The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has overhauled the regulatory framework for consumer protection and affects all businesses that engage in commercial practices directed at consumers in the UK.
A key change introduced by the DMCCA is the new enforcement regime, a dual regime by which the Competition and Markets Authority (“CMA”) can take action against businesses directly or via the court-based enforcement regime.
Although the DMCCA is a UK-specific regime, its reach extends beyond UK-headquartered businesses. Any business, wherever it is based, that markets or sells goods or services to consumers in the UK must ensure its commercial practices comply with the Act. For multinational organizations, this means reviewing whether global pricing models, online purchasing journeys and consumer-facing terms that may be compliant in other jurisdictions meet the UK’s stricter consumer protection requirements. Businesses should be cautious about assuming that a single global approach will satisfy all regulatory regimes, particularly where pricing transparency and consumer disclosures are concerned.
The CMA has also been granted significant powers to impose fines, as well as compensate consumers. For example, if a business fails to comply with a final infringement notice the CMA can impose fines of £300,000 or 10% of the businesses’ turnover (whichever is higher).
In the CMA’s April 2025 paper on its approach to consumer protection, the CMA highlighted that drip pricing would be one of their areas of focus for investigation. Drip pricing is the practice of providing an initial price to consumers and then adding mandatory charges to that initial price further down the purchasing process. The DMCCA prohibits drip pricing.
The CMA delivered on its promise and issued its first fine imposed for a breach of consumer law to AA-owned driving schools (AA and BSM) in April 2026. The CMA’s investigation found that learner drivers were not shown the total price of lessons upfront when booking online, as a £3 mandatory booking fee was only included later in the purchasing journey. This breach, which affected over 80,000 individuals, attracted a £4.2 million fine as well as an order to refund more than £760,000 to customers.
More recently, in June 2026, the CMA fined StubHub (a ticket resale marketplace) £889,200 and ordered it to pay refunds of over £590,000 to customers for drip pricing. StubHub had added mandatory fees (for delivery and service) at the final stage of checkout, failing to provide customers with a total price upfront.
It is worth noting that, in both instances, the fines include a 40% reduction (the maximum reduction available) for admitting to breaking the law and agreeing to settle early. This underlines the importance of engaging constructively with CMA investigations early on.
The CMA continues to target drip pricing, with a number of investigations currently open including those against viagogo, Gold’s Gym and Ryanair. Given the CMA’s focus on drip pricing, businesses should act now to evaluate whether their customers’ purchasing journey complies with the DMCCA. This is particularly important for multinational organisations with centralised pricing and online sales processes, as the CMA has shown it is prepared to use its enhanced enforcement powers against any business serving UK consumers.
For further information on the DMCCA, please contact Dorothy Agnew.
