Most of the consumer aspects of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025.
This includes the repealed and replaced Consumer Protection from Unfair Trading Regulations 2008, which update the provisions about unfair commercial practices, as well as new powers for the CMA, including GDPR-style fines, and new rules about fake reviews and drip pricing.
The CMA has published guidance as follows:
- A short guide for businesses about how to treat consumers fairly.
- Full updated guidance on unfair commercial practices.
- How the CMA will use its direct consumer enforcement powers.
- Guidance about consumer enforcement.
- Guidance on fake reviews (with a short guide for businesses).
In March, Sarah Cardell of the CMA gave a speech in which she described how the CMA would approach enforcement during the first few months of the new consumer law regime. She also said that the CMA would be carrying out a further consultation about its guidance on drip pricing.
To start with, it plans to take a light touch to enforcement and focus on the most serious breaches. These might include aggressive sales practices that prey on vulnerability; providing information to consumers that is objectively false; or contract terms that are very obviously imbalanced and unfair. In addition, the Advertising Standards Authority has she ASA has also said that it will take into account the CMA’s guidance and approach.
The CMA has published an “Approach to Consumer Protection” which sets out:
- likely priority areas of enforcement and compliance activity
- how the CMA will reflect the government’s strategic steer and its own planned improvements to key aspects of the way it works (pace, predictability, proportionality and process – the ‘4Ps’ framework)
- what stakeholders can expect from the CMA.
The CMA and the UK government have also published a joint statement, reinforcing the CMA’s intended approach and the role of robust consumer protection in helping to grow the economy by promoting trust and confidence, while deterring poor corporate practices.
The subscriptions rules are due to come into force in the spring of 2026, while the provisions about digital markets and competition came into force on 1 January 2025.
