Hidden fees are now a regulatory target
Federal and state agencies are actively investigating businesses that advertise low base prices and then stack on mandatory fees at checkout. The practice — called drip pricing or junk fees — has gone from a common dark pattern to a named enforcement priority. FeeClear helps you audit your own pricing before a regulator does.
What is drip pricing?
Drip pricing is the practice of advertising a low headline price and then revealing mandatory charges — resort fees, service fees, processing fees, convenience fees — only as the customer moves through the purchase flow or reaches checkout. By the time the true total appears, many customers feel too invested to back out.
The resulting gap between the advertised price and the actual price is what regulators call a deceptive practice. Even if each fee is individually disclosed somewhere on the page, advertising a price that cannot actually be paid is increasingly treated as a misrepresentation under consumer protection law.
The regulatory wave
Rule on Unfair or Deceptive Fees (effective May 12, 2025)
The Federal Trade Commission's final junk-fees rule, codified at 16 C.F.R. Part 464, took effect May 12, 2025. It requires businesses offering live-event tickets or short-term lodging to disclose the total price — inclusive of all mandatory charges other than government taxes and shipping — at least as prominently as any other price displayed. The rule also prohibits misrepresenting the nature, purpose, or amount of any fee. Violators are subject to FTC Act § 5(m)(1)(A) civil penalties (currently $53,088 per violation, adjusted annually for inflation).
Read the full compliance brief →Honest Pricing Law (effective July 1, 2024)
California's SB 478 amended the Consumer Legal Remedies Act and is codified at Cal. Civ. Code § 1770(a)(29). It prohibits advertising any price that does not include all mandatory charges other than government-imposed taxes and reasonable shipping. SB 1524 carved out a narrow exception for restaurant menu charges that are clearly displayed alongside the price. Violations expose businesses to actual damages, restitution, injunctive relief, and attorneys' fees under the CLRA.
Read the full compliance brief →Protections Against Deceptive Pricing Practices (effective January 1, 2026)
Colorado's HB 25-1090, signed by the Governor on April 21, 2025, requires businesses to clearly and conspicuously disclose the maximum total price up front. The law applies broadly to consumer transactions including hospitality, food service, broadband, real estate, and rental housing, with industry-specific accommodations. Violations are deceptive practices under the Colorado Consumer Protection Act, which authorizes actual damages plus 18% interest compounded annually after a 14-day cure period.
Read the full compliance brief →Total Price Disclosure Law (effective January 1, 2025)
Minnesota's Total Price Disclosure law, codified in the Deceptive Trade Practices Act at Minn. Stat. § 325D.44 et seq., prohibits advertising or displaying a price that does not include all mandatory fees and surcharges a reasonable consumer would expect. Government-imposed taxes are excluded. Delivery platforms have specific upfront fee-disclosure obligations. Enforcement is by the Minnesota Attorney General under the state's deceptive trade practices framework.
Read the full compliance brief →NYC Hotel Fee Disclosure Rule (effective February 21, 2026)
The New York City Department of Consumer and Worker Protection adopted a final rule requiring hotels and booking platforms operating in NYC to disclose the total price of a stay — inclusive of all mandatory fees other than government taxes — at least as prominently as any other displayed price. The rule also addresses unexpected credit card holds and advance deposits, with the deposit-and-hold provision taking effect January 22, 2027.
Who is at risk?
Any business that advertises a price and then adds mandatory charges is potentially exposed. Enforcement has been most active in:
- Hotels and short-term rentals (resort fees, cleaning fees)
- Live-event ticketing (service fees, facility charges)
- Subscription software (mandatory onboarding fees, activation fees)
- Moving and delivery services (fuel surcharges, stair fees)
- Auto dealerships (dealer fees, documentation fees)
- Restaurants and dining (service charges framed as optional tips)
Smaller businesses are not exempt. State attorneys general and the FTC have brought actions against businesses of all sizes, and private plaintiffs have used state consumer protection statutes to pursue class actions.
What FeeClear does
FeeClear applies a deterministic rule set to your pricing inputs — advertised base price, mandatory fees, fee labels, and jurisdiction — and scores your disclosure practices against the patterns regulators have identified as deceptive.
A free check gives you a risk score and a summary of the top findings. A full report ($29) includes every finding with severity ratings, prioritized recommendations, sample disclosure copy you can adapt, and a downloadable PDF you can share with counsel or your compliance team.
FeeClear is an educational screening tool, not legal advice. Use it to identify where your current pricing disclosures may draw scrutiny, then work with qualified legal counsel on your actual compliance posture.
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Start Free CheckRegulatory summaries on this page are provided for informational purposes only and may not reflect the most current legal developments. They do not constitute legal advice. Consult a qualified attorney familiar with consumer protection law and the specific regulations applicable to your jurisdiction and industry.