Consumer Law | UK Regulatory Outlook April 2025

Digital Markets, Competition and Consumers Act 2024 

Rules on UCPs in effect and CMA publishes final UCPs guidance 

On 6 April 2025, the "unfair commercial practices" (UCPs) part of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) came into effect, bringing significant changes to UK consumer law. Just ahead of the deadline, the Competition and Markets Authority (CMA) published its final guidance on UCPs. The rules on the enforcement of consumer protection law under the DMCCA also came into effect on 6 April 2025. The CMA now has new powers to enforce consumer protection law directly, without going to court. See this Insight for more information.  

The CMA has also now set out the approach it will take to applying the new direct consumer protection law regime in the first year. The document is mostly in line with the plans the CMA outlined in March – see this Regulatory Outlook – but also includes the following timeline: 

• April-July: the CMA will publish a programme of engagement with businesses and consumer organisations.
• Summer 2025: the CMA will consult further on certain aspects of its guidance on "drip pricing" (such as how it relates to fixed-term periodic contracts) covered by the material pricing information obligations in section 230 of the DMCCA.
• Autumn 2025: the CMA will publish final guidance on drip pricing.  

The document also sets out how the CMA will implement the "4Ps" in its consumer protection work: pace, predictability, proportionality and process. On pace, it promises to be as efficient and expeditious as possible, while on predictability, it is committed to minimising uncertainty. On proportionality, the CMA promises to use its enforcement powers in a fair and proportionate manner, ensuing that redress measures and fines reflect the seriousness of the conduct under investigation. Finally, on process, the CMA promises to engage directly with businesses throughout any investigation to ensure the process is understood.  

Consumer-facing businesses should now review their practices alongside the UCPs guidance and implement any necessary changes to ensure compliance. The CMA has effectively given traders a three-month grace period to comply with the new fake reviews regime, saying that it will focus on supporting businesses with compliance, rather than enforcement during this time. It has also said that, in general, it will only take enforcement action where the conduct represents "clear infringements of the law" and, in relation to drip pricing, it will not enforce on issues to be covered by the additional guidance mentioned above until it is published in final form.  

Dynamic pricing and secondary ticketing 

CMA publishes update on its investigation into Ticketmaster 

Having launched an investigation into Ticketmaster's sale of Oasis tickets in September 2024 (see this Insight), the CMA has written to the ticketing platform highlighting its concerns under consumer protection law and requesting changes to its practices to address the issues raised.  

The CMA's concerns relate to the following possible breaches by Ticketmaster: 

• Labelling certain seated tickets as "platinum" and selling them for nearly 2.5 times the price of equivalent standard tickets, without sufficiently explaining that they did not offer additional benefits and were often located in the same area of the stadium.
• Not giving consumers clear and timely information about how the pricing of standing tickets would work. Ticketmaster had not used an algorithmic pricing model, for example, to adjust ticket prices in real time when demand was high. However, it had released a number of standing tickets at a lower price and, once they had sold out, then released the remaining standing tickets at a much higher price. Consumers were not told of the two categories of standing tickets at different prices and therefore ended up waiting in a lengthy queue without knowing the price they would be paying. When they reached the front of the queue, they then had to decide whether to pay the higher price. 

The CMA says that changes made by Ticketmaster since the investigation began are insufficient to allay its concerns. The CMA has outlined the further steps needed – including to the information Ticketmaster provides to customers, when it provides that information, and how it labels some of its tickets – and is consulting with the platform on these changes. 

CMA responds to government consultation on the resale of live events tickets 

The CMA has also published its response to the government's consultation on the resale of live events tickets – see this Regulatory Outlook for background. The CMA supports the government's proposal to introduce a price cap for ticket resale and outlines some key considerations to help manage the risks, including: 

• Applying the resale price cap to both resellers and secondary ticketing platforms.
• Introducing a licensing regime for platforms wanting to host listings for resold event tickets.
• Introducing a requirement for primary sellers to make the original ticket prices readily available to make it easier for secondary ticketing platforms to comply with any applicable price cap obligation.
• Introducing powers to regulate buyer fees directly in any price cap legislation. The government should also consider whether consumer law is set appropriately, as restrictions on ticket resales may increase the ability of platforms to charge higher buyer fees as the restrictions reduce the number of competing authorised resellers. 

EU Digital Fairness Act expected in Q3 of 2026 

Speaking at the EU Parliament's Committee on Internal Market and Consumer Protection, the Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection has revealed that the European Commission plans to present the Digital Fairness Act "in the third quarter of 2026". He said that the proposal will aim to close the gaps in digital consumer protection law in relation to issues such as addictive design, dark patterns and burdensome subscription cancellations, which are not covered under current laws. The Commission has also published a timeline on the proposed Act, which shows that a public consultation is planned for Q2 of 2025.  

More broadly, Commissioner McGrath emphasised the need to be "bolder, simpler and faster" in enforcing consumer and digital laws, especially with the rise in online shopping. He pledged to uphold strong consumer protections amid the simplification efforts. 

The Digital Fairness Act was an anticipated outcome of the European Commission's "fitness check" of EU consumer law (see our Insight).