Fees on a private practice website: the rules

When a UK private practice shows fees on its website, each figure is a price statement, and consumer law and the CAP Code decide how it is shown. Consultants also have duties under the CMA’s Private Healthcare Market Investigation Order 2014: written fee information before the first appointment, and fee information for PHIN, which publishes it. The fees page should agree with both.

Key points

• A consultant gives each patient a written cost estimate before an outpatient consultation, and keeps their fees up to date with PHIN.
• Since 6 April 2025, a fee that lets a patient decide whether to book must be the total price; charges added later are drip pricing.
• A “from” price includes every mandatory charge and must not exaggerate how many patients pay it.
• Care by a registered health professional, within their profession, is exempt from VAT when its primary purpose is the patient’s health; each practice checks its own services.
• A clear fees page shows each fee as a total, what it covers and what is billed separately.

Consultants give a written estimate before the first appointment

The Order applies to anyone providing privately funded healthcare in the UK, and its fee duties fall on consultants: doctors on the GMC’s specialist register, or who hold, have held or are qualified to hold an NHS consultant post in a speciality other than general practice. Its outpatients include patients seen in consulting rooms, so the duties reach a consultant’s own rooms.

When the appointment is confirmed, the patient receives, by letter or email, the estimated cost, which may be a range if the factors that decide the final figure are explained; any financial interest the consultant has in the facilities used; every insurer that recognises them; a reminder to insured patients to check their outpatient cover; and PHIN’s website address (articles 20.1, 22.3 and 22.6).

Before further tests or treatment come the reason, an estimate of the consultant costs or an agreed self-pay package price, and what the estimate leaves out (22.4). Hospitals and clinics must require this of every consultant who practises there (22.2).

The Order does not ask for fees on a website, but a website fee that differs from the letter gives the patient two figures.

PHIN publishes consultants’ fees

Consultants must also give PHIN, the Private Healthcare Information Network, their outpatient consultation fee, the standard fee for up to 50 of their most frequent procedures and their standard terms, kept up to date (22.1); PHIN publishes this on its website (24.6), in consultants’ profiles. The CMA’s open letter of July 2023 said that, as well as naming those in breach, it can issue legally binding directions enforceable in court. Keep the practice website and the PHIN profile on the same figures.

Consumer law asks for the total price up front

The unfair commercial practices rules of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025. A page that gives a service and its price, and lets the patient decide whether to book, is an invitation to purchase (section 230(10)). It must give the main characteristics, the total price and the practice’s identity and address; where a price cannot reasonably be calculated in advance, it says how it will be, as prominently as the price (230(2) and (5)). The total includes any fees, taxes or charges the patient will necessarily incur (230(4)). Leaving this out, or giving it unclearly, late or where the patient is unlikely to see it, is unfair in itself (225(4)⁠(b) and 230(9)).

The CMA’s price guidance says that hiding charges until later, sometimes called drip pricing, is illegal. A charge the customer must pay to buy the service is mandatory and normally belongs in the total, so a booking charge every patient pays is part of the consultation fee.

The CAP Code asks for complete prices and honest “from” prices

In the CAP Code, a price statement must not mislead by omission, undue emphasis or distortion (3.17), and a quoted price includes the non-optional taxes, fees and charges that apply to all or most buyers (3.18). A charge that depends on the patient’s circumstances is shown as excluded, with how it is calculated (3.19). If a consultation fee applies only to patients who also book a package, that commitment must be clear (3.21). “From” and “up to” must not exaggerate how available a price is (3.22), and the CMA adds that a “from” price includes every mandatory charge.

VAT: medical care is exempt, some services are not

Rule 3.18 allows prices without VAT only where all or most of the people addressed pay no VAT or can recover it, so on a page for patients any VAT that applies belongs inside the price.

HMRC’s VAT Notice 701/57 sets the test. A doctor, dentist, nurse or other health professional on the appropriate statutory register supplies exempt services when the service is within their registered profession and its primary purpose is to protect, maintain or restore the patient’s health. Most reports and certificates for a third party’s decision, such as for insurance or legal purposes, are standard-rated, as are services with no health purpose and those done purely for cosmetic reasons. HMRC generally accepts cosmetic services as exempt where they are part of a health care treatment programme. Which services are exempt is for the practice and its accountant to settle; the page shows the answer.

A clear fees page shows each fee and what it covers

• Each consultation fee as a total, first appointment and follow-up, with the length where it changes the fee.
• What is billed separately: tests, scans, pathology, the hospital, an anaesthetist. PHIN notes that surgeons and anaesthetists often bill patients directly, and that diagnostic costs often catch patients out.
• Any self-pay package, with what it includes and leaves out; PHIN notes that a package almost never includes the first consultation.
• For insured patients, the insurers that recognise the consultant, and what happens when the fee exceeds what the insurer pays, which PHIN calls a shortfall.
• How payment is taken, the cancellation terms and the date the fees were last reviewed.

Clear fees answer patients first, and search reads the same page

The Order exists because the CMA found a lack of publicly available information on consultants’ fees (20.1). Google’s guidance on people-first content asks whether a reader leaves having learned enough to achieve their goal, or feels they need to search again elsewhere; for a patient choosing a consultant, cost is part of that goal. Write fees as text and link to them from each treatment page patients understand, as part of the practice copywriting of a site.

The UAE and Türkiye have their own rules on prices in health advertising, set out in the advertising licence for a UAE clinic website and one site or two for a clinic in Türkiye.

Common questions

Do we have to put our fees on the website?

The Order asks for a letter or email to each patient and figures for PHIN, not a fees page. Once a fee is on the site, the consumer and advertising rules apply to it.

Can we show a range when the fee varies?

A range works if the page explains what decides the final figure, as the Order allows for a consultant’s estimate; a page can also give a fee for each hospital.

This article explains the rules in general terms and is not legal or tax advice.

This is part of the practice-focused copywriting work on every website we look after.

References

1. Private Healthcare Market Investigation Order 2014 (as amended). Competition and Markets Authority. 2017. Available from: assets.publishing.service.gov.uk/media/59031bc240f0b606e3000265/private-healthcare-market-investigation-order-2014-as-amended.pdf [cited 2026 Oct 18].
2. Help understanding private hospital costs. Private Healthcare Information Network. 2026. Available from: phin.org.uk/help/about-private-hospital-pricing-in-the-uk [cited 2026 Oct 18].
3. Open letter to private healthcare consultants and hospitals: update on enforcement action under the Private Healthcare Market Investigation Order 2014. Competition and Markets Authority. 2023. Available from: assets.publishing.service.gov.uk/media/64ba47d106f78d00147426aa/Open_Letter_to_private_healthcare_consultants_and_hospitals.pdf [cited 2026 Oct 18].
4. Digital Markets, Competition and Consumers Act 2024, Part 4, Chapter 1: Prohibition of unfair commercial practices (sections 225 to 230). The National Archives (legislation.gov.uk). 2024. Available from: legislation.gov.uk/ukpga/2024/13/part/4/chapter/1/crossheading/prohibition-of-unfair-commercial-practices [cited 2026 Oct 18].
5. Providing clear and accurate information about prices: summary (Price transparency, CMA209). Competition and Markets Authority. 2025. Available from: gov.uk/government/publications/price-transparency-cma209/providing-clear-and-accurate-information-about-prices-summary [cited 2026 Oct 18].
6. CAP Code: 03 Misleading advertising. Committee of Advertising Practice. Available from: asa.org.uk/type/non_broadcast/code_section/03.html [cited 2026 Oct 18].
7. Health professionals and pharmaceutical products (VAT Notice 701/57). HM Revenue & Customs. 2026. Available from: gov.uk/guidance/health-professionals-pharmaceutical-products-and-vat-notice-70157 [cited 2026 Oct 18].
8. Creating helpful, reliable, people-first content. Google Search Central. 2026. Available from: developers.google.com/search/docs/fundamentals/creating-helpful-content [cited 2026 Oct 18].