DMCC Act 2024 for UK business websites: reviews and pricing

Last checked: October 2026. This article summarises the CMA’s guidance and enforcement news as published on GOV.UK. It is general information, not legal advice. Read the current CMA guidance before changing your site.

The unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) apply to commercial practices from 6 April 2025, according to the CMA’s unfair commercial practices guidance (CMA207). The headline change, in the CMA’s words at the launch, is that it can now decide whether consumer protection laws have been infringed rather than litigating through the courts, and tackle breaches directly, including through redress and fines. CMA207 says breaches of the banned practices can lead to monetary penalties of up to the higher of £300,000 or 10% of worldwide turnover. Most banned practices are also criminal offences; the exceptions listed in section 237 include paragraph 13 of Schedule 20, the fake reviews practice.

CMA207 lists 32 practices that are unfair in all circumstances. Two matter for most business websites: fake reviews and drip pricing. The guidance also says an invitation to purchase directed at UK consumers must comply even if the trader is located outside the UK.

Banned practice 13, as summarised in CMA207, covers submitting, or commissioning another person to submit or write, a fake consumer review or a review that conceals that it was incentivised. It also covers anyone who publishes consumer reviews or review information: publishing them in a misleading way, or without taking reasonable and proportionate steps to prevent fake or concealed incentivised reviews and false or misleading review information, and to remove them. The detail is in the CMA’s fake reviews guidance (CMA208).

• Do not write or buy reviews. CMA208 says commissioning is not limited to money and could include a trader asking a member of staff to review its product. Reviews from employees or shareholders, or incentivised reviews, must not hide that link.
• If your site shows reviews, the CMA’s short guide for publishers says you should have a published policy that clearly prohibits fake reviews and states your approach to incentivised reviews, assess the risk of banned content regularly, and have processes to detect, investigate and remove it.
• Do not cherry-pick. CMA208 says a trader may infringe the law if it suppresses genuine negative or positive reviews or selectively promotes positive or negative ones.
• Star ratings count too. The short guide treats aggregated ratings, review counts and rankings as consumer review information that must not be false or misleading.

This is where a website build meets the law. A widget that shows only five-star entries, or a ratings badge fed by a source you cannot check, deserves a second look. The guide adds that using a third party to monitor reviews does not remove your own responsibility.

CMA207 states that showing consumers an initial headline price and then introducing additional mandatory charges as they proceed with a purchase, sometimes called drip pricing, is prohibited. Under section 230, an invitation to purchase omits material information if it leaves out, among other things, the total price, which includes any fees, taxes or charges the consumer will necessarily incur. The CMA’s detailed rules are in its price transparency guidance (CMA209), published on 18 November 2025. Its summary makes these points for websites:

• A page on your website showing a product and its price will normally be an invitation to purchase, even without a buy button.
• The total price should normally include mandatory charges such as a delivery or booking fee or VAT; listing them separately will not normally be enough.
• Optional delivery charges, such as next-day delivery, must be in the invitation to purchase but can be shown separately from the total. If the customer must choose a delivery option, include the cheapest one until they choose another.
• A “from” price is allowed if it includes all applicable mandatory charges and does not mislead.
• A retail site may comply by showing its delivery fees prominently and a running total, including those fees, throughout the purchase.
• A one-off, flat booking fee per order is a per-transaction charge and belongs in the total price, even in early-stage advertising.
• For a contract with a minimum term, show either the cumulative price for the whole term or the monthly price together with the number of months it is payable.

The CMA first took a phased approach: in March 2025 it said it would re-consult on the less settled aspects, including fixed-term periodic contracts. That consultation has concluded, and CMA209 is the final guidance.

Price is only one item. Section 230(2) lists the information that counts as material in an invitation to purchase, unless it is already apparent from the context. For a typical online shop or service page, the items that matter most are:

• the main characteristics of the product, to the extent appropriate for the medium;
• the total price, or how it will be calculated if it cannot reasonably be calculated in advance;
• the identity of the trader, its business address and any business email address;
• freight, delivery or postal charges not included in the total price that the consumer may choose to incur;
• for products with a right of withdrawal or cancellation, the existence of that right;
• the trader’s payment, delivery, performance or complaint-handling arrangements, where its practice departs from what it has published.

CMA207 adds that the material information must be given clearly, in a timely way and in a way the consumer is likely to see. In our view, a footer link to a contact page that nobody notices may not be enough on its own, so check what a customer sees on the product page itself.

On 18 November 2025 the CMA opened its first investigations under the new powers, into 8 businesses, after a review of more than 400 businesses in 19 sectors, and wrote to 100 businesses across 14 sectors about fees and sales tactics. In April 2026 it ordered the AA to refund more than £760,000 to learner drivers of AA Driving School and BSM Driving School and fined it £4.2 million, because a mandatory £3 booking fee was not included in the upfront price. The CMA said this was its first financial penalty under the new powers.

On fake reviews, the CMA’s one-year review says it sent advisory letters to 54 review publishers after a sweep. On 27 March 2026 it opened investigations into 5 businesses across sectors including funerals, food delivery and car sales, and said it expected an update in September 2026. The concerns it named are close to everyday website features: 1-star reviews moderated by a review provider and not counted towards star ratings, staff allegedly asked to write positive reviews, a ratings system that may have inflated scores, and undisclosed discounts offered in exchange for 5-star reviews. The CMA stressed it had not reached any conclusions. Its blog of 14 October 2026 says those investigations are continuing and a further update is expected in the coming months. The same post says 7 of the 8 November 2025 pricing cases have been settled and that 20 investigations have now been opened.

When the regime started, the CMA said its powers cannot be applied retrospectively, so fines in the first 12 months were likely to be lower than in later years. The October 2026 post notes that businesses have had ample time to comply.

1. List every place your site shows prices: product page, listing, basket, checkout, quotes, emails.
2. Check that mandatory fees, including small booking or admin fees, appear in the headline price or total.
3. Show optional extras separately and make sure none are pre-selected.
4. Check where your reviews and star ratings come from, and whether any incentive or staff link is disclosed.
5. Publish a review policy that prohibits fake reviews and states your approach to incentivised ones.
6. Record a short risk assessment for reviews and repeat it when you change how reviews are collected or shown.
7. Make sure staff and agencies do not post reviews.
8. Keep records of changes and the date.
9. Re-check after every redesign or plug-in change.

We build and adjust UK business websites, including pricing displays and review features, and we can help you describe them for your own legal adviser. We do not give legal advice. Simple presentation sites start from €300. See our services and references, request a quote or get in touch.

The CMA’s October 2026 post also says a new subscription contracts regime will come into force in January. If you sell subscriptions, check the government’s guidance on it before then.

• CMA: Unfair commercial practices guidance (CMA207), PDF, 18 November 2025
• legislation.gov.uk: DMCC Act 2024, section 230
• legislation.gov.uk: DMCC Act 2024, section 237
• GOV.UK: Price transparency (CMA209)
• GOV.UK: Providing clear and accurate information about prices: summary
• GOV.UK: Draft guidance for businesses on price transparency (consultation outcome)
• CMA blog: Our new consumer enforcement regime (10 March 2025)
• GOV.UK: CMA to boost consumer and business confidence as new consumer protection regime comes into force
• CMA: Fake reviews guidance (CMA208), PDF
• GOV.UK: Short guide for businesses publishing consumer reviews
• GOV.UK: CMA launches major consumer protection drive focused on online pricing practices
• GOV.UK: CMA orders the AA and BSM driving schools to refund learner drivers over drip pricing
• GOV.UK: Fake and misleading reviews: 5 businesses under CMA investigation
• CMA blog: Direct consumer enforcement: one year on (17 April 2026)
• CMA blog: Direct consumer enforcement: 18 months on (14 October 2026)