Consumer law | UK Regulatory Outlook March 2026

CMA sets out consumer law expectations for businesses deploying AI agents 

The UK Competition and Markets Authority (CMA) has published guidance, Complying with consumer law when using AI agents, setting out how businesses can use agentic AI to engage with their customers while complying with the law. It states that: 

• The same consumer law rules apply regardless of whether customers interact with a person or an AI agent. A business is responsible for the actions of an AI agent in the same way as it is responsible for its employees, even where a third party has designed or provides the AI agent on the business's behalf. Businesses should therefore consider compliance at the procurement stage, for example by using this guidance to inform discussions with third-party providers.
• Businesses should consider whether they need to label the use of an AI agent to avoid misleading consumers into thinking that a real person is providing the service. The relevant test is whether the fact that a consumer is dealing with AI rather than a person might affect their decisions; if so, the business should disclose this. At the same time, businesses should not overstate the role of AI in providing a service, or its capabilities.
• Businesses should train AI agents to comply with consumer law and test them before deployment. In doing so, they should consider what data their AI agent will need and how it will be prompted to: respect customers' statutory rights and the terms of contracts (for example, to ensure that cancellation rights are not breached); avoid misleading customers (both through what they say and what they omit to say); and properly obtain any consents required by consumer law.
• Businesses should regularly monitor AI agents' performance and ensure that appropriate human oversight is in place.
• Businesses should act quickly where an AI agent does not perform as expected and such failure could result in non-compliance with consumer law. 

The guidance provides examples of actions to consider in different scenarios (such as using an AI agent in marketing campaigns, processing refund requests, responding to customer service queries and providing services). 

Commencement of DMCCA alternative dispute resolution regime 

The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026 bring into force, on 6 April 2026, Chapter 4 of Part 4 of the UK Digital Markets, Competition and Consumers Act 2024 (DMCCA) which governs alternative dispute resolution (ADR) for consumer contract disputes.  

The DMCCA replaces the previous regime under the Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015. 

It prohibits ADR providers from carrying out ADR without accreditation. The new regulations create a transitional window, beginning on 6 April 2026, during which those prohibitions are disapplied for ADR that started during that period. The relevant period ends on 5 October 2026 or, if the ADR provider applies for accreditation under the DMCCA before that date, on the date that application is granted, refused or withdrawn. 

A series of other regulations have been made to ensure the effective implementation of the regime. These include the Digital Markets, Competition and Consumers Act 2024 (Alternative Dispute Resolution) (Conferral of Functions) Regulations 2026, which confer functions on the Chartered Trading Standards Institute in relation to ADR for consumer contract disputes under the DMCCA and make provisions in connection with the conferral of those functions. 

CMA launches Clear Pricing campaign to raise awareness of misleading pricing 

The CMA has launched its Clear Pricing campaign to raise consumer and business awareness of misleading pricing. It reminds businesses that "drip pricing" is a prohibited practice under the DMCCA, and has previously published guidance on price transparency covering the concepts of drip pricing, partitioned pricing and the core obligation on traders to present a total price wherever an invitation to purchase is made, including mandatory fees and charges.  

As part of the campaign, the CMA has introduced a "3 Step Pricing Check" to help businesses ensure that their pricing complies with the law, distilling the rules into three actionable steps: 

• "Show the total price up front."
• "Include all mandatory charges."
• "If you can't give a total yet, is it clear how customers can work it out?"