Enhanced UK consumer protection regime takes effect

On 6 April 2025 the UK's new consumer protection regime came into force. The changes have been made by the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), perhaps better known for creating a new digital markets regime regulating large technology platforms, but a considerable part of the DMCC Act also deals with consumer protection legislation, overhauling the previous regime.  The DMCC Act introduces a new direct enforcement regime for the CMA and makes a number of changes to the substantive law, aimed at improving and modernising consumer rights in order to ensure they keep pace with market developments, in particular the trend towards online retail and advertising.

The CMA has published its approach document, setting out its enforcement priorities for the first 12 months of the new regime. The CMA has indicated that its early enforcement will focus on the most serious infringements such as aggressive sales practices that prey on vulnerability, providing information to consumers that is objectively false, fees that are hidden until late in the purchase process and contract terms that are very obviously imbalanced and unfair. The approach document also explains how the CMA will apply its '4Ps' framework, with focus on pace, predictability, proportionality and process, to the new consumer protection regime.

The CMA makes it clear that it will support businesses who want to do the right thing but who may be unclear on exactly what is needed to ensure compliance, especially in areas where the law has been updated or there is less clear-cut precedent. It will take into account any proactive steps taken by businesses to remedy infringing conduct when deciding the appropriate level of a penalty. In addition, the CMA is running an extensive outreach business programme to assist businesses with understanding the changes and start preparing for the new regime.

See our briefing here for a more detailed overview.