Ryanair seating fees don't fly with the CMA: investigation launched

The CMA has today announced an investigation into Ryanair over its practice of charging parents to sit next to their children on flights. These mandatory fees, which rack up the cost of family holidays, may risk breaching consumer law. 

What’s the issue?

Ryanair’s T&Cs require at least one parent to sit with their children aged 2-11, but unlike other major UK airlines, Ryanair charges around £8 each way to book these “mandatory family seats”. 

Two legal concerns arise:

• Unfair contract terms – is Ryanair effectively charging parents so that the airline meets its own child safety and disability obligations under aviation rules? If so, that may be a term that unfairly tilts the contract in Ryanair's favour, which could be unlawful under consumer law.
• Drip pricing –  is the £8 fee hidden in the booking process? Since April 2025, it is illegal for businesses to advertise a headline price for a product and then reveal additional mandatory fees later on in the checkout process. 

The CMA has already shown it takes drip pricing seriously – in April 2026 it fined the AA's driving schools £4.2 million for concealing a mandatory booking fee until checkout. The AA avoided a further £2.8 million in penalties by settling early and admitting the breach, a lesson worth remembering for any business facing similar complaints. 

On unfair terms, this case may be the first test of the CMA’s direct enforcement powers in this area. The CMA has already indicated in its 2026-27 Annual Plan that it will focus on contract terms that are clearly imbalanced and unfair, and earlier this year consulted on revised guidance in this area (we await the final outcome of the consultation). This investigation confirms that enforcement is now following and forms part of the CMA’s wider efforts to help ease pressure on household budgets.

Interestingly, the Italian aviation authority has already taken action against the same Ryanair practice now being investigated by the CMA. The CMA’s latest investigation is therefore an example of the UK regulator prioritising consumer enforcement in an area where an overseas regulator has already been active. Regulatory alignment may be a recurring theme going forwards in CMA enforcement – the CMA’s ongoing investigation into Adobe regarding exit fees was similarly launched following a US settlement on the same issue. 

What happens next?

No finding of wrongdoing has been made at this stage, but the CMA has six months to gather information and evidence, which could lead to an infringement finding, remedies being imposed, or case closure. The CMA has now launched investigations into 15 businesses through its direct enforcement powers under the DMCCA.