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The Competition and Markets Authority has published its draft Annual Plan for 2026-27, signalling a year of increased focus on consumer protection.
While still subject to consultation, the draft Annual Plan gives a clear steer on the CMA's priorities for the year ahead. We've blogged separately about the CMA's new consumer enforcement powers under the Digital Markets Competition and Consumers Act 2024. The draft plan commits the CMA to implementing this new enforcement regime and to double down on clear breaches of the law, particularly in areas of essential household spend.
The CMA's overarching goal is simple, to "put money back in people's pockets" while supporting fair competition. It intends to use its new enhanced powers to deliver this.
The consultation on the draft Annual Plan is open until 18 February 2026, with the final version due in March 2026.
The big picture
This plan is the "first detailed implementation step" under the CMA's 2026-2029 Strategy, which puts "championing consumers" at the heart of driving economic growth and improving household prosperity. The CMA wants people to trust the markets they buy from and for fair-dealing businesses to compete on a level playing field.
A central part of the CMA's strategy is its transformational "4Ps" operating model: pace, predictability, proportionality and process. The CMA says it will embed these principles in its consumer protection work by actively streamlining cases to focus on the most important concerns and by publishing regular information about investigation progress including timings and next steps.
Where the CMA will put its enforcement energy
While the CMA says it will help businesses understand the new rules and sort out problems early, it is also clear that where the law is certain, and the harm is serious, it will not hesitate to act decisively.
Priority also goes to tackling "egregious practices" (i.e. practices that are obviously and seriously wrong), including:
- providing objectively false information to consumers;
- aggressive sales practices that prey on vulnerable consumers;
- banned practices, such as fake reviews;
- hidden fees; and
- clearly imbalanced and unfair contract terms (e.g. unfair exit charges).
The CMA commits to progressing its first investigations under the new regime with a focus on price transparency and online choice architecture, in sectors such as secondary ticketing, homeware and personal fitness. It will also drive sector-wide change by issuing advisory letters, highlighting compliance risks and encouraging fixes without the need for a formal investigation.
What this means for consumer-facing brands
Consumer facing businesses should check their customer journeys for price transparency and to ensure there are no design choices that could unfairly steer or mislead consumers. Now is the time to get compliant!
Given the explicit focus on "cost-of-living" pressures, businesses should also expect closer scrutiny of pricing claims, how add-ons and options are presented, and whether key terms are fair, especially when operating in sectors that are key to household budgets.
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