Six Months On From DMCCA: CMA’s Priorities, Early Action, and What’s Next for UK Consumer Law Enforcement

With the introduction of direct consumer enforcement under the Digital Markets, Competition and Consumers Act (the DMCCA) in April 2025, the UK’s consumer protection landscape reached a turning point. Six months on, Emma Cochrane, Acting Executive Director of Consumer Protection at the Competition and Markets Authority (the CMA) has published an assessment of the CMA’s early impact - highlighting the areas where it has taken action already, the support available to businesses, its commitment to clearer guidance and what’s next (spoiler alert (although no real surprises): it is poised to open cases). We set out below the key updates from the announcement.

CMA’s priorities: tackling egregious harm

The CMA reaffirms that it is targeting the practices most likely to harm consumers and highlighted key priorities including:

• Ensuring consumers shopping online are not exploited by misleading online choice architecture (e.g., misleading scarcity and urgency messages, and fake reviews).
• Ensuring consumers get clear, accurate and complete pricing information (including action on drip pricing and misleading sale prices).
• Enabling consumers to exercise their legal rights by tackling unfair cancellation/refund policies and unfair contract terms.

Enforcement in practice

Over the last six months, the CMA says that it has:

• Taken action against leading online shopping platforms, such as Amazon, setting important precedents for digital retail compliance.
• Taken steps to enhance compliance with the new rules on fake reviews on a sector-wide basis.
• Continued to monitor compliance with consumer law efficiently and at scale, using advanced technology and AI tools.
• Leveraged its new DMCCA powers to actively gather evidence directly from businesses and has already issued information notices in anticipation of potential enforcement action across multiple sectors and practices. 

Support and new resources for businesses

The CMA also underlines its commitment to helping businesses comply including: 

• On fake reviews, by conducting a compliance sweep of over 100 businesses in July, followed by sending advisory letters to over 50 businesses.
• An enhanced complaints process for businesses to alert the CMA on suspected breaches.
• New and refreshed guidance, including on price transparency (final guidance due “in autumn” following consultation) and a forthcoming refresh on unfair contract terms guidance.

Looking ahead

The CMA has been busy but says it “is just getting started”. 

The CMA plans to open enforcement cases “soon”, following recent evidence gathering. It warns that its early cases will focus on “egregious conduct where there are clear infringements of law”, and specifically mentions practices concerning misleading online choice architecture and drip pricing.

Formal investigations may not be the most appropriate outcome of early investigations, and the CMA has said that it may instead issue an advisory letter or continue to monitor business conduct. However, the CMA reminds businesses of the importance of compliance with their information requests; a failure to comply (without reasonable excuse) could now result in fines of up to 1% of turnover.

To explore these developments in more detail and understand what they mean for your business, join our webinar “UK consumer law in transition – enforcement, guidance and what’s next” this Thursday, 13 November. We will cover the CMA’s priorities, practical compliance steps, and what’s on the horizon. Be sure to register. 

For more information and regular updates about the DMCCA, please check our DMCCA Client Toolkit. If you are not a subscriber and do not have access, you can subscribe by clicking on this link.