On 6 April 2025, new rules that overhaul the UK’s consumer law regime came into force through the unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 (Act).

Prior consumer law protections were extremely difficult to enforce. This has changed because the UK Competition and Markets Authority (CMA) now has direct enforcement powers to impose fines of up to 10% of global turnover on businesses that infringe consumer law. They also have additional powers to require redress to consumers, and/or to issue “directions” to infringing businesses to correct their behaviour.

In this article, we set out the key information which businesses should familiarise themselves with, in respect of the new regime and the enforcement powers available to the CMA, what they can expect from the CMA going forward and what activities the CMA is likely to direct their focus to.

What consumer laws have changed?

Whilst the Act broadly maintains the scope and effect of existing consumer law rules, the new regime now introduces a prohibition on ‘drip-pricing’, as well as a prohibition on submitting, commissioning or facilitating fake or misleading reviews. In connection with this, the Act places a positive obligation on traders to take ‘reasonable and proportionate steps’ to stop fake reviews being posted on their website.

1.     Drip pricing – it is now automatically deemed unfair if a business shows a customer a cheaper headline price for a product in its invitation to purchase, but then later adds non-optional charges to the initial price at the end of the purchasing process. Consumers must be provided with the total price of the product in the invitation to purchase, which includes any fees, taxes or other charges that the consumer will incur if the product is purchased.

2.     False reviews – commissioning another person to write fake reviews or offering services to businesses to facilitate or to submit, commission or publish such fake reviews, are all banned. This also includes the submission or publishing of a consumer review that is not based on a person’s genuine experience, but purports to be.

What else is changing?

In addition to the above changes, from April 2026, traders will also be subject to additional obligations in connection with subscription contracts to make it easier for consumers to provide informed consent and to opt out of auto-renewal contracts.

Obligations will be placed on businesses that require them to provide consumers with clear pre-contract information and reminders before a contract is automatically renewed. Consumers will also need to be granted a ‘cooling off’ period on renewal and businesses will need to ensure the cancellation process is quick, straightforward and easy.

What powers are available to the CMA?

The Act empowers the CMA to directly enforce consumer protections through administrative proceedings, without having to go to court. The CMA now has the power to:

• issue direct infringement notices to traders in suspected breach of consumer law;
• impose fines of up to 10% of annual global turnover, as well as personal fines of up to £300,000 to persons who are an ‘accessory’ to substantive consumer law infringements by a business; and
• impose enhanced consumer protection measures, such as redress orders.

These enforcement powers mirror the CMA’s competition law rules, and recent guidance confirms that the CMA will approach consumer law enforcement using a similar framework to its competition law investigations. It is worth noting that the CMA can request information from businesses in connection with its investigations on an extraterritorial basis.

CMA’s focus

The CMA has stated that it intends to take a proportionate approach to enforcement and to help businesses minimise compliance burdens. In the next 12 months, the CMA expects to focus its early enforcement efforts on serious consumer law breaches, including:

• aggressive sales practices that prey on vulnerable consumers;
• the provision of objectively false information to consumers (such as countdown timers);
• hidden fees and the use of pre-ticked boxes that lead to unintended purchases; and
• clearly unbalanced and unfair contract terms in breach of the Consumer Rights Act 2025, including those imposing unfair exit charges.

The CMA is also expected to work closely with other enforcers such as Trading Standards and the EU Consumer Protection Cooperation network, as well as consumer groups such as Which and Citizens Advice, to maximise the impact for consumers.

Businesses should therefore conduct a thorough review of their business models to identify any automatic renewal agreements and noncompliant practices and processes, to ensure prompt compliance with the Act. Marketing and sales teams will need to be updated on the drip-pricing rules and the use of fake reviews, to avoid bad behaviour.

Should you require any assistance in reviewing your existing trade practices and consumer-facing terms of business, please get in touch with a member of the Geldards Commercial Team, who will be happy to assist.