CMA’s consumer law enforcement priorities and finalised guidance for businesses

New consumer protection rules in the Digital Markets, Competition and Consumers Act (“DMCCA”) 2024 came into force on 6 April 2025 (except for subscription contract rules, which are expected in April 2026). They replaced and expanded the consumer protections set out in the Consumer Protection from Unfair Trading Regulations 2008. Practices such as “drip pricing” (fees that are hidden until late on in the buying process) and fake and misleading reviews are now considered unfair and banned practices under the DMCCA.

Under its new direct enforcement regime, the Competition and Markets Authority (“CMA”) can directly investigate and fine businesses which infringe the new rules up to 10% of global turnover, without recourse to a formal prosecution in the courts. This marks a changing of the tide in the UK’s consumer protection landscape which will see the CMA gaining the same powers for consumer protection law as it has for competition law enforcement.

We wrote a four-part series of articles on the new rules earlier this year:

1. The Digital Markets, Competition and Consumers Act 2024: Article 1 – scope, key changes and enforcement | Knowledge | Regulatory | Gordons
2. The Digital Markets, Competition and Consumers Act 2024: Article 2 – unfair commercial practices – overview and scope: misleading acts, omissions and aggressive practices | Knowledge | Regulatory | Gordons
3. The Digital Markets, Competition and Consumers Act 2024: Article 3 – automatically unfair commercial practices | Knowledge | Regulatory | Gordons
4. The Digital Markets, Competition and Consumers Act 2024: Article 4 – green claims | Knowledge | Regulatory | Gordons

The CMA has now published its “approach to consumer protection” document which sets out its priorities for the next year.

The CMA’s immediate focus will be on helping businesses comply through co-operation and the publication of further guidance, however this is likely to be coupled with significant levels of enforcement. This will be targeted in areas deemed to be of greater culpability and harm, particularly in areas where the law/obligations on businesses have not materially changed. Those include:

1. Aggressive sales practices that prey on vulnerable customers;
2. Drip-pricing;
3. Unfair contract terms;
4. Green claims;
5. Scarcity/urgency claims and misleading online architecture; and
6. Fake and misleading reviews (though businesses are likely to have an informal transitional period for compliance).

Final guidance has now been published on:

1. Unfair Commercial Practices;
2. Consumer Protection Enforcement Regime;
3. Fake Reviews; and
4. Enforcement and penalties.

The Advertising Standards Authority has also aligned the CAP (Committee of Advertising Practice) Code and BCAP (Broadcast Committee of Advertising Practice) Code with DMCCA.

For more information or if you have any questions about how businesses can adapt to the now in-force rules, get in touch with a member of our Regulatory team.