Consumer law | UK Regulatory Outlook January 2026

This year there is already a packed agenda for consumer protection law. In the UK, the subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) may begin to take effect and the Competition and Markets Authority (CMA) is expected to test its enhanced powers of enforcement against the unfair commercial practices provisions in the Act. In the EU, the Commission's recently published 2030 Consumer Agenda will set the tone, including the possible publication of the Commission's legislative proposal for a Digital Fairness Act. Overarching priorities for the EU in this area of law include protecting vulnerable consumers, particularly children, in the digital environment, as well as simplifying the regime and reducing the administrative burden. Below, we set out in more detail the key developments most likely to shape 2026.

UK DMCCA: subscriptions and unfair commercial practices in focus

Subscriptions regime

The regime for paid business-to-consumer subscription contracts under the DMCCA may commence in autumn 2026. The regime includes rules on providing certain pre‑contract information, sending renewal reminders and making cancellation of subscription contracts simpler. Further detail is expected to be set out in secondary legislation and guidance.

Unfair commercial practices

The DMCCA unfair commercial practices provisions, including the express bans on fake reviews and drip pricing, as well as the CMA's direct enforcement powers, have been in force since April 2025. The CMA has also published various guidance to support businesses' compliance with the rules – see our Digital Regulation timeline for more information. 

In April 2025, the CMA also outlined its intended approach for the first year of the new regime. The CMA expected to focus on "egregious practices where the law is clear", such as aggressive sales practices targeting consumers in vulnerable positions, providing objectively false information, banned practices such as fake reviews, hidden fees and clearly imbalanced and unfair contract terms, including those imposing unfair exit charges on consumers.

Following the publication of its price transparency guidance under the DMCCA, the CMA has already launched various investigations into potentially non-compliant businesses, targeting online pricing practices, which signals its readiness to use its new powers. The regulator has also sent advisory letters and requests for information to businesses in a variety of sectors, showing that its aim is also, where possible, to work with companies and encourage compliance, rather than move straight to enforcement.

That trajectory is expected to continue through 2026, reinforced by the CMA's strategy for 2026-2029. As the CMA's chief executive Sarah Cardell put it when launching the strategy: "Supporting businesses to comply with the law, alongside tough enforcement where it really matters to people. That is the recipe to maximise the value of the new regime for consumers and fair dealing businesses – and you can expect it to continue."

European Commission's 2030 Consumer Agenda

The European Commission has published the 2030 Consumer Agenda, "a new strategic framework for EU consumer policy that sets out concrete priorities and actions for the next five years."

Digital Fairness Act

The European Commission intends to table a legislative proposal for a Digital Fairness Act in the fourth quarter of 2026. The initiative is expected to target online dark patterns, addictive design features, unfair personalisation and pricing and problematic influencer marketing practices as well as to include simplification measures. See Osborne Clarke's Digital Fairness Act microsite for more information.

Geo‑Blocking Regulation evaluation

The Commission aims to complete its evaluation of the Geo‑Blocking Regulation in the second quarter of 2026, following the launch of its review in February 2025. It will also further analyse the benefits, challenges and possible risks of extending the regulation's scope. This may include consideration of whether audiovisual content, currently excluded from scope, should be brought within the regulation's framework.

Consumer Protection Cooperation Regulation revision

The Commission intends to propose a revision of the Consumer Protection Cooperation (CPC) Regulation in the fourth quarter of 2026 to address persistent enforcement inefficiencies, including lengthy procedures, insufficient resources at national level, the absence of stronger deterrent measures (such as the power to impose fines) and difficulties in addressing infringements by traders established outside the EU. In parallel, the Commission intends to continue supporting coordinated enforcement actions and activities of the CPC Network to tackle widespread breaches of EU consumer law.

Audiovisual Media Services Directive review

The Commission plans to evaluate the Audiovisual Media Services Directive (AVMSD) in light of significant changes in the audiovisual media environment since the directive was last revised in 2018. It launched a call for evidence on the evaluation and review of the AVMSD, which closed in December 2025. As part of the evaluation, the Commission intends to look at its scope, prominence of media services of general interest, audiovisual commercial communications, protection of minors rules applicable to video-sharing platforms and promotion of European works. The Commission aims to launch a further consultation on the AVMSD evaluation in the first quarter of 2026.

The protection of vulnerable consumers (with children front and centre), simplification and reducing the administrative burden are cross‑cutting priorities.