The Digital Markets, Competition and Consumers Act 2024 represents a fundamental reform of UK competition and consumer protection law. While the Act has already entered into force, its most significant impact will be felt from 2025 onwards, with enforcement activity expected to intensify through 2026. Businesses operating in digital markets should prepare for a far more interventionist regulatory environment.
The legislation reflects a broader policy shift towards stronger consumer protection and increased scrutiny of digital business models. Regulators are now equipped with enhanced powers to address practices that are perceived to undermine consumer choice, transparency and fairness.
A tougher regulatory framework for digital markets
One of the central objectives of the Act is to strengthen oversight of digital markets, particularly where businesses hold significant market power or influence consumer behaviour through online platforms. The Competition and Markets Authority now has expanded authority to investigate and intervene in digital markets, including the ability to impose conduct requirements and financial penalties without lengthy court proceedings.
This enhanced enforcement framework is designed to respond more quickly to emerging harms in fast moving digital sectors. As a result, businesses operating online will face closer scrutiny of how their products and services are marketed, priced and delivered to consumers.
Consumer protection enforcement and prohibited practices
The Act introduces a more robust approach to consumer protection, targeting practices that regulators consider unfair or misleading. Subscription models are a particular area of focus. Businesses must ensure that subscription terms are clear, renewal mechanisms are transparent and cancellation processes are straightforward and accessible.
The use of fake or misleading online reviews is also squarely within the regulator’s sights. Businesses are expected to take active steps to prevent the publication of false reviews and to ensure that consumer feedback presented on their platforms is genuine and representative.
Pricing transparency is another key area of enforcement. Hidden fees, drip pricing and unclear promotional claims are increasingly likely to attract regulatory attention. With the CMA now able to impose direct fines for breaches of consumer law, the financial and reputational consequences of non compliance are significantly heightened.
How Penerley supports businesses navigating digital regulation
As enforcement activity increases, proactive compliance will be essential. Penerley advises businesses on aligning their digital operations with the requirements of the Digital Markets, Competition and Consumers Act, helping clients identify and mitigate regulatory risk before issues arise.
Our team supports clients with reviewing consumer terms and conditions, subscription journeys, pricing structures and marketing practices to ensure compliance with evolving consumer protection standards. We also advise on internal compliance programmes, staff training and governance arrangements to support ongoing regulatory readiness.
For businesses facing investigations or enforcement action, Penerley provides strategic advice and representation, helping clients engage effectively with regulators and manage disputes. Our approach combines legal expertise with a practical understanding of commercial realities, ensuring that compliance measures support sustainable business growth.
