We are now just over halfway through the second year of the Competition and Markets Authority’s (CMA) direct consumer enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act).
Over the past 6 months, the CMA’s new consumer enforcement regime has moved firmly into delivery phase. We have secured practical results for consumers while sharpening our focus on the harms and reforms that will shape the year ahead.
Our work so far this year
Since April 2026, we have:
- opened 6 new investigations into Ryanair, Euro Car Parks, Microsoft, Virgin Atlantic, Trainline and Red Driving School, taking the total number of investigations we have opened to 20
- settled 7 of our cases
- ordered redress of over £2.3 million and imposed fines of over £11.8 million
- secured compensation for heating oil customers whose contracts were cancelled
Alongside our investigations, we have also continued our work to promote compliance, including:
- publishing our updated unfair contract terms guidance (CMA37) and holding a webinar for businesses
- writing to private parking operators and the wider car parking sector about the importance of complying with consumer law
- issuing an open letter to domestic heating oil suppliers about ensuring their terms are fair
- writing to suppliers of liquefied petroleum gas to remind them of their obligations under consumer protection law
Looking ahead
In the months ahead, we will continue to focus on practices that can cause significant consumer harm across markets, including continuing to bear down on drip pricing, misleading time limited offers or fake reviews. But our investigations into Adobe, Euro Car Parks, Ryanair and Microsoft show we are also willing to investigate conduct by individual businesses. We will act on intelligence and where there are problems, we expect businesses to put issues right quickly.
Pricing practices and online choice
We will continue to tackle drip pricing, partition pricing and online designs that obscure the true cost of a purchase or distort consumer choice. We have settled 7 of our 8 original online pricing practice investigations launched in November 2025, most recently Gold’s Gym, Wayfair and Buy It Direct, imposing penalties of over £6,000,000 and securing over £440,000 in consumer redress in these three cases.
Our newer investigations into Virgin Atlantic, Trainline and Red Driving School show that complete, accurate pricing remains a priority so consumers always know the total price that they will pay. We are also reviewing how online retailers disclose delivery fees and expect to provide an update shortly.
Using our intelligence capabilities, we are also watching for businesses who might be using misleading discounts.
Our expectation:
Discounts must be genuine and businesses must show the total price clearly and throughout the purchasing journey, without opting customers in by pre-selecting extra services. Online journeys should support informed choices. The rules are clear, and businesses have had ample time to comply.
Fake and misleading reviews
We continue to progress our investigations into Autotrader, Feefo, Dignity, Just Eat and Pasta Evangelists over concerns that consumer law on misleading reviews may have been broken, and we expect to provide a further update in the coming months. We have provided clear guidance about publishing consumer reviews and complying with consumer protection law.
Our expectation:
Businesses that host or use reviews should have effective systems to prevent misleading content and should act promptly when problems are identified. They should also bear in mind that commissioning reviews can take many forms and isn’t limited to paying consumers for them, for example unlawful conduct could include a business requesting members of staff to write reviews about its products or services.
AI products and services
We are actively monitoring how AI products are marketed and used, working with consumer groups and businesses to identify how benefits can be harnessed as well as emerging risks. Our guidance on using AI agents explains how existing consumer law applies to agentic AI.
In July we also opened an investigation examining concerns about how Microsoft presented information to consumers about changes to Microsoft 365 Personal and Family subscriptions, including the addition of new, AI-related features such as Copilot.
Our expectation:
Providers and businesses deploying AI must be responsible and accountable to consumers. New technology does not change their responsibility to comply with consumer law.
Subscription contracts
A new subscription contracts regime will come into force in January to ensure customers are better informed and make it easier for people to cancel plans they no longer want. Ahead of this, the government will be publishing secondary legislation and further guidance.
In the early months of the regime, the CMA’s focus will be on supporting businesses to get this right to help drive the best outcomes for consumers. However, businesses should not assume that our support for compliance means enforcement of the rules is being delayed. Conduct during this period may still be considered as part of enforcement action.
In line with our approach to consumer protection, we will use our powers proportionately by focusing enforcement on more egregious conduct, particularly in areas where businesses should already be clear about their obligations under the existing law. We will consider genuine efforts to comply with the new subscription rules when deciding whether to intervene.
Our expectation:
Businesses will be working to bring themselves into compliance with the new subscription contracts rules as quickly as possible.
Summing up
Over the last 6 months, we have continued to build on the strong foundations laid in the first year of the direct enforcement regime. The first half of this year has shown that our twin approach of helping businesses comply while showing the real consequences for those who don’t is continuing to deliver real benefits for consumers.
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