On 6 April 2025, significant changes to UK consumer protection law took effect under the Digital Markets, Competition and Consumers Act 2024 (the “Act”). These changes strengthen the enforcement powers of the Competition and Markets Authority (CMA) and introduce new rules targeting unfair commercial practices.

Previously, consumer protections were difficult to enforce in practice. That has now changed: the CMA can impose fines of up to 10% of a business’s global turnover for breaches of consumer law, require consumer redress, and issue legally binding directions to stop or correct unlawful conduct.

This article outlines the key changes introduced by the Act, the CMA’s new enforcement powers, and what businesses should do to comply.

What Has Changed?

While the Act broadly retains the substance of existing consumer law, it introduces new outright prohibitions aimed at curbing specific unfair practices:

1. Drip Pricing

Businesses must now present the total cost of a product or service up front, including all unavoidable fees, taxes, and charges. It is automatically considered an unfair practice to advertise a lower “headline price” and add non-optional costs later in the buying process.

2. Fake and Misleading Reviews

The Act bans:

· Commissioning or submitting fake reviews;

· Offering services that facilitate fake reviews; and

· Publishing reviews that are not based on genuine customer experiences.

Traders are under a positive duty to take “reasonable and proportionate steps” to prevent fake reviews from being posted on their platforms.

3. Subscription Contracts

The Act is aimed at ensuring consumers:

· Give informed consent before subscribing;

· Receive clear pre-contract and renewal information;

· Benefit from a cooling-off period at renewal; and

· Can easily cancel subscriptions without unnecessary obstacles.

These changes will apply to all businesses offering subscription-based services. You can read more about this here: https://www.berrysmith.com/news/are-you-stuck-in-a-subscription-trap-making-sense-of-subscription-contracts/

CMA’s New Enforcement Powers

The Act gives the CMA direct authority to enforce consumer law without court involvement. Key powers include:

· Issuing infringement notices;

· Imposing fines of up to 10% of global annual turnover for businesses, and up to £300,000 for individuals who are “accessories” to the breach; and

· Ordering businesses to provide consumer redress or take corrective action.

The CMA will approach consumer enforcement in line with its existing competition enforcement processes and can request information from businesses outside the UK if relevant to an investigation.

What Should Businesses Do Now?

To prepare for compliance and reduce enforcement risk, businesses should:

· Audit their consumer practices, particularly pricing structures, use of reviews, and subscription processes;

· Review and update terms and conditions, marketing strategies, and website disclosures;

· Train relevant teams, especially in sales and marketing, on the new rules around pricing transparency and review authenticity.