In 2025, consumer law has been pushed to the very top of many businesses' compliance agenda. Key parts of the Digital Markets Competition and Consumers Act (DMCCA) have come into force, and the Competition and Markets Authority (CMA) has been blessed with new powers, enabling it to tackle consumer law breaches more efficiently and to impose far heavier penalties.

A stream of guidance has followed, along with the first action under the new law. A few weeks ago, the CMA sent warning letters to businesses who had not published a policy on fake reviews on their websites. Now attention has turned to 'drip pricing', with the CMA announcing, this week, the launch of a 'major consumer protection drive'. Action includes:

  • Enforcement against 8 businesses over concerns about price transparency.
  • Advisory letters to 100 more businesses, expressing concern about their price promotional practices.
  • Finalised guidance on avoiding 'drip pricing' and other issues with price transparency.

Are you affected?

If you advertise prices to consumers, whatever your product line, you are affected and the CMA's action should come as a warning.

And if you engage in any of these practices – which have triggered the CMA's investigations into the eight businesses - then the risk of enforcement action will be high:

  • Presenting prices which do not include mandatory fees.
  • Not being sufficiently upfront about one-off initial fees for annual memberships or subscriptions.
  • Time limited offers which do not end when they say they will (including countdown clocks which reset).
  • Automatically opting customers in to the purchase of additional services.

Additionally, the CMA has highlighted the following sectors as being of particular concern – businesses operating in these markets should take urgent action to check their compliance:

  • holidays (including package travel)
  • driving schools
  • homeware retail
  • rail travel, bus and coach travel
  • parking and airport parking
  • luggage storage providers
  • cinemas
  • live event tickets
  • food and drink delivery
  • letter and parcel delivery
  • gyms and fitness
  • fashion
  • online vouchers

What should you do

If you have received a letter from the CMA, or your products or services fall into one of the above categories, then you should take urgent action to review customer journeys – from the perspective of the DMCCA and the associated guidance – and address potential compliance issues.

If you have not received a letter from the CMA, and your products and services do not fall into one of the above categories, then you may have a little more time to get your house in order. But there are no guarantees, and all businesses advertising prices to consumers should:

At the same time, businesses should consider checking their compliance in other areas targeted by the CMA – for example, the presentation of review and testimonial information and the use of 'dark patterns', which may mislead or 'nudge' consumers to make decisions they did not plan to make.

Businesses should note that compliance may not be straightforward – the guidance from the CMA on price transparency recommends several solutions which, if adopted, would likely require significant website development costs. But doing nothing at all should not be an option – businesses which bury their heads in the sand, or are slow to address concerns, are far more likely to be on the receiving end of action from the UK's newly empowered consumer law regulator.

If you have any queries on price transparency, fake reviews or the CMA's action on unfair commercial practices (including misleading advertising), then please contact Dan Smith or Zoe Pearman.