DMCCA update: what B2C businesses need to know in July 2025

The CMA is now enforcing consumer law directly - here's what that means for your business

In July 2024, we published an article about the introduction of the Digital Markets, Competition and Consumer Bill and what it meant for UK B2C businesses. On 6 April 2025, a new consumer law enforcement regime came into force, giving the Competition and Markets Authority (CMA) direct enforcement powers under the Digital Markets, Competition and Consumers Act (DMCCA). The CMA introduced a three-month grace period to help businesses comply with the new rules on fake reviews before full enforcement began on 6 July 2025. That support period has now ended and businesses must ensure compliance to avoid enforcement action from the CMA.

This update outlines what’s changed, where the CMA is focusing its attention and offers some practical steps your business should be taking now to stay compliant.

What's changed in July 2025

The CMA no longer needs to go to court to take enforcement action against businesses that infringe consumer law. It can now act directly - investigating suspected breaches and proposing fines or remedies.

Before making a final decision, the CMA must give the business a chance to respond. If it concludes that a breach has occurred, it can issue a formal notice confirming the outcome along with any penalties or steps the business must take. These steps may include actions such as issuing refunds or changing internal practices.

The CMA now has the power to impose:

• Civil penalties of up to 10% of global annual turnover or £300,000, whichever is higher, for serious breaches;

• Personal fines of up to £300,000 for individuals such as directors or senior managers; and

• Administrative penalties of up to £30,000 or 1% of global turnover for procedural failings, like failing to respond to information requests.

The CMA has said it will focus its first 12 months on serious consumer harm, including:

• Fake or misleading reviews;

• Aggressive or manipulative sales practices; and

• Unfair contract terms.

However, less serious breaches won’t be ignored by the CMA, so now's the time to make sure your practices are compliant.

Key areas of focus under the DMCCA in July 2025

1. Fake reviews and misleading endorsements

Fake reviews are now explicitly banned. This includes:

• Publishing or commissioning fake reviews;

• Displaying incentivised reviews without clear disclosure; or

• Manipulating rankings or review content in a misleading way.

You must also take “reasonable and proportionate” steps to ensure reviews shown on your website or platform are genuine.

These changes form part of a broader list of 32 banned commercial practices introduced under the DMCCA. These practices are deemed automatically unfair - this means that no additional consumer harm needs to be proven.

2. Drip pricing

All unavoidable charges, including booking or admin fees, must be included in the headline price or clearly disclosed upfront. Hiding costs until checkout could now be considered a banned commercial practice.

3. Situational vulnerability

The new rules expand the definition of vulnerable consumers to include those in temporary circumstances. For example, the DMCCA's explanatory notes state that consumers recently made redundant, facing health issues, mourning a loss or undergoing a divorce may be classed as "vulnerable consumers".

Using aggressive or exploitative tactics against consumers in these situations could now be treated as an unfair commercial practice under the DMCCA.

You can read more about how the CMA defines and approaches vulnerable consumers in its guidance on unfair commercial practices.

4. Subscription contracts (coming in 2026, but prepare now)

The rules on subscriptions will soon change:

• Clear pre-contract info must be provided (e.g. minimum term);

• A 14-day renewal cooling-off period will allow consumers to cancel after a renewal;

• A simple online cancellation process (the “cancellation button”) will be mandatory; and

• Businesses must send renewal and trial-ending reminders.

5. Other unfair practices to watch

The CMA can now intervene more easily in relation to:

• Misleading actions – where a business provides false or misleading information about a product, service, or itself that could influence a customer’s decision (e.g. exaggerated claims about quality or performance).

• Misleading omissions – where a business leaves out important information that a customer needs to make an informed choice (e.g. hiding fees, failing to explain key contract terms).

• Failures to act with professional diligence – where a business doesn’t meet the standard of care and honesty that a responsible trader would be expected to show (e.g. unfair small print, confusing cancellation processes, or misleading website layouts).

Previously, regulators had to show that these practices significantly impaired a consumer’s ability to make informed decisions. Now under the DMCCA, the threshold is much lower. The CMA only needs to show that the practice is likely to cause a consumer to make a different decision.

Practical steps for your business

With the CMA’s new enforcement powers in full effect and more regulatory changes on the horizon, now is the time for SME B2C businesses to review their consumer-facing practices. The risk of financial penalties and reputational damage is real, but staying compliant doesn’t have to be complicated.

Here are some practical steps your business can take to get ahead of the DMCCA changes and protect both your customers and your brand:

1. Audit your review and endorsement processes

• Remove or block any fake, manipulated, or misleading consumer reviews.

• Clearly label incentivised reviews and endorsements.

• Implement internal checks to ensure compliance with the new obligation to take “reasonable and proportionate” steps to ensure reviews are genuine.

• If you're using influencers, affiliates or third-party endorsements, ensure all promotional content is transparent and any paid relationships are clearly disclosed. You can find more guidance on the Advertising Standards Authority website.

The CMA recently secured undertakings from Amazon to tackle fake and misleading review. This serves as a reminder that even businesses selling through third-party platforms risk enforcement action if they benefit from, or fail to monitor, suspicious reviews. It’s important to stay on top of review audits, even for listings hosted on external platforms.

1. Revisit your pricing strategy

   • Ensure that all unavoidable fees (e.g. booking, admin, service charges) are included in the headline price or clearly disclosed upfront.

   • Eliminate “drip pricing” practices that could now be considered banned.

2. Get subscription-ready (ahead of 2026 changes)

   • Review your subscription contract terms for compliance, especially around auto-renewals.

   • Plan for:

     a. Clear pre-contract information, including minimum duration;

     b. A 14-day renewal cooling-off period;

     c. A simple, accessible cancellation method (e.g. a “cancellation button”); and

     d. Reminder notices before trials or renewals.

3. Review your terms and conditions

   • Eliminate or revise any unfair contract terms, especially those that limit consumer rights, auto-renew without notice, or obscure key obligations

   • Make terms transparent, accessible, and easy to understand

   • Ensure that all of your B2C contracts comply with the Consumer Rights Act 2015. Find out more here.

4. Continue to monitor CMA guidance and future updates

• Keep an eye out for upcoming guidance from the CMA to ensure full compliance with evolving expectations.

Stay ahead of what’s next

More changes are on the horizon. From January 2026, rules on consumer savings schemes will kick in, followed by subscription and dispute resolution rules in spring 2026. Taking action now isn’t just about avoiding fines - it also helps build consumer trust and protects your brand reputation.

Tags: digital markets competition and consumers act, DMCCA, consumer law UK, consumer protection law UK.