After signalling a tougher stance on consumer protection early in 2025, the U.K. Competition and Markets Authority (CMA) delivered on that promise by launching a “major consumer protection drive” in November 2025. The Digital Markets, Competition, and Consumers Act 2024 (DMCCA) marks a structural shift in UK consumer enforcement. It significantly enhances the CMA’s powers, most notably by enabling it to impose direct administrative fines of up to 10% of global annual turnover for consumer law breaches without court involvement. The CMA may also take action against overseas traders targeting U.K. consumers, order compensation or other consumer redress, and impose daily penalties for non-compliance with investigative measures. No longer dependent on court proceedings or negotiated commitments, the CMA can now intervene more quickly and decisively. The DMCCA also expands the substantive consumer protection framework, including prescriptive rules on subscription contracts; broader prohibitions on unfair commercial practices; and new rules regarding consumer alternative dispute resolution. In April 2025, the CMA identified its initial DMCCA priorities: behaviours that are particularly harmful to consumers and amount to clear legal infringements, including drip pricing, fake reviews, aggressive sale practices, and unfair and unbalanced contract terms. The November 2025 announcement demonstrates a shift from signalling to visible, deterrence-oriented enforcement, with the CMA confirming it has: • Opened the first publicised DMCCA enforcement actions, investigating eight businesses across secondary ticketing, homeware retailers, driving schools, and gyms. The cases focus on alleged hidden fees, misleading time-limited offers, and/or automatic opt-ins for optional charges. • Written to 100 businesses across 14 sectors, directing them to review their pricing and sales practices. These businesses were identified through compliance sweeps monitoring over 400 businesses in 19 sectors since April, targeting sectors with notable consumer spending or emerging concern. • Published its final Price Transparency Guidance, setting out detailed expectations for presenting pricing information, avoiding drip pricing and “partitioned pricing” and providing compliant invitations to purchase. Early enforcement focuses on two practices prohibited under the DMCCA: drip pricing and pressure selling. Drip pricing occurs where headline prices omit mandatory fees that surface later during the checkout journey, despite requirements for upfront disclosure. Pressure selling includes misleading urgency cues that unfairly accelerate consumer decision-making. The CMA’s message Although these are the first publicised enforcement actions, the CMA has been engaging with other businesses privately for months. Strategically, it is clear that every online business is in-scope, and significant penalties are possible. While initial investigations focus on areas long considered concerning under the pre-existing regime, the CMA’s enforcement targets are now sector-agnostic, capturing essentially any businesses selling or presenting pricing to U.K. consumers online. This shift from the historical trend of sector-focused enforcement signals a potential intention by the CMA to demonstrate breadth and market-wide deterrence in DMCCA enforcement. The CMA can also pursue non-UK traders directing activities at U.K. consumers, meaning global digital platforms and overseas retailers should assess U.K.-facing customer journeys carefully. Where infringements are identified, the CMA may issue formal notices requiring remedial action and impose fines of up to 10% of global annual turnover, alongside daily penalties for ongoing non-compliance (all without court involvement). Takeaways for in-house teams

1. Audit customer journeys: In-house teams should work closely with product, marketing and engineering to map complete customer journeys from advertising and search results through to product display/landing pages, checkout and post-purchase stages. All fees, charges, taxes and surcharges should be classified as mandatory or optional, with mandatory charges clearly included in invitations to purchase. Particular care is needed for dynamic, personalised and loyalty pricing interfaces.
2. Scrutinise urgency and scarcity claims. In-house teams should help verify the logic, accuracy and data underpinning countdown timers and claims like “only [X] left” and “[X] people are viewing this now”. Where claims cannot reliably be substantiated with robust data, they may need to be removed or redesigned. Clear internal approval processes for deploying such claims help ensure compliance and operational efficiency for marketing and product teams.
3. Build cross-functional governance and retain evidence of compliance. In-house teams should help implement cross-functional governance frameworks for consumer law compliance and detailed documentation of risk assessments, decision-making and remediation decisions. They should help prepare playbooks for CMA engagement, including response strategies to information requests, settlement options and handling parallel regulatory scrutiny in other jurisdictions. Where compliance changes impact revenue, in-house teams should help explain the risk-reward balance and document key decisions.
4. Integrate U.K. rules into multi-jurisdictional strategies. With increasing overlap across U.K., U.S. and EU regulatory enforcement, multinationals should identify where UK rules exceed other regimes and decide whether to harmonise globally or adopt UK-specific design solutions. For in-house legal teams, the takeaway is clear: online pricing architecture, fee structures and digital design are now core legal risk areas. Where businesses sell to U.K. consumers online, legal functions must play a central role in governing pricing and customer journeys, embedding compliance into cross-functional decision-making and evidencing it in an increasingly assertive enforcement environment. Clive Gringras is a partner and Ed Roper a senior managing associate at Sidley Austin.