🛡️ Summary: Action Plan by Priority
New consumer protection laws are coming – here’s what you need to prioritise under the DMCC Act, and when, to stay compliant and avoid enforcement.
✅ IMMEDIATE ACTIONS (Before September 2025)
These are legal requirements from April 2025, with a short grace period. Prioritise these to avoid enforcement.
1. Fix Pricing Displays (Drip Pricing Ban)
What:
You must show the total cost up front, including:
- Delivery fees
- Service or booking charges
- Any other mandatory fees
Action:
Why: Non-compliance can lead to fines up to the higher of 10% of global turnover and £300k
Update your product pages and checkout flow
Ensure price comparison feeds (e.g. Google Shopping) include full pricing
2. Clean Up Reviews (Fake Reviews Ban)
What:
It’s illegal to:
- Post fake reviews
- Pay for positive reviews
- Host reviews without verifying authenticity
Action:
- Audit all customer review sources (Trustpilot, Yotpo, Bazaarvoice, etc.)
- Add moderation or filtering systems
- Remove unverifiable reviews or questionable star ratings
Why:
CMA will target this early; it’s a high-visibility consumer issue
3. Review Marketing Practices
What:
Aggressive or misleading tactics are under stricter bans, especially those:
- Creating false urgency (e.g. “only 2 left” if not true)
- Targeting vulnerable consumers (children, elderly, financially insecure)
Action:
- Audit pop-ups, banners, countdown timers, and urgency tools
- Avoid manipulative upselling or default opt-ins
Why:
Early CMA enforcement will target egregious or vulnerable-group violations
🔄 NEXT 3–6 MONTHS (by end of 2025)
These are not urgent, but still important to stay ahead and avoid investigation.
4. Set Up Internal Compliance Processes
Train staff (especially marketing and customer service)
Document your pricing, review moderation, and complaints handling policies
Assign a compliance owner or small team
5. Track CMA Guidance and Consultation
Final drip-pricing guidance expected by Autumn 2025, may include:
Subscribe to updates from the CMA or work with legal counsel
More examples of mandatory vs optional charges
Clarity on dynamic pricing or personalisation
🧭 EARLY 2026 PREP
These rules aren’t active yet but require planning ahead.
6. Subscription and Auto-renewal Compliance (Spring 2026)
📅 Effective from: Spring 2026
🚧 Start planning: Q4 2025
🧯 Risk: High if ignored — CMA will have direct enforcement powers and can issue significant fines
What’s coming:
- Clear opt-ins for subscription sign-ups
- Reminder emails before auto-renewals
- Easy cancellation process (no hidden steps)
Action (Start in Q4 2025):
Plan tech/dev work if changes are needed
Review subscription flows
Test your cancellation path, must be frictionless
Plan tech/dev work if changes are needed
How we can help:
We can help you get ahead of the 2026 rules with a mini compliance audit and targeted training for your marketing team. Get in touch to find out more.
