The UK government has signalled by statements to parliament a crackdown on “price gouging” – the practice of hiking prices to unjustified highs during crises. What should a business do?

Published: 01 June 2026
Authors: Kiran Desai

Ignoring the policy merits of what is proposed, the practical implication for businesses is that pricing decisions may face greater scrutiny, both regulatory and public. Rather than focusing on prescriptive steps, corporations may wish to test themselves against a series of internal questions. These include:

• how robust is our pricing governance and oversight?
• can we evidence and explain our price changes?
• how exposed are we to regulatory scrutiny?
• how vulnerable are we to reputational damage?
• are we balancing commercial reality with perceptions of fairness?

A New Focus on Price-Gouging in the UK

As first addressed in parliament on 24 March 2026 and reiterated on 21 May 2026, the UK government plans to empower regulators to act swiftly against excessive pricing. Price gouging typically means exploiting a crisis by raising prices to an unfair or unjustifiable level. Measures under discussion include rapid investigations and public “name and shame” campaigns to spotlight firms whose margins surge unfairly. In extreme cases, officials even suggest targeted orders or fines to stop “exploitative pricing”. This is a proactive shift – historically UK competition law has not punished  high prices alone (unless a dominant firm abused its power), focusing more on collusion or monopolistic conduct. Now, however, the UK government aims address unfair prices, reflecting public expectations and political pressure.

Key Questions for End-Consumer Facing Corporations

1. Do we have the right pricing governance and oversight?

Corporations should ask whether pricing is treated as a strategic governance issue, with clear internal controls and approval routes for significant price changes. The relevant internal question is whether the business has guardrails capable of testing not only commercial necessity, but also how a pricing decision may appear if reviewed by a regulator, customer base, or the media. The strength of that governance framework may be as important as the price decision itself.

2. Could we clearly justify and evidence each material price increase?

Corporations should ask themselves whether they could demonstrate, with contemporaneous records, why a price increase occurred and whether it was linked to genuine cost, supply, or market factors. The issue is not merely whether an increase can be defended in principle, but whether the business has documentary support showing purchase costs, margins, inventory constraints, or other drivers. A key internal question is whether the company could explain its pricing decisions in a way that appears disciplined rather than opportunistic.

3. How would our pricing look under regulatory scrutiny?

With stronger oversight powers under discussion, corporations should ask how their pricing patterns would appear if compared against pre-crisis levels, sector norms, or peer conduct. The question is whether the business has identified who would respond to an inquiry, how data would be assembled, and whether any pricing outliers would be difficult to explain. Even before any formal rules are settled, a prudent self-assessment is whether the company would be comfortable seeing its pricing decisions examined in real time by a regulator.

4. What would be the reputational impact if our pricing were publicly challenged?

Corporations should ask not only whether a price increase is legally defensible, but also how it would be perceived externally. A price decision that can be explained internally may still be portrayed publicly as exploitative, particularly in a period of economic pressure. The relevant question is whether the business has considered the effect on customer trust, brand value, and public narrative if it were singled out in a “name and shame” environment. In many cases, reputational exposure may matter as much as formal legal risk.

5. Are we striking a credible balance between fairness and commercial reality?

The final question is whether the business can articulate a coherent position on where legitimate cost recovery ends and perceived exploitation begins. Regulators have indicated that not every price increase is problematic, particularly where costs have genuinely risen, but the dividing line remains unclear. Corporations should therefore ask whether their internal policies, margin expectations, and crisis-response planning reflect a defensible balance between commercial viability and wider perceptions of fairness. What is already clear is that even an investigation can consume management time, create advisory cost, and inflict reputational harm before any formal determination is reached.