In October 2025 the Competition and Markets Authority (CMA) issued guidance on how to make a competition or consumer law complaint. The guidance sends a clear message, the CMA wishes to encourage a greater volume of well reasoned, quality complaints and to bolster its enforcement activity.

The release of this guidance marked six months since the consumer aspects of the Digital Markets Competition and Consumer Act 2024 (DMCCA) came into force.

In this article we explore how the CMA is acting on its strengthened enforcement under the DMCCA including recent actions on price transparency and fake reviews.

DMCCA 2024: a brief recap of the key consumer law changes

Unfair commercial practices: Updates to certain aspects of consumer law including those relating to unfair commercial practices (with particular focus on 'drip' pricing and fake or misleading consumer reviews).

Subscription contracts: New requirements in relation to subscription contracts, largely relating to pre-contract information, reminder notices (including on renewal), 'cooling off' periods, and exit/ cancellation. This part of the DMCCA is expected to in come into force in 2026.

Enforcement:

  • New, severe fines for non-compliance with all key consumer law, including the above but also, for example, failure to provide pre-contract information and unfair contract terms. The new fines are turnover linked - the maximum fine is the higher of £300,000 and 10% of the businesses' global turnover.
  • Direct powers of enforcement for the CMA under most key consumer legislation (including to impose the new fines).

How the CMA is driving compliance and complaints

  • Active promotion of complaint channels: Prominently publicising its online complaint form, its dedicated phone line, and its contact email, making it easier than ever for complainants to report concerns quickly and securely.
  • Streamlined pre-complaint consultations: Encouraging early discussions with complainants to help shape well-founded submissions, offering tailored guidance and outlining what evidence will strengthen each case.
  • Priority review and response timelines: Committing to acknowledge every complaint and, where there is a realistic prospect of investigation, providing a substantive update or information request within six weeks.
  • Enhanced guidance on evidence requirements: Proactively guiding complainants to submit thorough, evidence-based accounts of potential infringements, including documentary proof, information on the infringing business, market impact analysis, and proposals for remedies, encouraging and explaining what is meant by a "well-reasoned complaint". For consumer law issues, the CMA is specifically encouraging clear documentation of the consumer journey and supporting data on the relevant infringement such as studies, surveys or reports.

Of course, alongside promoting the complaint process, the CMA is also pro-actively launching enforcement action and issuing further guidance to businesses on their compliance responsibilities, including the launch of a major consumer protection drive.

How the CMA chooses which cases to investigate

In its complaints guidance, the CMA reiterates its prioritisation principles which it summarises as including:

  • the strategic significance of the sector/ trader;
  • how substantial the likely positive impact of any CMA action would be;
  • whether the CMA is best placed to act or whether there is a more appropriate alternative;
  • the resources required over the estimated duration of the case; and
  • the type and degree of any risks associated with CMA action, including the risk to a successful outcome of any investigation.

The CMA's top enforcement priorities in the first 12 months

In earlier guidance, the CMA said that in the first 12 months of the consumer aspects of the DMCCA coming into force, it would focus on the most "egregious" practices including:

  • aggressive sales practices that prey on consumers in vulnerable positions;
  • providing information to consumers that is objectively false;
  • banned practices including the new banned practice relating to fake reviews;
  • fees that are hidden until late in the purchase process - harming consumers and fair dealing businesses, by hindering effective price competition; and
  • contract terms that are clearly imbalanced and unfair, including those that impose unfair exit charges on consumers.

In case business was in any doubt as to the regulator's new, more interventionist approach, the CMA has, since April:

  • published guidance on unfair commercial practices[1] generally and fake reviews[2] specifically;
  • conducted a sweep of business websites to check for the use and content of policies on fake reviews, and sent out letters to raise concerns;
  • issued a short guide for online review sites[3], and updated guides for brands and their agencies[4], and content creators/influencers[5];
  • launched enforcement action against 8 businesses, across several sectors, over concerns about 'drip pricing', offers and price transparency;
  • sent advisory letters to 100 more businesses, expressing concern about price promotion; and
  • consulted on and issued finalised price transparency guidance[6], with examples of good practice.

How these changes affect your business

All businesses operating in the consumer market should be aware that the CMA has advertised accessible channels for potential complainants to report concerns directly. This may lead to an increase in the volume and quality of complaints submitted to the CMA and, therefore, a further drive in CMA enforcement action. The initiative on complaints is part of a multi-pronged approach from the CMA, also including its own pro-active investigations.

The guidance on complaints indicates an appetite from the CMA to hear about and investigate non-compliance. Alongside the other action taken to date and currently in progress, it serves as a timely reminder that businesses should review and ensure their compliance frameworks, practices, contracts and other documentation are robust, transparent, and compliant with competition and consumer law.

For advice on consumer law and the DMCCA please contact: Dan Smith, Zoe Pearman and Rachel Pennell.

Explore our resources for further information on the consumer law aspects of the DMCCA and UK competition law:

Footnotes:

[1] Unfair commercial practices: CMA207
[2] Fake reviews: CMA208
[3] Review: guidance for online review sites
[4] Reviews: guidance for businesses and agencies
[5] Social media endorsements: guidance for brands
[6] Price transparency: CMA209