Consumer law | UK Regulatory Outlook February 2026

CMA's annual plan 2026-2027: consumer protection aspects 

The Competition and Markets Authority (CMA) consulted on its draft annual plan for 2026-2027, outlining its priorities for the first year of its new strategy for 2026-2029.  

In relation to consumer protection, the CMA plans to encourage businesses to comply with the new Digital Markets, Competition and Consumers Act 2024 (DMCCA) regime while pursuing direct enforcement in priority areas. The CMA has reiterated its focus on the "more egregious practices where the law is clear", stating that these include (i) areas targeted as part of its first investigations (such as price transparency and misleading online choice architecture across various sectors); (ii) practices in relation to which it sent advisory letters (for example, fake reviews); and (iii) practices set out in its approach document on implementing an enhanced consumer protection regime under the DMCCA, published in April 2025.  

The approach document, which the CMA states continues to drive its priorities for 2026-2027, outlined the following practices as falling within that group of potentially egregious practices: 

• Aggressive sales practices that prey on consumers in vulnerable positions.
• Providing information to consumers that is objectively false.
• Banned practices including the new prohibition relating to fake reviews.
• Fees that remain hidden until a late stage in the purchase process.
• Contract terms that are clearly imbalanced and unfair, including those imposing unfair exit charges on consumers. 

The CMA says that it will continue "driving behavioural change" by sending advisory letters, which it says have so far been effective.  

It has also set out how it intends to apply its "4Ps" approach (pace, predictability, proportionality and process) in its first investigations under the new consumer protection regime. In particular, it intends to: 

• Focus on the most significant potential concerns.
• Publish regular updates on the progress of each investigation, including timings and next steps.
• Use its information-gathering powers proportionately and in a targeted way, focusing on specific, relevant information to minimise the burden on businesses.
• Develop further accessible materials to help businesses comply with the law and pursue cases that will promote legal certainty, recognising that there is limited case law in certain areas of consumer law and that the consequences for infringements are now greater under the new consumer regime.
• Continue to offer direct engagement with businesses, including to better understand the issues they experience in practice and where further guidance might best support compliance. 

CMA reflects on DMCCA progress and priorities  

Emma Cochrane, acting executive director, consumer protection, at the CMA has delivered a speech reflecting on the DMCCA's progress. Speaking ten months after the new unfair commercial practices regime came into force and the CMA obtained its new direct consumer enforcement powers, she also outlined what lies ahead. 

The CMA described its process in relation to fake reviews compliance as "proportionality and process in action", whereby it provided businesses with guidance, afforded them a three-month "grace period" to amend their practices, conducted a "sweep" to check compliance and sent advisory letters in the first instance, rather than launching enforcement action immediately. Its work on fake reviews continues. 

Regarding enforcement, the CMA highlighted that the response to its 100 advisory letters sent to businesses across 14 sectors in November 2025 has been positive. However, it added that "more change is needed" and further action can be expected.  

Over the past ten months, the CMA has been monitoring practices across the economy to ensure that it efficiently targets the most problematic conduct. It has:  

• Issued 29 targeted information requests to businesses to assess their commercial practices.
• Engaged directly with others on refund rights, potentially unfair terms and misleading claims.
• Continued cases that were opened before the DMCCA powers came into force. 

The CMA intends to provide updates on its live cases "in the coming months", with more enforcement to follow where it sees the need to protect consumers and fair-dealing businesses. Ms Cochrane noted that the CMA continues to monitor compliance and that further action can be expected "on fake reviews, unfair contract terms and drip pricing for businesses that have not shifted their behaviour".  

CMA issues first fine using its new powers under the DMCCA 

The CMA has fined Euro Car Parks £473,000 for failing to respond to a statutory notice requiring the company to provide information. While the penalty does not relate to an infringement of consumer law (the CMA is currently considering whether to launch a consumer enforcement case after receiving the information), this action underscores the importance of engaging with the regulator. The company failed to respond to it for three months, despite seven separate attempts by the CMA to secure a response through various means. It received a response only after notifying the company of its intention to issue a fine. The company told the CMA that it had blocked its emails, believing them to be fraudulent. The CMA did not consider this a reasonable excuse. 

The fine represents 75% of the maximum possible fixed charge the CMA can issue using its DMCCA enforcement powers. It has stated that this fine sends a clear message to businesses: those that fail to respond to its requests or refuse to comply risk facing "penalties like this one". 

CMA publishes explainer on its Green Claims Code with focus on supply chain responsibility  

See advertising and marketing section.