Digital Markets, Competition and Consumers (DMCC) Act

The Digital Markets, Competition and Consumers (DMCC) Act has introduced an entirely new digital markets regulatory system overseen by the Competition and Markets Authority’s Digital Markets Unit. It resets the landscape for consumer law enforcement in the UK and modernises the competition law regime – with far-reaching implications for all consumer-facing organisations, not just the tech sector.

We’ve already seen that the CMA is willing to use its new powers for breaches of competition and consumer law. Our Digital, Data and Commercial team advises businesses across a wide range of sectors on compliance with the DMCC Act, managing CMA investigations, and can help you update your policies and procedures to ensure compliance.

DMCC Act: Key takeaways

Digital Markets

The CMA’s Digital Markets Unit has been handed statutory powers which enable it to regulate the larges tech firms that have ‘strategic market status’ (SMS). Using its powers, the CMA can:

Open investigations to designate firms as having SMS in relation to a wide range of digital activities.
Impose tailored conduct requirements for SMS firms. These will effectively operate as a form of bespoke regulation for each SMS firm.
Make flexible ‘pro-competitive interventions’ in relation to SMS firms where required.to address structural market concerns.
More easily intervene and scrutinise merger activities involving SMS firms.

Competition

There are no substantive changes to competition laws, but the CMA will be handed much tougher enforcement powers. Including:

Enhanced powers to force companies to provide data/ information during investigations.
New and extended dawn raid powers for the CMA.
Codifying the CMA’s extra-territorial reach to order disclosure of documents stored outside the UK.
The ability to impose penalties up to 5% of global turnover on companies that breach commitments, undertakings or market investigation orders.

The Act also updates and amends the CMA’s merger notification and jurisdictional framework.

Consumer

The Act elevates consumer law compliance to new levels. The CMA has been handed game-changing new powers to impose penalties up to 10% of global turnover on companies that breach UK consumer protection laws. In addition:

Existing rules on unfair commercial practices are amended and updated in a number of areas. This includes tighter restrictions on drip pricing and a wider definition of vulnerable consumers.
There are detailed and prescriptive new rules for B2C subscription contracts and online product reviews.
Other enforcers, including local authorities, will have the power to apply to the court to impose civil penalties (without having to prosecute).

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What's next?

Digital regulation

For digital regulation, the DMCC Act marks a major shift from general competition enforcement to a more targeted, forward-looking regime for the most powerful digital firms. It gives the CMA’s Digital Markets Unit powers to designate firms with strategic market status, impose tailored conduct requirements and introduce pro-competitive interventions where needed, with the aim of making digital markets fairer, more open and more contestable.

Businesses should review how digital products and services are designed, sold and governed: check pricing journeys for transparency, test subscription and cancellation processes, audit how online reviews are collected and presented, and make sure legal, compliance, product and marketing teams are aligned on who owns DMCC risk.

Enforcement

For enforcement, the DMCC Act gives the CMA sharper tools and greater freedom to act quickly.

Now is the time to move from reactive compliance to enforcement readiness: review internal escalation routes, make sure teams know how to respond to CMA information requests, check document retention and governance processes, and test whether legal, compliance, customer, product and marketing teams can identify and fix higher-risk practices. Compliance should be treated as a live operational issue with clear ownership, training and board-level visibility.

In practice: Read our insights

28 April 2026

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The Law Commission announced on 20 April 2026 that it will conduct a review into the merits of introducing a new consumer class actions regime, prompted by a request from the UK government.

We explore the UK's current collective damanages regime and what this review could mean.

16 april 2026

CMA issues first fine for breach of consumer law under the DMCC Act in drip pricing case

In a landmark enforcement action, the Competition and Markets Authority has imposed its first financial penalty for a breach of consumer law using its new direct consumer enforcement powers under the Digital Markets, Competition and Consumers Act 2024, just five months after formally opening the case.

Consumer law risk mapping tool

In this video, Partner Richard Collie introduces our consumer law risk mapping tool. He gives an overview of the impact assessment topics and the bespoke report you'll receive afterwards to help you navigate the DMCC Act.