Consumer law | UK Regulatory Outlook May 2025

UK

Digital Markets, Competition and Consumer Act 2024: CMA's approach to the new consumer enforcement regime  

On 30 April 2025, the Competition and Markets Authority's (CMA) acting executive director for consumer protection, Emma Cochrane, delivered a speech on how the regulator is implementing its consumer protection duties under the Digital Markets, Competition and Consumer Act 2024 (DMCCA). The speech mostly reiterated the approach set out in the CMA's approach document, published after the release of its unfair commercial practices guidance, which also set out a timeline for further consultation and guidance – see this Regulatory Outlook. 

Ms Cochrane said that the CMA has two core priorities over the next 12 months:  

• To support compliance and help businesses "to do the right thing".
• To take action to protect consumers from harms stemming from the "more egregious practices" of some businesses, examples of which are set out in the approach document.  

She also said that the CMA is monitoring how entities change their practices in light of the new legislation and that, where it has concerns about compliance, businesses can expect to hear from it. The CMA will publish its decisions on which cases to pursue, based on its public prioritisation principles, "over the coming weeks". 

On implementing the "4Ps" (pace, predictability, proportionality and process), which will govern the CMA's approach to enforcement, she said that: 

• The CMA will publish a timetable at the start of an investigation (pace).
• Businesses will soon be able to rely on the CMA's precedent decisions to predict how consumer law will apply in different scenarios (predictability). The CMA is also exploring further ways to give businesses clarity on conduct that does not infringe the law, especially in areas where there is no legal precedent.
• In determining the level of any penalty, the CMA will take account of proactive steps businesses have taken to correct wrongdoing (proportionality).
• The CMA intends to implement a process which works for businesses of all sizes (process). 

Businesses can therefore expect assistance with compliance where they engage with the CMA, rather than enforcement, over the next 12 months (except for the worst infringements), but the CMA has also made it clear (in its annual plan 2025 to 2026) that it sees enforcement of consumer protection laws as instrumental to securing investment and economic growth. Once the initial 12-month period has passed, therefore, the CMA may well step-up its use of its direct enforcement powers under the DMCCA.  

UK government publishes final strategic steer to the CMA 

Following a consultation on the draft, which closed on 6 March 2025, the government has published its final strategic steer to the CMA. It sets out how the government expects the CMA to support and contribute to the government's overriding national priority – economic growth. The final document is in line with the draft – see this Regulatory Outlook for details.  

EU 

European Commission consults on consumer agenda 2025-2030  

The Commission has launched a call for evidence and a public consultation on a new Consumer Agenda 2025-2030. The agenda will build on the 2020 New Consumer Agenda, outlining updated priorities and actions to tackle current and forthcoming challenges in consumer law and policy. 

The consultation document lists various problems affecting consumers and businesses in the EU, including in relation to: 

• New technologies and data-driven practices, sometimes leading to unfair commercial practices, such as dark patterns, misleading marketing by influencers and addictive design of digital products.
• The development of e-commerce, which has led to increased circulation of unsafe products and difficulties with enforcement against traders established outside the EU.
• A misalignment between consumers' choices and their environmental concerns due to sustainable choices not being easily available and affordable.
• Vulnerable consumers and children who face various challenges associated with new technologies, market trends and unethical practices.
• Administrative burdens and complex regulatory requirements, especially for small to medium-sized enterprises.  

The agenda will complement other key initiatives in the consumer sector, such as the upcoming Digital Fairness Act, slated to address manipulative and unethical commercial practices in the digital world, reduce legal uncertainty for businesses, prevent regulatory fragmentation and facilitate enforcement. It will also seek to harness the opportunities presented by emerging technologies, including AI.  

The consultation and call for evidence close on 11 August 2025.