The UK’s antitrust and consumer agency—the Competition and Markets Authority (CMA)—has announced its first enforcement actions under the country’s new consumer protection regime. On November 18, 2025, the CMA opened eight investigations into various pricing practices, issued advisory letters to 100 businesses across 14 sectors, and published new price transparency guidance. The actions send a clear message: the CMA is ready to deploy its new, enhanced powers to tackle business practices that it believes are the most harmful to consumers.

Background: The Digital Markets Competition and Consumer Act (DMCCA) Powers

In April 2025, the CMA gained the ability to impose sanctions on businesses in breach of consumer laws without needing to go through court. The agency’s enhanced powers under the new regime include the ability to fine businesses up to 10 percent of global turnover and to require financial redress for the affected consumers’ losses. Read our previous Alert for more information on the CMA’s new consumer protection powers.

First CMA Actions Signal New Era for Consumer Protection

Following a cross-economy review that lasted seven months, the CMA has launched investigations into eight businesses across four sectors (event ticketing, driving schools, fitness, and home goods), focusing on “drip” pricing, and online sales tactics that risk pressuring consumers into rushed or unwanted purchases. The investigations target the following:

  • StubHub, viagogo, the AA Driving School, BSM Driving School, and Gold’s Gym in relation to a potential failure to disclose all mandatory charges in the initial prices quoted to consumers.
  • Homeware retailers Wayfair, Appliances Direct, and Marks Electrical to determine whether i) time-limited sales offers to consumers were accurate; and ii) customers were being automatically opted in to purchasing optional extras.

If the CMA finds there has been a breach of the consumer protection rules, it will issue a provisional infringement notice, allowing the businesses to respond. Parties may settle or offer commitments (with the possibility of significant fine reductions for early settlements, and no fines or admission of liability in the case of commitments), but otherwise face the sanctions detailed above.

Additionally, the CMA has sent out advisory letters to 100 businesses across 14 key areas of consumer spending in the UK, asking for a review of their compliance with consumer laws and their practices’ alignment with the agency’s new guidance on price transparency. The sectors involved are holidays (including package travel), driving schools, homeware retailers, rail travel, parking and airport parking, bus and coach travel, luggage storage providers, cinemas, live event tickets, food and drink delivery companies, letter and parcel delivery, gyms and fitness, fashion, and online vouchers.

This proactive approach to “prevent rather than cure” reflects the CMA’s mission to promote growth in the UK economy. That said, businesses are not off the hook—the CMA typically sends advisory letters when it has identified concerning conduct that it would like the recipient to address, meaning that the receipt of an advisory letter is a strong steer to the recipient to bring their business into line.

CMA CEO Sarah Cardell confirmed that “[t]his is just the start of our work,” warning businesses that the CMA will “stamp out” illegal conduct and protect consumers and fair-dealing businesses alike.

Intensified Scrutiny on Live Event Ticketing

The launch of investigations into the live ticketing industry further ramps up the pressure on what is a politically charged area among politicians, sports fans, and music lovers. This heightened scrutiny has continued to intensify since the CMA launched a probe into Ticketmaster’s use of dynamic pricing in the sale of Oasis concert tickets. Alongside the newly opened CMA investigations into StubHub and viagogo, on November 19, 2025, the UK government announced plans for new legislation banning the resale of tickets for profit.

Looking Ahead

The initial enforcement actions address certain drip pricing practices which have long been prohibited under consumer law. The DMCCA’s new prohibitions and recent CMA guidance on issues such as fake reviews and price transparency lay the groundwork for future investigations into newer areas of concern like “partitioned pricing,” where prices are presented as separate components without an overall total. Looking ahead, enforcement is likely to intensify in sectors of high household expenditure, as indicated by the range of sectors covered in the CMA’s advisory letters.

In line with the CMA’s phased approach to the new regime, 2026 will see stricter rules on subscription contracts regarding renewals, simpler cancellation processes, and new cooling-off rights for consumers. With the CMA sending a clear message it will make use of its new powers to protect the interests of consumers, businesses operating in the UK should review their online sales practices to ensure compliance with current consumer laws as well as a smoother transition when the new subscription rules take effect next year.

For more information, please contact Deirdre Carroll, Tom Evans, Andrew Morrison, or any member of the firm’s Antitrust and Competition or Data, Privacy, and Cybersecurity practices.