A new era of consumer protection law enforcement is here to stay
The Competition and Markets Authority (CMA) is making full use of its enhanced consumer enforcement powers under the Digital Markets, Competition and Consumers Act 2024 (DMCC).
On 23 June 2026, the CMA confirmed that, since those powers came into force, it has secured over £1.95 million in refunds for customers and imposed fines exceeding £5 million. Between April 2025 and April 2026, the CMA also opened investigations into 14 businesses (reaching settlements in two cases), issued 157 advisory and warning letters and sent 46 information notices.
These figures underline a clear message: direct enforcement by the CMA is now a central feature of the UK consumer protection law landscape.
What changed and when?
Most of the DMCC’s consumer protection provisions came into force on 6 April 2025. These reforms affect the vast majority of businesses supplying goods, services or digital content to UK consumers.
Key changes include:
- Direct fining powers – The CMA can now impose fines of up to 10% of global turnover without needing to go through the courts (although a court-based route remains available).
- Refunds – The CMA can require businesses to compensate consumers directly through redress orders.
- Updated rules on pricing and reviews – The DMCC updates and replaces aspects of the Consumer Protection from Unfair Trading Regulations 2008, including tighter rules on price transparency and fake or misleading consumer reviews.
The DMCC also makes changes relating to subscription contracts, but those are not yet in force.
The CMA’s initial focus
Since April 2025, CMA enforcement activity has focused on three key areas:
- Drip pricing – Presenting a low headline price, with additional mandatory fees added later in the purchasing process.
- Fake and misleading reviews – Submitting or commissioning fake reviews, failing to disclose incentivised reviews and presenting review information in a misleading way.
- Online choice architecture (OCA) – Designing online journeys to influence consumer decisions, including through urgency claims or scarcity messaging.
Investigations
The CMA has launched a number of high-profile investigations across different sectors.
This includes an investigation into five companies as part of its “crackdown” on fake and misleading reviews across various sectors including funerals, food delivery and car sales. The issues under consideration included suppression of negative reviews, inflation of star ratings, misleading reviews written by non-customers and undisclosed incentivised reviews.
The CMA has also launched targeted investigations in relation to:
- Adobe – Considering whether Adobe’s early cancellation fees on membership plans for certain products were unfair and whether customers were given clear and timely information about those fees upfront.
- Ryanair – Considering whether additional charges for parents to sit with their children are fair and whether the mandatory family seat fee is “dripped” during the booking process.
Enforcement action in practice
Fine – Euro Car Parks
The CMA issued Euro Car Parks Ltd with a fine of £473,000 for failing to comply (without reasonable excuse) on time with a formal CMA information notice.
Fine and refunds – The AA and BSM driving schools
The AA and BSM driving schools were fined £4.2 million (reduced from £7 million due to co-operation and early settlement by The AA which owns both driving schools) after the CMA found evidence of drip pricing. Over 80,000 customers were not shown the total price they would have to pay upfront when booking lessons online (a mandatory £3 booking fee was added later in the ordering process).In addition to the fine, the CMA ordered the two businesses to repay over £760,000 to affected customers so the total financial impact of the CMA’s action was over £5 million.
Fine and refunds – Marks Electrical
The CMA fined Marks Electrical £720,000 for breaches of consumer law identified by the CMA and ordered it to refund around £600,000 to customers. The CMA’s investigation looked at conduct from April to November 2025 during which time Marks Electrical were found by the CMA to be automatically opting customers into optional paid-for additional services without express customer consent.
Fine and refunds – StubHub
The CMA fined secondary ticketing platform StubHub UK £889,200 and also ordered it to pay refunds to more than 50,000 customers of over £590,000 for breaches of consumer protection law for drip pricing. StubHub added mandatory delivery and service fees at the end of the checkout process, meaning consumers were not provided with the total price they would have to pay at the start of the purchasing journey.
Key lessons for consumer-facing businesses
- Engagement with regulators matters – Early engagement, co-operation and remediation can materially reduce penalties.
- Price transparency is critical – Hidden or “dripped” charges remain a primary enforcement priority.
- Online journeys should be reviewed – Businesses should audit customer journeys to ensure pricing is clear and consent mechanisms are fair and unbiased.
- Consent must be meaningful – Passive mechanisms (such as pre-ticked boxes) are unlikely to constitute valid consent.
What to expect in year 2 of the DMCC
The CMA says it will continue to focus on areas of essential spend where consumers feel the pinch most, as well as practices that are widespread and cause significant harm and says that businesses should prioritise compliance in the following areas:
- Price transparency – Don’t use hidden, ‘dripped’ or unlawful partitioned pricing and discount claims must be true, accurate and not misleading.
- Fake reviews – Have robust policies in place so reviews give consumers an honest picture and make sure your employees are implementing them.
- Terms in contracts with consumers – Review your terms carefully (especially any that impose exit fees) against the CMA’s guidance once it is published later this year.
- Subscription contracts – The new rules are expected to come into force in spring 2027 but detailed guidance is still awaited.
- Responsible use of AI, including agents – The CMA has recently published advice offering practical tips on using agentic AI responsibly.
How we can help
The CMA’s new powers mean enforcement is faster, more direct and more financially significant than ever before.
If you would like advice on reviewing your consumer-facing practices or managing regulatory risk, please contact our team.
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Disclaimer
This information is intended for general informational purposes only and does not constitute legal advice. We recommend seeking professional advice before taking any action on the information provided. If you would like to discuss your specific circumstances, please feel free to contact us on 0800 2800 421.
