All fine?

What will cost your business more?

A - Safety failures leading to two tragic deaths.

B - Failing to mention a £3 booking fee on your website at the outset of a booking process.

A £2.475M fine following a safety prosecution resulting from the deaths of two contractors reported earlier this week (14 April 2026) was notable both for the tragic events and for the relatively high level of fine. Although the Sentencing Guidelines for safety offences ‘top out’ at £10M (with provision to go further for Very Large Organisations), it is common to see fines at a much lower level even in serious cases. It’s a serious and tragic case that serves as a very loud and clear warning to all businesses that safety must be a top priority. The business concerned reported a turnover in the region of £450M in recent years – well into the ‘Large’ company bracket in terms of turnover within the guidelines which starts at £50M. Within those guidelines, a £2.4M fine sits fairly high on the table of possible fines, starting points and ranges within the culpability bands that commonly arise.

A CMA enforcement action over a failure to mention a £3 booking fee until part way through the booking process concluded the same week. The Final Infringement Notice and settlement directed refunds to the tune of £760,000 (an average payout of £9 per consumer) and… a fine of £4.2M. Not only that, but that the £4.2M fine represented a 40% reduction from what would have been the financial penalty imposed – ie. £7M without that discount.

The wider picture is that the CMA decision forms part of a much broader investigation into similar practices that led them to look at over 400 businesses across 19 sectors, issuing guidance to 100 of those businesses and launching investigations into 8 of them. The sectors addressed were diverse: travel, retail, parking, storage, ticketing, delivery and leisure amongst others.

CMA noted its power to fine up to 10% of global turnover or 5% (+ daily default penalties) for failure to follow undertakings. The business in question reported UK turnover just under £400M, so the fine imposed even before reduction for credit, whilst substantial by any measure, represented less than 2% of turnover.

Fines are not supposed to be measures of consequences – judges are always make it clear in fatality cases, for instance, that they are not putting a price on the loss that has been suffered – but they are, in some way, a scalable measure of wrongdoing in terms of the harm caused or risked and culpability.

Read more at:

https://www.cps.gov.uk/cps/news/companies-fined-over-ps2m-after-deaths-pest-controllers-chicken-factory https://www.gov.uk/government/news/cma-orders-the-aa-and-bsm-driving-schools-to-refund-learner-drivers-over-drip-pricing