Living With CMA Direct Enforcement: Consumer Law Compliance Under the DMCC Act

Introduction

Since April 2025, the Competition and Markets Authority has been able to decide that a business has breached consumer law and impose a penalty directly, without first going to court. Penalties can reach the higher of £300,000 or 10% of global turnover, with further exposure for failing to comply with information requests and directions.

The regime is no longer theoretical. The first wave of investigations, the advisory letters issued across a range of consumer sectors, and the first penalties under the Digital Markets, Competition and Consumers Act 2024 have given businesses a clear picture of where the regulator is looking and how it builds a case.

This session covers the substantive rules, the mechanics of an investigation, what the early outcomes tell us about the CMA's approach and the practical compliance work consumer-facing businesses should now have in place.

What You Will Learn

This webinar will cover the following:

• The DMCC Act 2024 regime: direct enforcement from 6 April 2025 and how it differs from the previous court-based route
• The scale of exposure: penalties of up to 10% of global turnover or £300,000, individual penalties, and additional penalties for non-compliance with notices
• The substantive rules: unfair commercial practices, banned practices, drip pricing, fake reviews, invitations to purchase and unfair contract terms
• Lessons from the first wave: the opening investigations, the first penalty decisions, and the significance of the CMA's advisory letter campaign
• CMA priorities: aggressive sales practices, consumers in vulnerable positions, hidden fees, unfair exit charges, and the use of AI by traders
• Inside an investigation: information notices, interim steps, infringement notices, undertakings, settlement and the CMA's penalty methodology
• Redress and directions: consumer compensation, enhanced consumer measures, and compliance programmes imposed as part of an outcome
• Practical readiness: pricing and checkout audits, review governance, marketing sign-off processes, and preparing for the subscription contracts regime