Guide To The Digital Markets, Competition and Consumers Act

The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) is now law, replacing the Consumer Protection from Unfair Trading Regulations 2008 and significantly strengthening the UK’s consumer‑protection framework.

The DMCC Act, which took effect on the 6 April 2025, gives the Competition and Markets Authority (CMA) new powers to directly enforce consumer law and issue substantial financial penalties. It also introduces new rules on fake reviews, drip pricing and a comprehensive subscription‑contract regime. This updated guide summarises the changes most relevant to SMEs and online businesses.

Previously, the Competition and Markets Authority (CMA) had relied upon voluntary adherence to the guidelines it set, since they had no power to impose fines, even after having secured a court order for compliance. However, the DMCC Act now gives the CMA direct authority to determine breaches of consumer law and issue substantial financial penalties. Such penalties can include fines of up to 10% of global turnover for businesses and £300,000 for individuals. These powers are one of the biggest changes to consumer law in the past 15 years.

In real-world practice, such increased powers may make it easier for the CMA to investigate the huge post-queuing ticket price inflation that Oasis fans were subject to by Ticketmaster during the bands 2025 tour. Furthermore, if ticketing platforms are found to have used ‘dynamic pricing’ in a way that does not comply with regulations, then the CMA will now have the authority to issue fines directly.

There are many parts of the new Act that are likely to be relevant only to very large organisations. So, for the purposes of this guide, we’ll focus on any new rules or legislation within this Act that SMEs should be aware of.

Fake Reviews

The DMCC Act creates a new, standalone ban on fake reviews that is automatically considered illegal without needing to prove consumer harm. This covers submitting or commissioning fake reviews as well as hosting or publishing them without taking reasonable and proportionate measures to prevent their appearance.

This requirement is stricter than current EU regulations, which only mandate verifying the origin of reviews if the seller claims they come from genuine customers. The government, alongside the CMA, will issue formal guidance, but the prohibition itself is already contained within active legislation.

Drip Pricing and Hidden Fees

The DMCC Act has made drip pricing rules tougher and clearer, specifically targeting surprise charges appearing late in online checkouts. Under the new regulations, sellers must clearly state the total unavoidable price upfront, including any fees, taxes, and charges, as well as any mandatory variable costs and how they are calculated. This serves as a primary compliance milestone for online retailers, travel agencies, and event hosts.

Subscription Terms

The DMCC Act establishes a proactive new framework for subscription contracts, which are agreements that automatically renew for a fixed or indefinite period, obligating consumers to continue payments until they cancel.

To stay compliant with these new regulations, businesses must provide clear pre-contract information, ensuring consumers understand key aspects of the subscription, such as price changes, cancellation procedures, and notice periods.

Additionally, consumers are granted a 14-day cooling-off period, during which they can cancel the subscription and receive a refund without penalty, which applies at the start of a contract and upon the automatic renewal of any long-term subscription.

The regime also requires businesses to send regular written reminders via a durable medium (like email or SMS) before renewals or the end of free trials or discounted periods, helping consumers stay informed about their options. Furthermore, termination procedures must be straightforward, allowing consumers to end their contracts with a clear declaration of intent through an exit route that is just as easy as the sign-up process. Given the significant obligations and the zero-grace-period expectation for January 2027, businesses must begin auditing their consumer subscription paths immediately.

When is this happening?

While changes were initially scheduled for Spring 2027, Prime Minister Andy Burnham has brought the implementation deadline forward to January 2027, to protect consumers signing up for services in the new year.

Burnham is also planning to prohibit “pretend prices”, which is the practice of falsely advertising products at a previously higher price, aimed to trick the consumer into thinking they are buying something on sale. This is a tactic generally considered unlawful however not definitively blacklisted, so currently the CMA must undertake a convoluted process of proving consumer harm, to penalise businesses. This prohibition would significantly improve consumer protection and transparency.

Finally, the DMCC Act also raises the bar with regards to the protection of vulnerable persons. When commercial practices target or reach groups who are particularly vulnerable, whether that is due to age, mental or physical health, or financial circumstances, the law judges the fairness of the practice against an average member of that vulnerable group rather than the general public. SMEs must ensure that marketing, sales funnels, and cancellation terms do not take advantage of vulnerable demographics. 

What Might The Digital Markets, Competition and Consumers Bill Mean For You?

There are some policy changes and new rules in the DMCC Act, as outlined above, that you should know about, especially if you are selling to the general public. However, the overriding changes are the increased powers to the CMA which enables direct enforcement of the regulations laid out in this Act. For example, the CMA can now impose a maximum penalty of 10% of the business's global annual turnover or £300,000 (whichever is higher) for a breach of consumer law. Therefore, businesses are advised to familiarise themselves with this Act and ensure they are compliant.

Do you need legal advice and contracts created for your online business? My e-commerce package includes:

• Website legal audits/advice on website updates required to ensure legal compliance.

• Website terms and conditions.

• Privacy Policy and required customer notifications on your site where personal data is collected.

• Cookie Policy and Cookie pop-up notice requirements.

• Website information requirements.

• Sale of online goods/services terms and conditions.

• Copyright legends and advice on content protection.

• Online Membership - legal advice and required documentation.

Please get in touch if you’d like to know more.

*Please be aware that this guide does not outline every change, update or new regulation introduced in this Bill, rather we are just highlighting a few key areas. Please read the Bill to be fully informed.