Direct consumer enforcement: one year on

A year ago, the Competition and Markets Authority (CMA) launched its new direct enforcement regime under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act).

It’s been a busy 12 months, so now feels like a good moment to reflect on what we’ve delivered against the commitments set out in our approach document, and to look ahead at what’s coming next.

What the numbers tell us

Numbers give an insight into the scale of work happening behind the scenes – a helpful starting point for understanding progress so far.

From April 2025 to April 2026, we have:

opened investigations into 14 businesses and settled with 2 ordered that a total of £760,000 be refunded to consumers, and imposed fines totalling £4.7 million issued 157 advisory and warning letters sent 46 information notices

Before the new rules came into force, we published guidance on how we’ll use the regime, how to comply with the law on consumer reviews, and unfair commercial practices. We’ve since published and updated 10 other pieces of guidance to help businesses comply – including new guidance on price transparency and draft revised guidance on unfair terms in consumer contracts.

But ultimately, what matters most is the difference we make:

giving consumers the confidence to shop online, with clear and accurate pricing and the means to exercise their rights if things go wrong creating a level playing field where fair-dealing businesses can thrive Our purpose and approach

The CMA’s purpose is to promote competition, protect consumers and support growth and household prosperity. This is no small task – particularly at a time when people are feeling cost of living pressures, with price rises caused by the conflict in the Middle East starting to bite.

That’s why we’ve focused on using our enforcement powers strategically – making sure that businesses’ behaviour genuinely complies with consumer protection rules.

From the outset, our approach has been twofold:

providing clear, practical guidance to help the majority of businesses who want to do the right thing, and taking targeted enforcement action where we identify egregious breaches

A year on, this approach is well established.

Focusing our efforts

Our public enforcement action has targeted 3 areas, as set out in our approach document: drip pricing, fake reviews, and online choice architecture (OCA).

With each, we deliberately cast a wide net – and the results speak for themselves.

Drip pricing

This week we announced that the AA Driving School and BSM Driving School, who are both owned by the Automobile Association Developments Limited (the AA), admitted liability for drip pricing and agreed to refund over £760,000 to affected learner drivers. The AA was also fined £4.2 million.

This settlement is a major milestone in our work to enforce against illegal and harmful drip pricing practices.

Fake reviews

We carried out a sweep of review publishers and issued advisory letters to 54 firms to improve their compliance with the law. 90% of the businesses we contacted then took action to improve their policies and in March we opened investigations into 5 companies to establish whether consumer laws on misleading reviews have been broken.

By looking into key stages in the online reviews ecosystem – such as how reviews are obtained, moderated and displayed, through to the star ratings presented – we’re investigating multiple practices that can shape what people see when they search, shop or book online.

Online choice architecture

Many of the businesses we wrote to in November moved swiftly to stop adding extra products or services by default. We’re continuing to investigate default optional charges and false ‘time limited’ offers. And we’re talking to the wider community of regulators – through the Digital Regulation Cooperation Forum and International Consumer Protection and Enforcement Network, for example – about how AI could affect online choice architecture in future.

Tackling other harmful behaviour

Beyond those areas, we’re considering standalone cases that address the conduct of a specific business, where we have intelligence of potential infringement.

For example, our investigation into Adobe will examine whether its early cancellation fees are unfair and misleading. Expect more of these standalone cases in the next year.

Responding to wider changes

Our strategy matters, but so does remaining agile. It was crucial to respond quickly to the concerns we heard from consumers about heating oil. We’ve welcomed some businesses publicly confirming that they would honour agreed prices, even as wholesale prices increased. This gave consumers the immediate comfort that they could rely on the contract terms they agreed and wouldn’t be left to bear the risk alone.

Combining our markets and consumer enforcement roles, our heating oil market study will examine whether consumers need to be better protected against possible future shocks.

Engaging with businesses across the UK

Supporting businesses has been central to our strategy, with over 2000 attendees at our events and seminars over the first year. We’ve engaged directly with businesses at the FSB Coventry Business Bootcamp, started a programme of events with regional law firms to share compliance advice, and promoted our Clear Pricing campaign – featuring Alexander Armstrong – which gives businesses a simple, 3-step checklist for transparent pricing.

We’re looking forward to building on this momentum at the FSB Manchester Business Bootcamp on 15 May and through more local law firm events.

What to expect in year 2

In our second year, we’ll continue to focus on areas of essential spend where consumers feel the pinch most, as well as practices that are widespread and cause significant harm.

My message to businesses is to prioritise compliance in the following areas:

price transparency – don’t use hidden, ‘dripped’ or unlawful partitioned pricing and discount claims must be true, accurate and not misleading fake reviews – have robust policies in place so reviews give consumers an honest picture - and make sure your employees are implementing them terms in contracts with consumers – review your terms carefully (especially any that impose exit fees) against our updated guidance which we will finalise in Autumn by the latest subscription contracts – new rules are expected to come into force in Spring 2027 with guidance from DBT – businesses must get ready to comply how you’re using AI, including agents – our recent advice offers practical tips on using agentic AI responsibly

And if you see other businesses breaking the rules? Report it to us.

Summing up

I’m proud of what we’ve achieved so far, and excited about what’s ahead. Helping businesses comply while showing the real consequences for those who don’t – that twin approach is already delivering better outcomes for consumers. And we’re just getting started.

https://competitionandmarkets.blog.gov.uk/2026/04/17/direct-consumer-enforcement-one-year-on/

seen at 11:54, 17 April in Competition and Markets Authority.