After signaling a tougher stance on consumer protection earlier this year, the UK Competition and Markets Authority (CMA) has delivered on that promise by launching a “major consumer protection drive.”
On November 18, 2025, the CMA announced its first public enforcement actions under the Digital Markets, Competition, and Consumers Act 2024 (DMCCA), alongside more than 100 advisory letters and the publication of its final Price Transparency Guidance.
The move is significant not only for the sectors involved but also for the message the CMA wants to send: Any business selling to UK consumers online — whether a digital-native platform or a traditional retailer with an online presence — is now squarely within scope.
This shows an intention by the CMA to demonstrate both breadth and deterrence in enforcing the DMCCA. Enforcement no longer seems confined to specific sectors or even necessarily to those businesses with the widest consumer base. Any organization that presents pricing or sells to consumers online (even to a subset of its customer base) is now firmly within the CMA’s sights.
CMA priorities: drip pricing and pressure selling
The CMA’s early enforcement is focused on two practices prohibited under the DMCCA:
- drip pricing, where headline prices fail to show mandatory fees that surface only later during the checkout journey. Mandatory charges must be disclosed in certain locations upfront.
- pressure selling, where misleading urgency cues (such as countdown timers or “last chance” messages) unfairly push consumers to make faster decisions. These are considered unlawful unless they reflect genuine, time-limited circumstances.
These two themes have long been concerns under the preexisting consumer-protection regime, but the DMCCA enhances CMA powers and gives it a clearer mandate to act swiftly.
Enforcement strategy
The CMA has taken a “two-tiered approach” to enforce these pricing concerns:
- First, the CMA has launched enforcement actions against eight companies, including secondary ticketing sites, homeware retailers, and driving schools, that are allegedly involved in the suspected use of hidden fees, misleading time-limited offers, and/or automatic opt-ins for optional charges.
If the CMA confirms infringements, it may issue a formal infringement notice setting out the breach and the steps required to restore compliance. The CMA can also issue a penalty notice imposing direct administrative fines of up to 10% of global annual turnover with daily penalties available for ongoing noncompliance. Notably, these are direct administrative penalties; the CMA can impose these penalties without court proceedings.
- Second, the CMA has written to another 100 businesses across 14 sectors, warning them to review and correct their pricing and sales practices. These 100 businesses were identified through the CMA’s “compliance sweeps,” which have monitored more than 400 businesses in 19 different sectors since April. The CMA’s focus has been on sectors “where the CMA identified potential concerns, as well as key areas of [consumer] spending,” including food delivery companies, cinema chains, fashion retailers, and travel and holiday companies.
In addition, the CMA has published its finalized Price Transparency Guidance, which contains guidance for business on what to include in and how to present pricing information and how to avoid drip pricing and “partitioned pricing” (where component parts of a price are given but the overall price a customer would pay is not).
What this means for businesses
The CMA announced in April 2025 that its initial focus areas under the DMCCA would be drip pricing, customer reviews, misleading sale practices, misleading online choice architecture, and unfair cancellation terms. This latest wave of enforcement indicates that the CMA is moving decisively from signaling to visible, deterrence-oriented action.
Consumer-facing businesses — whether traditional retailers or online businesses — should urgently review their online pricing, customer journeys, sales practices, and wider compliance strategies against the new guidance. The CMA’s actions demonstrate that neither size, profile, nor sector insulates businesses from scrutiny.
How can we help?
At Sidley, our lawyers have extensive experience in advising clients on regulatory issues, consumer law investigations plus the ramifications of potential follow-on claims and additional international scrutiny. We regularly support clients in reassessing risk and compliance strategies, and engaging with the CMA, other international regulators and defending companies in court.
Our team would be pleased to discuss how the CMA’s enforcement approach and the DMCCA may affect your business.
