- within Wealth Management, Law Practice Management and Coronavirus (COVID-19) topic(s)
The UK Competition and Markets Authority ("CMA") has launched a sweeping consumer protection drive targeting online pricing and sales practices, marking its first enforcement actions under the Digital Markets, Competition and Consumers Act 2024 ("DMCCA"). On 18 November 2025, the CMA announced that it had:
- Opened investigations into eight businesses across the ticketing, driving schools, gyms, and homeware sectors;
- Issued advisory letters to 100 firms, following a cross‑economy review of more than 400 businesses across a diverse range of further sectors; and
- Published final price transparency guidance.
This marks a step change in UK consumer law enforcement, with immediate implications for any business selling online to UK consumers. More broadly, it seems to mark the beginning of a new era of enforcement of consumer law in the United Kingdom by the CMA, which all consumer-facing businesses should prepare for.
What is the CMA Looking At?
The new investigations build on the CMA's cross-economy review by primarily focusing on the following key online pricing practices in high-spend sectors for UK consumers:
- Drip pricing, comprising omitting mandatory fees from up-front prices or introducing unavoidable charges late in the funnel;
- Misleading "time‑limited" offers and countdown timers;
- Default opt‑ins for ancillary services; and
- Pressure‑selling tactics that distort consumer choice.
The investigations include scrutiny of whether mandatory fees are included in the first price shown, whether time‑limited sales end when advertised, and whether customers are automatically opted into add‑ons.
What is Novel About This Development?
The CMA is using its new powers to enforce consumer protection law under the DMCCA for the first time. These new powers allow the CMA to launch administrative investigations (rather than the prior cumbersome court-based procedure) and, if an infringement of consumer law is found, the CMA may impose penalties on the business of up to 10% of its worldwide turnover, and/or may require it to take certain "enhanced consumer measures." These can include offering compensation or other redress to affected consumers, compliance measures, and "choice" measures (actions enabling consumers to choose more effectively between the suppliers of their goods, services or content). In short, consumer protection enforcement is now very similar to the enforcement of competition law. This materially increases both the speed and the stakes of consumer protection enforcement, and, the CMA has been clear from the outset of the new rules that it intends to use them fully.
Although several behaviours under examination, such as drip pricing and misleading headline prices, were already unlawful under the Consumer Protection from Unfair Trading Regulations 2008, the DMCCA regime sharpens prohibitions and enforcement mechanisms, and specifically targets practices like misleading countdown timers and default opt‑ins. The CMA's publication of final price transparency guidance, combined with immediate enforcement and market‑wide advisory letters, signals a coordinated "act now" approach rather than gradual education followed by later action.
The scope of the CMA's work into online pricing is strikingly broad. The CMA's cross-economy review spanned 19 sectors and found concerns in 14, with enforcement and advisory letters reaching businesses operating across everyday consumer journeys: from buying tickets and furniture to joining gyms, booking travel and arranging deliveries. This cross-market approach elevates pricing transparency from a sector nuance to a baseline compliance imperative for all online retailers and service providers. Indeed, the CMA has stressed that, "This is just the start of our work. Any businesses who break consumer law should be in no doubt we will stamp out illegal conduct and protect the interests of consumers and fair-dealing businesses."
How Should Consumer-facing Businesses Respond?
In light of these developments, businesses should move quickly to evaluate pricing displays, promotional mechanics, and checkout flows against the CMA's final price transparency guidance and unfair commercial practices guidance. The overriding principle is that the price the consumer sees up front must include all mandatory charges, with optional extras presented clearly and not already selected by default. In particular, "time-limited" claims must be accurate and time‑bound, not perpetually reset or extended, and any urgency and scarcity messaging must be truthful, substantiated, and not designed to mislead. Headline prices should not exclude compulsory costs. Any unavoidable fees introduced later in the journey are high-risk.
Consumer law compliance matters now more than ever. The CMA's new process allows it to move from review to enforcement rapidly, and these most recent developments underline that it is serious about doing so. Firms should ensure internal sign‑off frameworks capture pricing rules, maintain evidence to substantiate promotional claims, and implement monitoring to detect non‑compliant patterns across web, app, and third‑party platforms. Failure to reply or provision of incomplete data may, themselves, trigger penalties.
Finally, boards should calibrate risk to the new landscape and potential exposure to greater penalties. The DMCCA's turnover‑based fines, plus potential compensation orders, change the cost‑benefit calculus for online pricing practices. Advisory letters received by many firms are a red flag to act now, not a warning to file in a drawer for later. Even businesses not contacted should assume scrutiny and align promptly, given the breadth of the CMA's action and its stated intent to continue sector‑wide monitoring and enforcement.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2025. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.