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Get DMCC Ready: changes to consumer law and its enforcement to take effect from 6 April 2025

10 March, 2025
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2 min read

The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 2) Regulations 2025 (SI 2025/272) have been made.  They bring into force various consumer provisions of the Digital Markets, Competition and Consumers Act 2024 in April 2025 and January 2026.

The new regulations bring the following provisions into force with effect from 6 April 2025 (to the extent they are not already in force):

The consumer law enforcement regime

Part 3 of the Act introduces two regimes for the enforcement of consumer protection law; a court-based regime, where enforcement authorities apply to court for action to be taken against a trader, and a direct enforcement regime operated by the Competition and Markets Authority. This new enforcement regime gives the CMA the ability to issue hefty fines for companies that fail to comply with consumer law.  Earlier this year we published an article written by the CMA explaining how it sees the Act changing the enforcement of UK consumer law.

Unfair commercial practices regime

Part 4 of the Act updates and replaces the Consumer Protection from Unfair Trading Regulations 2008 (CPRs).  The updates include changes to drip pricing law and the introduction of a new banned practice regarding fake and misleading reviews.

However, separate regulations are needed before the provisions relating to consumer rights of redress can come into force.  They will clarify the rights and specific remedies.  Until then, the remedies under the CPRs continue to apply. 

The duty of expedition on the CMA and sectoral regulators

The regulations bring into force the provisions in the Act amending the Enterprise and Regulatory Reform Act 2013 requiring the CMA to exercise its consumer functions as soon as reasonably practicable.  We expect this new duty will mean that the CMA's investigation and enforcement timetables are punchier than previously.

Consumer savings schemes

From 1 January 2026, the Regulations also bring into force the provisions relating to consumer savings schemes. These establish new rules to protect consumers' money paid into saving schemes, such as Christmas savings clubs. 

One aspect of the new Act not brought into effect by these regulations is the new subscriptions regime.  This is expected to come into force no earlier than Spring 2026.

Get DMCC Ready: changes to consumer law and its enforcement to take effect from 6 April 2025