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Today (6 April 2025) is the day that most of the consumer law provisions in the Digital Markets, Competition and Consumers Act come into force.
United Kingdom
Consumer Protection
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…and the CMA has published its final (ish) guidance.
Today (6 April 2025) is the day that most of
the consumer law provisions in the Digital Markets, Competition and
Consumers Act come into force. These include the CMA’s
extensive new enforcement powers and the recasting of the rules
around unfair commercial practices, including in particular rules
about drip pricing and fake reviews.
The CMA has published several pieces of guidance, which we will
discuss in more detail over the coming days, but in summary, the
guidance includes:
A short guide to how to treat consumers fairly;
Full updated guidance on unfair commercial
practices;
How the CMA will use its direct consumer enforcement
powers;
Guidance on consumer enforcement; and
Guidance on fake reviews (including a short guide for
businesses).
Last month, Sarah Cardell of the CMA gave a speech in which she set out the CMA’s
approach to enforcement in the first few months of the regime, and
indicated that the CMA would be carrying out a further consultation
about its guidance on drip pricing. In the meantime, it will take a
light touch to enforcement. Its early enforcement action is likely
to focus on the most serious breaches. These might include
aggressive sales practices that prey on vulnerability; providing
information to consumers that is objectively false; or contract
terms that are very obviously imbalanced and unfair. The ASA has
also indicated that it will have regard to the
CMA’s guidance and approach.
However, while a light touch to enforcement is welcome, traders
now need to comply with the new laws, there’s no leeway for
procrastination. If you haven’t looked at your terms of
business, sales practices and customer journeys, now is a good time
to start.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.