honest sentence rather than a new rate card.
- 06
Golf courses, venues, and event spaces
Mandatory cart fees, ticketing fees, and room setup charges sit in the same category. If nobody can play the round or book the hall without paying it, the advertised number should already include it. That shapes how I lay out rates on a golf course website and how packages get priced on a venue and event website.
Notice how many of those examples are not really copywriting problems. They are integration problems. You wrote an honest rate, and a third-party tool added a fee at a step you never see because you are not the one booking your own campsite on a Tuesday night.
How do I check my own website for hidden fees?
Walk your own purchase like a stranger, on a phone, all the way to the final screen. Write down the first price you were shown and the last price you were asked for. Every difference between those two numbers is either a government tax charged to the buyer, or something that belongs in the advertised price.
- 1Open your own website on a phone and write down the first price a customer sees, exactly as it appears.
- 2Go all the way through to the final checkout, booking, or quote screen without paying, and write down the real total.
- 3List every difference between the two numbers, then sort each one into government tax charged to the buyer, or everything else.
- 4Move everything in the second pile into the advertised price, or say on the same screen that it will be added and how much it is.
- 5Check the tools too, not just your pages: booking engines, online ordering, ticketing, and payment add-ons often insert fees your website never mentions.
Do this on a phone specifically. Desktop layouts have room to put a fee note next to a price. Phone layouts push that note below the fold, and below the fold is exactly where the Bureau says the total price should not be hiding.
If the walk turns up a gap, the fix is usually smaller than owners fear. Most of the time you are raising a displayed rate by the amount of a fee you were already collecting, and deleting a line from the checkout. The revenue does not change. Only the honesty of the first number does.
Does this apply to a small shop, or only to companies like Cineplex?
It applies to every size. The Competition Act has no revenue threshold for this, and the Bureau names no small business exemption. Large companies draw the enforcement because penalties scale with harm and volume, but the rule itself does not change when the business gets smaller.
There is also a change most owners have not heard about. As of June 20, 2025, private parties can seek permission to bring deceptive marketing applications directly to the Competition Tribunal, and monetary awards are available as a remedy. That means individuals, public interest groups, and competitors, not only the Bureau.
I am not raising that to be alarming. Realistically, nobody is filing a Tribunal application over a campground reservation fee. I am raising it because the practical risk for a small business was never really the federal penalty. It is the customer who feels stung at checkout, tells eleven people, and leaves the review that outranks your homepage for a year.
British Columbia has its own layer too. The Business Practices and Consumer Protection Act separately treats misleading price representations as a deceptive act, including one rule that matters to anyone advertising a monthly figure. More on that next.
What about monthly payment plans and package pricing?
The BC statute is direct about this: showing a monthly figure without giving the total price at least the same prominence is treated as a deceptive act. If you advertise a per-month number for anything, the full amount has to stand beside it with equal weight, not underneath it in smaller type.
This is the rule I am most careful about on my own site, because I offer a monthly option and it would be very easy to make the small number the loud one. So here is how I write it every time, and you are welcome to steal the pattern.
The Trailhead is $2,000. If paying it once is the sticking point, Own It Monthly is 12 payments of $189, which is $2,268 all in, and you own the finished site outright at the last payment. Full price first, monthly figure second, total spelled out, difference visible. Nobody has to do arithmetic to find out what they agreed to.
Every package on my services page is written the same way, and my website cost guide covers what different builds actually cost if you are still working out the scope. The point is not that I am unusually virtuous about it. The point is that this pattern takes about the same number of words as the sneaky version and does not age into a problem.
| How the risky version reads | How the honest version reads | |
|---|---|---|
| Headline number | From $99 a month, in large type | Full price first, monthly figure beside it |
| The total | Absent, or in fine print below | Stated in the same sentence as the monthly figure |
| Mandatory fees | Added at checkout as extras | Already inside the advertised number |
| What the customer does | Multiplies, guesses, or gets surprised | Reads one sentence and knows the number |
| What happens later | A refund argument, or a review | A customer who quotes your price correctly |
Why all-in pricing sells better anyway
Because the fee reveal happens at the exact moment a customer has decided to buy, and it replaces trust with suspicion at the worst possible second. A price that grows on the way to checkout does not just risk a legal problem. It undoes the work the rest of your website just did.
Think about the sequence from the customer's side. They found you, read enough to believe you, chose you over two other options, and started giving you their information. That is the highest-trust moment in the whole relationship. A surprise fee arrives precisely there, and the message it sends is not the size of the fee. It is: what else did you not tell me.
The businesses I see winning on price pages are almost never the cheapest. They are the ones whose number does not move. A slightly higher rate that stays put reads as competence. A lower rate that grows reads as a trick, even when the final total is identical.
There is a quieter benefit too. Honest all-in pricing is easy for an AI assistant to quote correctly, and increasingly that is how people get their first answer about you. A page with one clear number gets repeated accurately. A page with a headline rate and a footnote gets repeated as the headline rate, and then you spend the sales call explaining the difference.
If you want a straight read on your own pricing pages, send them over. I will tell you where your first number and your last number stop agreeing, and whether the fix is a rewrite or a sentence.
Sources and further reading
- Competition Bureau: drip pricing
The Bureau’s own plain-language page. It states that customers should not have to scroll or read fine print to find the total price, which is a web design instruction as much as a legal one.
- Competition Act, section 74.01
The civil provision itself, including subsection (1.1) on prices that are unattainable because of fixed obligatory charges. The criminal counterpart is section 52(1.3).
- Competition Bureau: guide to the 2022 amendments
Covers the June 23, 2022 changes that added the drip pricing provisions to both the civil and criminal misleading representation rules.
- Competition Bureau: Cineplex decision
The September 2024 Tribunal ruling on a mandatory online booking fee, and the roughly $38.9 million penalty. The Federal Court of Appeal dismissed the appeal on January 21, 2026.
- Business Practices and Consumer Protection Act (BC)
British Columbia’s own consumer protection statute, which separately treats misleading price representations as a deceptive act, including showing a monthly figure more prominently than the total price.
Frequently asked questions
Is drip pricing illegal in Canada?
Yes. Since June 23, 2022, advertising a price that a customer cannot actually pay because of fixed mandatory fees is treated as a false or misleading representation under the Competition Act, under both the civil provision in section 74.01(1.1) and the criminal provision in section 52(1.3). The only fees that can sit outside the advertised price are amounts charged to the buyer directly by a federal or provincial statute, such as sales tax.
Does this apply to a small business, or only to big companies?
It applies to businesses of every size. The Competition Act sets no revenue threshold and the Competition Bureau’s guidance names no size exemption. Big companies get the headlines because the penalties scale with the harm, but a small campground or repair shop advertising an unattainable price is doing the same thing the law describes.
Which fees can I leave out of the advertised price?
Only amounts charged to the purchaser by or under an Act of Parliament or a provincial legislature, which in practice means sales taxes such as GST and PST. Amendments passed in 2024 narrowed this deliberately, because some businesses were treating general regulatory costs and business taxes as if they qualified. A fee charged to your business and passed along to the customer is a cost, not an exempt charge.
What happened in the Cineplex case?
The Competition Tribunal found in September 2024 that Cineplex engaged in drip pricing by advertising ticket prices online that excluded a mandatory booking fee of $1.50, and ordered a penalty of roughly $38.9 million. Cineplex appealed, and on January 21, 2026 the Federal Court of Appeal dismissed the appeal, leaving the Tribunal’s findings and the penalty in place.
Can a customer or competitor take action, or only the Competition Bureau?
Both. As of June 20, 2025, private parties including individuals, businesses, competitors, and public interest groups can seek leave to bring a deceptive marketing application directly to the Competition Tribunal, and monetary awards are available as a remedy. Enforcement is no longer only the Bureau’s job.
Can I show a mandatory fee separately if I disclose it clearly?
The safest reading of the Bureau’s guidance is no, not if the fee is fixed and unavoidable. The Bureau states that customers should not have to scroll down or read the fine print to find the total price, and the Cineplex case turned on a fee that was disclosed later in the purchase flow rather than hidden entirely. If a customer cannot buy without paying it, put it in the price.
What about fees that vary, like shipping?
Variable charges are harder to fold into one number, and the Bureau notes that variable fees can still raise concerns depending on how they are presented. The practical approach is to make the variable amount findable before the customer invests time: a shipping estimate on the product page, a clear service area with call-out terms, or a rate that already assumes the common case.
Is this guide legal advice?
No. I build websites, I am not a lawyer. This is a plain-English summary of published Competition Bureau guidance and Canadian law, with links to the primary sources so you can read them yourself. For a specific fee on a specific invoice, talk to a lawyer.
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