
If your business advertises to UK consumers – whether you’re selling beauty products, running a gym, or offering subscription boxes – the new Digital Markets, Competition and Consumers Act 2024 (DMCCA) should be firmly on your radar.
Coming into force in April 2025, the DMCCA is the biggest overhaul of UK consumer protection law in decades. And it’s not just a case of updating your terms and policies – the Competition and Markets Authority (CMA) now has serious teeth, with direct enforcement powers and hefty fines for non-compliance.
If you’re advising the business on sales, advertising, or consumer terms, here’s what you need to know.
What’s changed?
The DMCCA targets common sales and marketing practices that regulators say have misled or disadvantaged consumers. Some of the key areas you’ll want to review include:
- Fake reviews. Businesses are banned from commissioning or publishing fake reviews. That includes incentivising reviews without clear disclosure or failing to take reasonable steps to verify authenticity.
- Drip pricing. All unavoidable charges – booking fees, admin costs, delivery fees – must be disclosed upfront. Hiding charges until checkout is no longer allowed.
- Subscription traps. If your business uses subscription models (gym memberships, apps, food boxes), you’ll need to tighten pre-contract information, make cancellation easier, and send clear reminders before free trials end.
- Direct enforcement powers. The CMA can now impose fines of up to 10% of global turnover for breaches, without needing to go through the courts first. Compliance is now a financial as well as a legal risk.
What in-house lawyers should focus on
With enforcement risks higher than ever, now’s the time to:
- Audit pricing and checkout flows. Are all compulsory charges shown upfront – not hidden during checkout?
- Review your use of customer reviews. Can you evidence that reviews are genuine and any incentives are properly disclosed?
- Tighten up subscription journeys. Make sure sign-ups, terms, and cancellations are frictionless and clear, with reminder notices sent in good time.
- Update your internal training. Marketing, sales, and product teams need practical guidance on the new rules – not just a policy gathering dust.
Final thoughts
The DMCCA means greater scrutiny, faster enforcement, and bigger consequences. It’s not just about fair trading anymore – it’s about safeguarding the business against enforcement action that could hit the bottom line hard.
Getting ahead of this isn’t just smart risk management – it’s a chance to show real value by making the consumer journey cleaner, clearer, and legally watertight.
the plume press
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