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This article is provided by by BRC Associate Member and Partner, RPC.

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The Digital Markets, Competition and Consumers Act 2024 (DMCCA) is set to substantially overhaul the UK's consumer protection law and enforcement regime.  We now know the date that key consumer protection and enforcement changes will come into force: 6 April 2025.

For more on the changes being introduced, see our previous article here, but in short the 6 April date will bring Part 3 (the consumer protection enforcement regime) and Part 4 (the unfair commercial practices regime) of Chapter 1 of the DMCCA into force. These parts:

  1. give the CMA the power to enforce consumer protection laws without going through the courts (including the power to issue fines of up to 10% of global annual turnover), and
  2. expand consumer protection provisions relating to unfair selling and unfair commercial practices, such as in relation to drip pricing and fake reviews

(see our article here for further detail on these changes).

Following consultations on the CMA's draft guidance and enforcement principles, we are now expecting most final guidance to be published on or around 6 April too.

However, final guidance on the new drip pricing provisions may take a longer to land.  Following a significant number of consultation responses to the draft guidance on this point, the CMA will look to run a further consultation on the application of the drip pricing provisions, so as to "provide a clear framework for compliance".  Therefore, it will likely be Autumn 2025 before the final guidance is published, and in the meantime the CMA has indicated it will only enforce "clear breaches" of the rules.

On the new fake review provisions (to be a blacklisted practice), the CMA understands that business may need some time to implement changes to ensure compliance and so has stated an intention to "focus on supporting businesses with their compliance efforts rather than enforcement" for the first three months following 6 April.

So where will the CMA be focussing their enforcement energy come 6 April?

CMA Chief Executive, Sarah Cardell, said in her blog post announcing 6 April as the big coming-into-force date that "early enforcement action following commencement is likely to focus on more egregious breaches.  For example:

  • aggressive sales practices that prey on vulnerability
  • providing information to consumers that is objectively false
  • contract terms that are very obviously imbalanced and unfair
  • behaviour where the CMA has already put down a clear marker through its previous enforcement work
  • where the law tells us that a practice is always unfair"

The changes coming in are substantial and will affect all organisations involved in B2C sales and services to UK consumers. Complying with the new laws and upcoming guidance will be key to avoid feeling the effects of the CMA's substantial new powers.

If you have any queries please contact the RPC team.


On 8 May 2025, BRC will be joined by hosts, RPC for an exclusive roundtable discussion on this topic aimed at those senior legal roles. Further details to follow. Express your interest here.

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