What the UK’s Consumer Law Reform Means for Your Business and Your Consumer Strategy
Author: Sam Honey
Key Contact: Declan Goodwin
We take an in-depth look at how the Competition and Markets Authority (CMA) is expected to exercise its new enforcement powers under the Digital Markets Competition and Consumers Act 2024.
2025: A new era in consumer protection
From 6th April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCCA) ushers in one of the most significant changes to UK consumer protection law in over a decade. Businesses across all sectors – particularly those operating online or selling directly to consumers – must be ready to navigate this new regulatory landscape.
The DMCCA substantially enhances the enforcement powers of the CMA, allowing it to impose fines of up to 10% of global turnover for breaches of consumer protection law. Crucially, the CMA can now exercise these powers without recourse to the courts, dramatically increasing the likelihood of regulatory intervention.
New powers, clearer priorities
The CMA has made no secret of where it plans to look first. In its Annual Plan for 2025 to 2026, it has highlighted its focus areas for early enforcement. These focus on the most egregious harms, including:
- Aggressive sales tactics, especially those that target vulnerable consumers in high-cost or essential sectors;
- Objectively false or misleading information provided to consumers; and
- Clearly unfair or imbalanced contract terms.
The CMA’s recent and ongoing investigation into Ticketmaster’s sale of Oasis Live ’25 concert tickets exemplifies this shift in approach. The regulator is actively challenging pricing practices and transparency failures that may have misled consumers.
Key compliance areas: hidden fees, omissions and fake reviews
The revised legislation addresses a number of problematic practices, with immediate implications for businesses:
- Hidden fees: the CMA is taking aim at hidden fees revealed late in the purchasing process. Clear, upfront disclosure of total prices is now essential.
- Omissions: information must be timely, prominent and understandable. Gone are the days of hiding critical details (such as pricing or contractual terms) in the small print or behind multiple clicks. The CMA may now consider this practice a breach.
- Fake reviews: new rules impose proactive duties on businesses to prevent, detect and remove fake or misleading consumer reviews, including the implementation of internal policies and systems.
Subscription traps and vulnerability
Looking ahead to 2026, businesses offering subscription services may need to radically rethink their sign-up and cancellation processes. The DMCCA mandates easy cancellation and clearer upfront disclosures. Meanwhile, the guidance on vulnerability now considers a broader range of life situations – meaning your marketing practices may need to be tailored to more than just your “average consumer”.
Building compliance into business strategy
Where once consumer protection may have been considered a secondary legal issue, the DMCCA compels businesses to prioritise compliance in both their operational and customer-facing practices. The CMA now has powers to:
- Demand documents and data, with penalties for non-cooperation;
- Impose interface notices requiring changes to website or app design;
- Penalise misleading pricing, even where consumer behaviour isn’t demonstrably affected.
These developments reflect a clear intention to ensure consumer protection law is actively enforced, not passively encouraged.
A proactive approach is essential
To prepare for the new regime, businesses should:
- Audit their commercial practices to identify areas of legal risk;
- Review how pricing, reviews, and product information are presented to consumers;
- Ensure contracts and consumer terms are balanced and transparent;
- Implement processes to manage fake reviews and monitor online choice architecture; and
- Review the CMA’s guidance.
If you have any questions, or would like to ensure your company is compliant with the DMCCA, please contact our Commercial and Technology Team.
