Digital Markets, Competition and Consumers Act 2024 (DMCC) – traders guide

Our guide to navigating the Consumer Law Revolution: what these major changes mean for your business and what you need to do now

The UK’s consumer law protection framework is experiencing one of the largest overhauls in over a decade, with the introduction of the Digital Markets, Competition and Consumers Act 2024 (DMCC). If you are a business that sells or supplies products, services, or digital content online or in person to UK consumers, you are engaging in a commercial practice, and therefore the DMCC likely applies to you.

This article covers what has already changed, what is coming next, and how Debello Law can help you to stay compliant and competitive in the industry.

A brief recap: what is the DMCC?

Introduced in May 2024, the DMCC is a landmark piece of legislation that has two central aims:

• To strengthen consumer protection, particularly in digital markets, by banning unfair commercial practices and improving transparency in online transactions; and
• To regulate the behaviour of digital platforms, promoting fair competition across the UK economy.

Rather than taking effect all at once, the DMCC is being implemented gradually in stages to allow businesses time to adapt. The first wave of measures, focusing on fake reviews and drip pricing, came into force on 6 April 2025 following a period of consultation and the publication of CMA Guidance (Unfair Commercial Practices and Approach to Consumer Protection). Additional reforms concerning subscription renewal traps and improving how customer complaints are handled have not taken effect yet but are expected to follow.

As two of these provisions are now in force, retailers should be taking active steps to ensure compliance and avoid the risks of reputational damage, financial penalties, and legal scrutiny.

What is the relevant terminology to be aware of?

• Consumer review is defined as a “review of a product, a trader or any other matter relevant to a transactional decision”. This includes reviews which focus on aspects of the transaction, including delivery or after-sales care. It can take different forms, including text, speech, graphic images such as a star rating or thumbs up/down, video reviews, testimonials in advertisements, social media posts that contain consumer opinions, and influencer content that is not clearly marked as sponsored or incentivised.
• Drip pricing can be defined in the online retail sector as a sales technique where an initial headline price is displayed at the start of the purchase and additional mandatory fees are revealed (or “dripped”) later in the transaction process. The objective being to gain the consumer’s interest by advertising a misleadingly low price, with the true final cost being disclosed at a later stage, after the consumer has already spent considerable time and effort in the transaction process.

• Fake review is defined as a “review that purports to be, but is not, based on a person’s genuine experience”. Generally, a fake review would be positive, to artificially boost a product or retailer’s rating in comparison to its competitors. However, they can also be negative, in circumstances where they are false and intended to harm the businesses reputation.

What do the new rules mean for your business?  

Retailers are now subject to new rules on the use of consumer reviews and pricing transparency, designed to tackle misleading selling practices and improve consumer confidence.

1. Ban on fake and misleading consumer reviews

The DMCC makes it unlawful to use or facilitate fake or misleading consumer reviews in a commercial practice. The key activities that are now prohibited are:

1. Making, publishing or commissioning fake reviews. This includes providing them to other traders to post on their website or publishing them on your own website or social media platforms. It covers those written by staff, agencies, or bots pretending to be genuine customers.

1. Offering incentives (e.g. discounts and free products) in exchange for reviews. This is unless it is made expressly clear, prior to entering the incentivised transaction with the consumer, that the review must reflect the consumers genuine experience, and they must disclose the fact their review has been incentivised. As a business, when the consumer review is published, you must prominently disclose that it was incentivised (e.g. by marking it as an advertisement). Retailers are also required to distinguish incentivised reviews from other consumer reviews and take appropriate steps to stop incentivised reviews from misleading other consumers (e.g. by not including these reviews towards a products overall displayed review rating).

1. Publishing consumer reviews in a misleading way. This includes selectively publishing only positive consumer reviews, supressing or deleting negative consumer reviews, or only encouraging those who are satisfied to leave reviews – essentially, taking any action that would give a misleading impression to other consumers. This does not mean you need to publish all reviews, but if you choose to highlight only some reviews, you must ensure that the presentation of the consumer reviews is balanced and representative.

1. Displaying aggregate ratings or testimonials that are unsubstantiated. Consumer reviews based on ratings should be backed up by verified data. If you make a claim such as you are “the UK’s most reviewed makeup brand”, you must be able to substantiate that claim. This also includes the prohibition of displaying reviews relating to different products than the product that a consumer is viewing on the landing page. If you display or link to reviews, you must take reasonable steps to ensure their authenticity by checking the review provider’s moderation methods, monitoring for suspicious or spam content, and acting quickly to remove or challenge fake reviews when identified.

2. Ban on drip pricing

This practice is now prohibited under the DMCC, as all mandatory additional fees must be included in the up-front price.

In practice, this means that the advertised price must now reflect the true total minimum price a consumer could reasonably expect to pay for the product, including all non-optional fees, taxes, charges or other payments.

This information must be presented clearly, prominently and in a timely manner at the beginning of the transaction process. The obligation to disclose the full price applies from the moment the price is first presented, before the consumer starts to make a purchasing decision, including:

• search results on a search engine,
• homepage promotions,
• product listing pages, and
• in advertisement and marketing emails.

What are mandatory charges that must be included in the initial price up-front?

Mandatory fees, taxes, charges or other payments are where the consumer cannot purchase the product without these being applied, including VAT, service charges, booking fees, platform or admin fees. For example, an event ticket site advertises a concert ticket for £60, but there is a £10 administrative fee added at the final checkout stage of the transaction process. This fee is mandatory, so to comply with the DMCC the additional fee must be disclosed up-front.

Qualifiers such as “from £X” or “starting at £X” are still valid, so long as the lowest price shown is a true reflection of the purchase price including all mandatory fees. Using the concert ticket example, if there are multiple ticket prices, an appropriate qualifier would be “from £70” where this is the minimum total price, as this includes the ticket price of £60 plus the £10 administrative fee.

What charges can be displayed separately?

There are certain categories of fees and charges that may be displayed separately to the up-front price, provided they are clearly presented and not misleading. These are:

• Optional add-ons such as premium delivery, gift wrapping, optional additional services, or extended warranty cover. These do not need to be included in the headline price, so long as they are genuinely optional and not essential to completing the purchase for the product or service.

• If, due to the nature of the product or service, the total price genuinely depends on choices the consumer makes, these additional costs do not have to be included in the up-front price, but businesses are expected to still provide clear pricing guidance. Examples include delivery charges that vary by post code or location, custom product pricing, and charges based on time, date or group size (e.g. peak and off-peak pricing). To achieve best practice, based on the latest guidance, businesses should inform consumers early in the purchase journey what factors influence the price and show a realistic price range before the checkout stage.

• In limited situations, if the price (or part of it) cannot be reasonably determined in advance, the advertisement must flag these additional charges clearly with a warning or explanation that such charges apply, even if the amount cannot be known in advance. This may occur where the retailer faces third-party charges outside of their control, such as international customs duties or local taxes, currency conversion fees, or third-party facility fees.

What actions should be taken to ensure compliance?

Recommendations to comply with the ban on fake and misleading consumer reviews

This applies to anyone who engages in the commercial practice of submitting, commissioning or publishing prohibited reviews, as well as those who facilitate fake or misleading consumer reviews.

Who is responsible for ensuring compliance?

This includes professional reviewers, journalists, content creators, e-commerce websites, online marketplaces, social media platforms, recommendation platforms, search engines, booking agents, and review sites.

All traders are individually responsible for any consumer reviews they display, including those reviews obtained via direct consumers or third-party platforms.

It is important to be aware that the new rules go beyond merely prohibiting certain activities, they also place a positive duty on traders that publish consumer reviews to take proportionate and reasonable steps to detect, prevent, and remove fake and misleading reviews.

What are “proportionate and reasonable” steps?

The CMA recognises that this will vary from business to business, generally depending on relevant factors including the size of the business, the state-of-the-art that it has available, and the platform(s) it operates on. As a minimum, in addition to refraining from carrying out the above prohibited activities, the CMA expects businesses who publish consumer reviews to take the following positive steps:

• Conduct regular internal risk-assessments of the likelihood that consumers will encounter prohibited reviews and the adequacy of the businesses’ prevention and removal processes. This should be periodically reviewed to ensure compliance is maintained and is not intended to be a one-off exercise.

• Where a risk is identified, the business should establish systems, policies and procedures to detect, investigate and deal with prohibited reviews.

• Have a feedback mechanism for members of the public to report perceived problematic reviews.

• Introduce a written policy to explain how you collect, verify, and publish customer feedback, how you monitor for fake and misleading content, how you respond to challenges, and if applicable, what your approach is to incentivised reviews and how these will be prominently disclosed.

• Avoid using service providers that promise to artificially inflate review ratings.

• Avoid using default opt-ins for reviews which could be seen as manipulating consumer feedback. Use neutral prompts, give all consumers an equal opportunity to submit feedback, and avoid steering language that encourages positive reviews.

• Avoid suppressing, filtering or editing consumer reviews based on sentiment alone.

• Have an internal system to keep a comprehensive record of any actions taken regarding consumer reviews.

Where possible, our other recommendations for promoting compliance include:

• Use moderation tools or manual checks to flag suspicious consumer reviews. If you operate review moderation, this must be applied consistently, fairly and explained in your written consumer review policy.

• Use fraud detection or verified buyer badges when permitting anonymous or pseudonymous consumer reviews.

• Provide comprehensive refresher training to relevant teams. All marketing, sales, web development, and customer service teams should be informed of the new rules and understand how to apply them.

Recommendations for responding to the ban on drip pricing

This applies to any trader that sells to UK consumers, regardless of their sector or size, if they display prices of their products or services where mandatory fees and charges are applied. While online sales are the primary focus, the rules also apply to in-person sales where an initial price is advertised with additional fees and charges later disclosed.

This includes overseas businesses that offer goods or services specifically to the UK market, for example by having their pricing in GBP, UK shipping options, or sites displayed in the English language.

For platforms that aggregate or resell listings from multiple suppliers (e.g. ticketing, travel, or marketplaces), these rules still apply to the site host even if they are not the original seller. The CMA expects these platforms to set minimum pricing transparency standards for its suppliers, monitor compliance, and remove or correct non-compliant listings.

In circumstances where a trader sells its product or service via a third-party platform or marketplace, the trader bears ultimate responsibility for ensuring the total price presented is accurate and compliant.

To comply with the new rules, businesses should:

• Review and update pricing displays across all sales channels to ensure pricing is transparent early in the transaction process. All prices shown to consumers must include all mandatory charges up-front. This must be displayed at the first material point where a price is shown. This applies across all product listings, promotional banners, advertisements, search results and landing pages.

• Identify and categorise fees accurately. You should be able to distinguish between your mandatory fees and any optional add-ons. Optional add-ons may be displayed separately to the up-front price but must not be pre-selected or misleading.

• Ensure pricing information is clear, prominent and understandable. This means avoiding the use of small print or vague disclaimers. Any non-optional charges must be made known to the consumer in clear and plain language.

• Provide comprehensive refresher training to relevant teams. All marketing, sales, web development, and customer service teams should be informed of the new rules and understand how to apply them.

What are the consequences of non-compliance?

If you fail to comply with the new rules on drip pricing or fake and misleading reviews, the new regime introduces tougher penalties and gives the regulator, the CMA, enhanced powers to issue enforcement notices without court proceedings where serious breaches are identified.

The potential consequences of getting it wrong include:

• Significant fines, as the CMA has the power to impose fines up to £300,000 or 10% of annual global turnover (whichever is higher) for breaches.

• Legal directions and enforcement action, including provisional and final infringement notices, requiring specific changes to your practices or website, directions to stop unlawful activity, orders to refund consumers or provide other forms of redress, and requiring you to issue a public statement to acknowledge a breach or correct misleading information.

• Heightened regulatory scrutiny, if you fail to comply your business may be prioritised for future monitoring by the CMA, particularly in high-risk sectors such as travel, events, hospitality, and health and wellness.

• Reputational damage arising from CMA investigations and fines being publicised, which can lead to negative press and loss of consumer trust in the brand.

• Supplier contract breaches could occur if you fail to comply with rules for listing on marketplaces, advertising platforms, or using affiliates.

The CMA has outlined its enforcement strategy for the first three months following the DMCC’s implementation on 6 April 2025:

• It will be focusing on obvious violations of the new drip pricing rules, such as mandatory fees being added late in the purchase process. For more complex areas, like pricing structures in fixed-term contracts, the CMA plans to consult further in the summer and issue detailed guidance in the autumn; and

• It will refrain from enforcement actions related to fake reviews during this period, instead focus on supporting businesses in aligning with the new rules.

How we can assist

At Debello Law, we specialise in helping retailers interpret and implement regulatory changes. Compliance is not only about avoiding the risk and penalties, but is also necessary to maintain long-term trust with your consumers and establish a robust compliance framework.

We are ready to help your business understand the new rules, make necessary changes, and maintain compliance. We provide tailored packages that include the following services:

• Undertaking audits of your website, purchasing journey and marketing to ensure your business is legally compliant and drop pricing risks are eliminated;
• Performing a risk assessment to identify gaps in compliance and recommend changes to the way you are operating;
• Developing or updating your consumer review policies and procedures to meet the CMA’s expectations;
• Offering practical resources and staff training on how to apply said policies and procedures; and
• Providing strategic guidance to anticipate and manage consumer complaints or CMA intervention.

This article is provided for general information purposes only and does not constitute legal advice. If you would like to discuss your businesses legal requirements further, please get in touch with us.