Digital Markets, Competition and Consumers Act

Insight

07.01.2025

The UK Government has announced a target timeline for the implementation of the Digital Markets, Competition and Consumers Act (the Act), which received Royal Assent on 24 May 2024.

Changes to consumer law

The Act is focused on improving transparency for consumers and increasing competition among traders. The key changes to consumer law include:

Banning fake reviews: the Act prohibits the submitting or commissioning of fake reviews and will require businesses to take reasonable and proportionate steps to verify reviews.
Banning drip pricing: the Act also restricts "drip pricing" (hidden fees) and will require businesses to provide more information upfront, for example when advertising..
Stricter rules on subscription contracts: businesses will be required to provide clearer pre-contract information, reminders before a subscription renews and easier ways for consumers to exit these contracts.
Greater enforcement of consumer law: the Act enables the Competition and Markets Authority (CMA) to enforce consumer law directly (rather than having to go through the courts). Penalties will include issuing enforcement notices and imposing fines of up to 10 per cent of an infringer’s global annual turnover.

You can read about the detail of these changes in our article from earlier this year.

Timeline

On 9 September 2024, the Department for Business and Trade issued a statement setting out the Government’s target dates for implementing the Act. The changes to consumer law are expected to be implemented in the following order:

April 2025
- Direct enforcement powers of the CMA (Part 3).
- New rules on unfair trading practices, including fake reviews and drip pricing (Part 4, Chapter 1).
Spring 2026 onwards
- Reforms to subscription contracts (Part 4, Chapters 2 and 4).

What do I need to do?

With just over four months to go until the first major consumer law change and given the lead time for updating terms and conditions and back office systems, businesses will need to ramp up their preparations, especially in relation to drip pricing and reviews.

We recommend that businesses focus on:

auditing the existing customer journey to see how pricing and reviews work from initial marketing all the way through to checkout;
taking advice to assess compliance bearing in mind existing EU guidance in this area (although non-binding it is likely to be instructive) and the nuance inevitably involved in understanding how consumers may be affected by these practices;
updating terms and conditions and how those are implemented at each stage of the customer journey; and
training and raising awareness within the business.

We anticipate the CMA will issue revised guidance in the run up to the implementation and we will publish a separate article on that to keep you updated.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.