Consumer law | UK Regulatory Outlook September 2025

UK updates 

CMA guidance on fake reviews and endorsements under DMCCA 

Following publication by the Competition and Markets Authority (CMA) of a slew of new and updated guidance on fake reviews and endorsements, we have published an Insight taking a deeper dive into what the CMA expects from traders and content creators in order to comply with the Digital Markets, Competition and Consumers Act (DMCCA). 

CTSI publishes updated Guidance for Traders on Pricing Practices in light of DMCCA 

The Chartered Trading Standards Institute (CTSI) has updated its 2018 Guidance for Traders on Pricing Practices, focusing on traders' obligations to consumers under the DMCCA. The guidance covers all consumer goods, services and digital content. It applies to all platforms used for business-to-consumer commercial practices, including all distance contracts (online, over the phone, by post etc). The guidance provides examples of good practice on pricing and shows what is and is not likely to comply. 

The guidance will be further updated once amendments to the Price Marking Order come into effect in October 2025 (see this Regulatory Outlook). 

EU updates 

Digital Fairness Act consultation deadline extended 

In July 2025, the European Commission published its much-anticipated consultation and call for evidence on a potential Digital Fairness Act (DFA) to improve consumer protection in the digital sphere. The original deadline for responses was 9 October 2025, but the Commission has now extended it to midnight on 24 October 2025.  

Osborne Clarke has published a series of Insights on topics touched by the consultation: 

• Dark patterns
• Addictive design
• Specific features in digital products – particularly those common in video games
• Unfair personalisation practices
• Social media influencers
• Unfair pricing practices 

See also our Digital Fairness Act (DFA) section. 

New code of conduct for online ratings and reviews for tourism accommodation 

The new EU Code of Conduct for online ratings and reviews for tourism accommodation has been created by tourism industry stakeholders and is intended to support their implementation of existing EU legislation and initiatives in this field, including the Digital Services Act, the Digital Markets Act, the Unfair Commercial Practices Directive and the Platform to Business Regulation.  

Signatories commit to various principles, including: 

• Explaining to users how ratings are calculated by providing a prominent link to the information on the page where the rating is displayed.
• Publishing policies and measures, such as banning, blocking, suspending or labelling accounts that repeatedly violate policy, to mitigate against the impact of those who undermine the integrity of online reviews.
• Clearly labelling sponsored and incentivised reviews.
• Establishing clear, easily accessible means for accommodation providers and consumers to report and flag reviews that are fake, policy-violating or illegal.
• Refraining from generating fake reviews or engaging third parties to do so.  

Signatories include tourist accommodation providers and their representatives, consumer associations and other active stakeholders in the industry.