Consumer-law compliance depends on what a customer sees and experiences, not simply the wording of the business’s terms and conditions. The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) makes that distinction commercially significant, particularly for businesses using online pricing, promotions and customer reviews.
Prices and reviews: the rules already in force
The Act’s unfair commercial practices provisions apply to conduct from 6 April 2025. They replace and update the Consumer Protection from Unfair Trading Regulations 2008, retaining many existing prohibitions and adding more specific rules on fake reviews and drip pricing.
An advertised price should include unavoidable charges where they can reasonably be calculated in advance. Where a charge cannot reasonably be calculated, the business must provide the information required by the pricing rules. Adding a mandatory fee only at the final payment screen can therefore be unlawful even if the customer can abandon the purchase.
Businesses publishing consumer reviews must take reasonable and proportionate steps to prevent and remove prohibited content, including fake reviews and reviews that conceal incentives. A statement that reviews are supplied by customers does not, by itself, discharge that responsibility. Review collection, moderation and complaint handling should be considered together.
The consequences of a breach
The Competition and Markets Authority can determine infringements through its direct enforcement process without first obtaining a court judgment. For a substantive breach, the maximum financial penalty is £300,000 or, if higher, 10% of worldwide turnover. That is a statutory ceiling, not an automatic penalty for every error.
The business can respond to the evidence before a final decision and has rights of appeal. An investigation or information notice should nevertheless be addressed promptly: failing to comply with procedural requirements can create separate exposure. Preserve relevant versions of webpages, advertisements and internal approval records.
Subscription contracts: prepare for a separate regime
The subscription-contract provisions have their own implementation timetable. Government draft guidance published on 19 October 2026 anticipates application to qualifying contracts entered into on or after 1 January 2027. However, it expressly states that the implementing regulations remain subject to parliamentary approval. These forthcoming requirements should not be described as already operative.
Businesses can prepare by reviewing pre-contract information, renewal reminders, cancellation processes and refunds. The final regulations, commencement provisions and sector exclusions must be checked before implementing the new regime. Existing consumer-law obligations continue meanwhile.
Review the whole sales process
Test the experience on a mobile device, including promotional landing pages and checkout. Identify who approves prices and discount claims, who investigates suspect reviews, and who can correct an error across every sales channel. Agencies and software providers should have clear contractual responsibilities, but outsourcing a process does not remove the need to assess the business’s own obligations.
Balaghi & Rose can advise on consumer-facing commercial terms and regulatory concerns. Contact our team to discuss the relevant sales process or correspondence.
General information only. This article concerns UK consumer legislation, with a practical focus on businesses in England and Wales, and reflects the position checked on 26 October 2026. It is not legal advice.
