Key points

• Since April 2025, the Competition and Markets Authority has been able to decide for itself whether consumer protection law has been breached and to impose fines of up to 10 percent of global annual turnover, without going to court.
• The Digital Markets, Competition and Consumers Act 2024 also introduced new banned practices, including fake reviews and hidden or drip pricing, and made the rules on pricing transparency more explicit.
• The CMA has signaled that online pricing and review practices are early priorities and has opened investigations into pricing practices across several sectors.
• Fines are not the only consequence. Undertakings, compliance programs, consumer redress and reputational harm often matter more in practice.
• Companies should test their pricing journeys, review handling and urgency claims against the new rules now, and be ready to respond quickly to information requests.

What changed in April 2025

Before April 2025, the CMA could investigate consumer law breaches but needed to go to court to establish infringement and secure penalties. The consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) changed this. The CMA can now investigate suspected breaches, reach its own decision and impose financial penalties of up to 10 percent of a business's global annual turnover. Separate penalties can apply for failing to comply with information requests. Businesses can appeal to the Competition Appeal Tribunal.

The same regime applies across the economy, so retailers, travel businesses, ticketing platforms, subscription services and financial services firms are all within reach. The Act also lets the CMA obtain undertakings, issue directions and, in appropriate cases, require redress for consumers.

New and clarified prohibitions

The Act added a list of practices that are banned outright. Among them are submitting or commissioning fake reviews, and hosting reviews without taking reasonable steps to ensure they are genuine. It also strengthened the rules on drip pricing, requiring that the total price, including mandatory fees, be shown upfront. Pressure-selling and misleading urgency claims remain central concerns, and the CMA's published guidance sets out its view of how the rules apply.

A new regime for subscription contracts is also being brought into force, with requirements about pre-contract information, reminders and easier cancellation. Companies with recurring revenue models should confirm the commencement timetable and plan system changes well ahead.

How the CMA has used its powers

In the first year the CMA concentrated on publishing guidance, engaging with industry and opening a series of investigations, particularly around online pricing and price presentation. It has been clear that it prefers to resolve concerns through undertakings and compliance changes where businesses engage constructively, but it has also said it will use fines where there is evident non-compliance.

The CMA also continues to work alongside other regulators, including sector bodies and trading standards. Companies should expect that findings in one forum may be referenced in another, and that internal documents describing how a practice was designed will be closely examined.

Individual and corporate exposure

The Act gives the CMA wider reach over those who are responsible for infringements. Directors and managers whose consent or neglect contributed to a breach can face scrutiny, and the CMA's published position emphasizes that senior accountability is part of its approach. This matters for governance. Boards should be satisfied that someone owns consumer law compliance, that issues are escalated, and that monitoring covers marketing, pricing and customer service teams, not just legal.

Consumers can also seek redress through existing private rights, and the Act's regime has added to the sense that failing to engage with complaints is costly.

What businesses should do

Start with the customer journey. Test the whole path from advertisement to checkout and confirm that headline prices include everything that is mandatory. Document the logic for any urgency or scarcity message, and make sure the claim is true when displayed.

Review how reviews are collected, moderated and displayed. Records showing the steps taken to prevent fake reviews are essential. Where reviews are incentivized, disclosure must be clear.

Review subscription flows against the forthcoming requirements, and confirm that cancellation is as easy as sign-up.

Prepare for engagement. Decide in advance who handles a CMA information request, how documents will be preserved, and how legal privilege will be protected. Early, well-organized responses often shape the course of an investigation.

Consider a short program of privileged compliance reviews in the highest-risk areas, with findings reported to the board or its audit committee.

Sector considerations

Ticketing, travel and hospitality businesses are exposed because their prices often include booking fees, service charges and optional extras added late in the journey. Retailers face questions about reference pricing and promotional claims, and marketplaces face questions about the extent to which they are responsible for reviews and seller practices. Financial services firms must continue to meet sector rules while also taking account of the general consumer regime.

Groups operating across several European markets should also remember that the DMCC Act applies in the United Kingdom, and that parallel rules in the European Union follow different procedures. A single global design for pricing and reviews is efficient, but it must meet the strictest applicable standard.

Looking ahead

The consumer regime is still bedding in. The first formal infringement decisions will set expectations about penalty levels and procedure, and appeals to the Tribunal will test the CMA's approach. In the meantime, the best protection is a compliance program that is demonstrably current, tested and owned at senior level.

Corvane Ryle's Consumer Protection and Antitrust & Competition teams in London and Chicago advise on CMA investigations, compliance reviews and the design of consumer-facing practices.