Since our last legislation update in January there is more to keep up-to-date on in the world of UK legislation.
Data protection
On 28 June 2021, the EU Commission published an adequacy decision in respect of transfers of personal data from the EU to the UK which had a sunset clause of 27 June 2025. With the expiry of UK adequacy looming, the EU has proposed to extend UK adequacy by 6 months in order for the UK data protection reforms to be finalised.
Speaking of UK data protection reform, this is progressing well and indications are the Bill may pass in April 2025. The main change made to the Bill as it has passed through the various Parliamentary processes is the extension of the PECR soft opt in for direct marketing to charities (currently it is only available to commercial organisations). You can read more about the reforms here.
Digital Markets, Competition and Consumers Act (DMCC)
Most of the consumer law provisions of the DMCC, which will affect most businesses providing goods and services to consumers in the UK, will come into force on 6 April 2025. This includes:
- The potential for fines of up to 10% of global turnover, which can be imposed by the Competition and Markets Authority (CMA) rather than a court process being required (although a court route is still available).
- The ability for the CMA to issue redress orders requiring non-compliant businesses to compensate consumers.
- Changes to UK consumer law (updating and replacing the Consumer Protection from Unfair Trading Regulations 2008) on pricing practices and fake or misleading reviews
The changes relating to consumer savings schemes (in Part 4 of Chapter 3 of the DMCC and related Schedule 2) will come into force until 1 January 2026.
There is still no fixed date for the changes in relation to subscription contracts although they are expected to take effect for contracts entered into from spring 2026.
You can read more about the CMA’s enforcement plans here.
Online Safety Act 2023 (OSA)
The OSA has already started taking effect. The deadline for in-scope services to complete compulsory illegal content risk assessments and implement safety measures to mitigate the risks identified has passed. Next steps for in-scope businesses can be found on Ofcom’s website. Ofcom is responsible for enforcing the OSA and can fine companies up to £18m or 10% of their global revenue (whichever is greater) for non-compliance.
Economic Crime and Corporate Transparency Act 2023
This Act will introduce a new corporate offence of failure to prevent fraud and comes into effect on 1 September 2025. You can read more here.
The Reporting on Payment Practices and Performance (Amendment) Regulations 2024
For financial years beginning on or after 1 January 2025 more extensive reporting requirements apply to large companies/LLPs subject to the statutory duty to report on their payment practices. You can read more here.
Price Marking (Amendment) Order 2024
Amendments to the Price Marking Order 2004, which will come into effect on 1 October 2025, aim to help consumers identify and compare unit and selling prices for goods. You can read more here.
Employment law
Labour has numerous proposals for employment reform stemming from its plan to Make Work Pay, described by Keir Starmer as “the biggest upgrade to workers’ rights in a generation”. Whilst some of Labour’s initial plans have been abandoned (including the right to switch off), the Government is pushing ahead with numerous wide-ranging reforms via the Employment Rights Bill.
From extending the Statutory Sick Pay regime to an estimated 1.3 million more employees, to regulating umbrella companies and making it easier for trade unions to gain recognition and organise industrial action, these changes will have a major impact on how employers manage their workforce.
The Employment Rights Bill is currently at Committee Stage in the House of Lords and it is anticipated that most changes will come into effect around October 2026.
You can read our Employment Team’s latest commentary on the proposed changes here:
Make Work Pay – Statutory Sick Pay
Make Work Pay – Collective Redundancy & Fire and Rehire
Make Work Pay – Umbrella Companies
Make Work Pay – Zero Hour & Agency Workers
Make Work Pay – Trade Unions
What to expect
With so much happening it looks like there will be a lot for in-house legal teams and compliance teams to keep up with in 2025.
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.
