Consumer law | UK Regulatory Outlook April 2026

UK government publishes consultation response on DMCCA subscription contracts regime 

The UK government has published its response to the consultation launched in November 2024 on implementation of the new subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).  

While the unfair commercial practices provisions under the DMCCA have been effective since April 2025, the subscription contracts regime will not come into effect until spring 2027. The consultation response provides additional detail on how the new regime will work, although a number of questions remain outstanding. 

See this Insight for more information.  

CMA's areas of focus for year two of direct consumer enforcement regime 

Emma Cochrane, Executive Director of Consumer Protection at the Competition and Markets Authority (CMA) has outlined what to expect from the CMA in year two since the regulator received its new direct enforcement powers under the DMCCA in April 2025, as well as reflecting on the achievements of its first year.  

Ms Cochrane notes that the CMA's twofold approach is now well established: providing guidance to help the businesses who "want to do the right thing", while taking targeted enforcement action where it identifies egregious breaches. To date, its enforcement action has focused on three areas set out in its approach document published in April 2025: drip pricing, fake reviews and online choice architecture. 

She emphasised that the CMA will 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". Her message to businesses is to prioritise compliance in the following areas: 

• Price transparency – businesses should not use hidden, "dripped" or unlawful partitioned pricing. Discount claims must be true, accurate and not misleading.
• Fake reviews – businesses must have robust policies in place to ensure that reviews give consumers an honest picture, and make sure that employees are implementing them.
• Terms in contracts with consumers – businesses should review their terms carefully (especially any that impose exit fees) against the CMA's updated guidance, which it intends to finalise in the autumn.
• Subscription contracts – new rules are expected to come into force in spring 2027 (see above), and businesses must ensure they are ready to comply.
• Use of AI, including AI agents – the CMA's guidance offers practical tips on using agentic AI responsibly (see this Regulatory Outlook). 

In March 2026, the CMA published its annual plan for 2026 to 2027, outlining its priorities for the first year of its new strategy for 2026-2029. The consumer protection aspects are largely in line with the draft plan – see this Regulatory Outlook for more information. 

Government Consumer Action Plan to be published later in the year 

The secretary of state for the Department for Business and Trade, Peter Kyle, has written to the Business and Trade Committee setting out the steps the government is taking to review the consumer protection system.  

The government has written to all secretaries of state and regulators asking them to set out what further action they plan to take to address consumer harms in their area, with a particular focus on eliminating contractual traps, making pricing clear and consistent and toughening enforcement actions against conduct and businesses "that do the most harm to the community". These actions will help shape the government's consumer action plan, which it intends to publish later in the year. 

It will also review: 

• The statutory consumer protection duties of local Trading Standards teams, working with relevant government departments, with a view to streamlining or removing duties where appropriate so that resources can be targeted more effectively.
• Consumer redress mechanisms, including the potential introduction of a Consumer Ombudsman for unregulated sectors, to provide a single point of resolution for consumers.
• The design and potential benefits of a dedicated opt-out collective actions regime for consumer law claims, on which the Law Commission has been engaged.  

Consumer class actions regime under consideration by the Law Commission 

The Law Commission of England and Wales has launched a new project to consider the potential introduction of a consumer class actions regime, having been asked by the government to assess whether the enforcement of consumer laws could be strengthened through such a mechanism. 

The project will examine the potential benefits and risks of introducing such a regime, alongside existing mechanisms such as public enforcement action and alternative dispute resolution, and will consider how it should be designed. 

The Law Commission is inviting anyone with an interest to respond to an Initial Scoping Questionnaire by 30 October 2026. It intends to undertake wider stakeholder engagement as the project progresses, before publishing a consultation paper in which it will set out its provisional reform proposals.