Consumer Law | UK Regulatory Outlook November 2025

UK updates 

Digital Markets, Competition and Consumers Act 2024 updates 

CMA publishes final guidance on price transparency  

The Competition and Markets Authority (CMA) has published its final price transparency guidance under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The CMA adopted a phased approach to the "drip pricing" aspects of its new guidance on the unfair commercial practices regime under the DMCCA, and consulted on draft guidance on price transparency in the summer (see our Insight for more information).  

The guidance covers what businesses must include in their pricing information (including mandatory fees and charges), as well as the concepts of "drip pricing" and "partitioned pricing".   

The CMA has made some changes to the final guidance to address issues raised by stakeholders in response to the consultation. For example, it provided: 

• More information on who is legally responsible for making an invitation to purchase.
• More examples of ways in which traders may comply with the price transparency requirements in both online and offline contexts, including in relation to delivery charges.
• Updated guidance on when the limitations of the medium may justify the omission of required pricing information.

The CMA has also published guidance on obtaining consent for additional charges when selling online. This explains traders' responsibilities when selling optional extras (as opposed to making mandatory charges) to customers online (such as insurance, faster delivery, charitable donations), alongside visual examples of compliant and non-compliant practices. 

Enforcement action on online pricing and sales practices  

Using its new powers under the DMCCA, the CMA has launched an enforcement action covering online pricing practices, including drip pricing and pressure selling. It has reviewed more than 400 businesses across 19 different sectors to assess compliance with the rules on price transparency and found potential concerns in 14 sectors. Based on this work, the CMA has: 

• Launched investigations into eight businesses that it suspects may have broken consumer law in relation to their use of fees, misleading time-limited offers and/or the practice of automatically opting-in consumers to optional charges.
• Sent advisory letters to 100 businesses outlining concerns about their use of additional fees and some of their online sales tactics. The sectors under scrutiny are holidays (including package travel), driving schools, homeware retailers, rail travel, parking (including airport parking), bus and coach travel, luggage storage providers, cinemas, live event tickets, food and drink delivery companies, letter and parcel delivery, gyms and fitness, fashion, and online vouchers.
• Under the DMCCA, the CMA is now able to determine whether a breach of consumer law has occurred without intervention from the courts and can directly impose fines for non-compliance of up to 10% of global turnover. 

Secondary ticketing resale updates 

Government's response to the consultation on the resale of live events tickets 

The government has published its response to the consultation on the resale of live events tickets. See this Regulatory Outlook for the background of its work on the secondary ticketing market to ensure that fans are protected from misleading or harmful practices in this sector and are able to resell tickets to other fans when they cannot attend an event.  

As a result of the consultation process, the government intends to take forward the following measures: 

• Price cap for resale tickets: Reforms to introduce a price cap making it unlawful to resell live events tickets for more than the original ticket cost, inclusive of unavoidable fees incurred during the original purchase.
• Resale service fees cap: A cap on the level of service fees that can be levied by resale platforms on resale transactions.
• Resale volume limits: New limits which would prohibit someone from reselling more tickets to an event than they were entitled to purchase originally.
• Enforcement: New ticketing measures will be enforced under the new consumer enforcement regime in Part 3 of the DMCCA, which provides for financial penalties of up to 10% of global turnover. The government has decided not to take forward a licensing regime for now, but may revisit this if the consumer enforcement regime does not deliver satisfactory outcomes.
• The government intends to legislate for the above when parliamentary time allows.  

Government's response to the call for evidence on pricing practices in the live events sector 

The government has published its response to the call for evidence on pricing practices in the live events sector. As a result of the implementation of the DMCCA, it does not believe that further legislation is needed to ensure that prices are clear.  

The CMA, as part of its project on dynamic pricing, set out key types of information that could be material for consumers and tips for businesses using dynamic pricing based on existing law (see this Regulatory Outlook). On the back of the CMA's new guidance, the government expects the live events industry, particularly those involved directly in ticket sales, "to take decisive action." 

EU updates 

European Commission publishes 2030 Consumer Agenda  

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

The agenda addresses four key priority areas:  

• An action plan for consumers in the single market: As part of this, the Commission plans to complete an evaluation of the Geo-Blocking Regulation in Q2 2026 as well as further analysis of the benefits, challenges and possible risks of extending its scope.
• Digital fairness and online consumer protection: Among other measures in this area, the Commission plans to: Propose a Digital Fairness Act, planned for Q4 2026, to further strengthen the protection of consumers online (see Osborne Clarke's Digital Fairness Act hub for more information); conduct an EU-wide inquiry into the broader impacts of social media on the wellbeing of young people; evaluate the Audiovisual Media Services Directive; further strengthen the ability to combat online fraud in the EU by publishing an action plan on online fraud; and work closely with Member States to ensure the consistent implementation and enforcement of the AI Act and the relevant consumer protection and product safety laws.
• Promoting sustainable consumption. The Commission will, among other things, explore the need for a recommendation on "green by design" features in e-commerce. This would cover aspects such as the availability of sustainability filters, greener delivery options and sustainable return-management policies. It may also include voluntary environmental charters, under which companies commit to specific sustainability targets.
• Effective enforcement and redress. The Commission will propose a revision of the Consumer Protection Cooperation Regulation, maximise the use of AI in enforcement and market surveillance activities, and focus on ensuring effective redress through the implementation of the revised Alternative Dispute Resolution Directive, the Representative Actions Directive and the revised Product Liability Directive.

Protecting consumers in vulnerable situations, such as children in the digital environment, as well as simplification and administrative burden reduction are overarching priorities, says the Commission.