Under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), the Competition Markets Authority (CMA) was given a new statutory function with powers to determine breaches of consumer protection laws. This included direct enforcement and sanctioning powers, including the ability to impose significant financial penalties on infringing businesses without the need to go to court. Just over six months on, this article reviews how the CMAs enforcement strategy is taking shape both to address breaches and encourage compliance, and what we might expect for the coming year.
Tackling consumer harms
In April 2025, the CMA outlined its year-one approach for exercising its new function, as businesses navigate and adapt to the new rules. It has recently reiterated that a core focus continues to be tackling egregious harm to consumers specifically to ensure that consumers can:
1. Shop online with confidence, without being manipulated by misleading information such as false scarcity and urgency messages, or by fake reviews.
2. Access clear, accurate and complete pricing information, by tackling things like drip pricing and misleading sale prices.
3. Exercise their legal rights when things go wrong, by tackling unfair cancellation and refund policies, and unfair contract terms.
In line with these ambitions, the CMA has:
- Tackled information practices on websites such as Amazon and Ticketmaster. In June 2025, Amazon was required to give undertakings to the CMA committing to enhance its existing systems for tackling fake reviews. Undertakings from Ticketmaster to tell fans at least 24 hours in advance if a tiered pricing system is being used for ticketing and provide more information during online queues to help fans anticipate how much they might have to pay.
- Undertaken a large-scale compliance audit for the new rules on fake reviews which included a web-sweep of over 100 businesses and resulted in advisory letters being issued to over 50 businesses.
- Exercised its new powers to require businesses to provide information to the CMA prior to the CMA formally launching an investigation, resulting in information notices being issued in relation to potential enforcement cases across a range of sectors and practices.
- Implemented processes to facilitate monitoring and action at scale, including use of cutting-edge tech and AI tools to identify and capture evidence of infringements and to support evidence review.
Supporting businesses
While the CMA has stated that ensuring harmful conduct is stopped quickly and that consumers are compensated its approach is not one-sided. Engagement and education for businesses are a core part of its current regulatory strategy, to help businesses understand and apply the new rules, in particular on fake reviews, pricing transparency and complaints processes. Key new resources include:
- Online reviews guidance delivered by webinar and attended by over 200 businesses and advisors.
- Complaints guidance for business and consumers to support greater reporting potential breaches to the CMA via well-reasoned and evidence backed complaints. Part of the CMAs function is to promote competition and it recognises that fair dealing businesses also lose out when competitors flout the regulations.
- Price transparency guidance, published following public consultation and feedback from a large number of business and consumer bodies.
- Updated social media reviews and endorsements resources for businesses marketing via social platforms.
Looking ahead
While the CMA has some sharp statutory teeth at its disposal, its core messaging remains to safeguard consumers rights whilst helping businesses to adapt to and comply with the new regime. It emphasises that collaboration and compliance will make the market fairer for everyone. Guidance and support for businesses remains part of the CMAs strategy for the coming months, with new guidance on unfair contract terms among its next declared initiatives.
That said, as we move towards the end of the CMAs first year as consumer law regulator, we can expect to see enforcement actions intensify, including against significant market players and household names. We should expect to see outcomes of investigations into offences such as drip pricing, for example, very shortly.
If you would like advice on how the new DMCCA rules affect your business and achieving compliance, please contact a member of the Commercial and Technology team at [email protected].
