Whether you sell glasses, contact lenses or related optical products and services, these changes affect your practice directly. As providers of essential services, opticians are likely to be a high-risk sector for regulatory scrutiny. This note explains the key issues every optical practice needs to have at the top of its to-do list.
What has been happening?
The Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) came into force in April 2025, bringing in a range of new obligations for businesses, covering pricing practices, fake reviews and unfair commercial practices. There are also new rules on subscription contracts set to come into force in Spring 2027, which will be particularly relevant to opticians offering contact lens plans and other subscription-based services.
What’s the risk?
The DMCCA gives the UK’s Competition and Markets Authority (“CMA”) new enforcement powers, including the power to fine businesses in breach of the law up to 10% of global annual turnover without going to court. In fact, it has already exercised this power, fining one business £4.2 million (reduced from £7 million as they settled) for non-compliance with the price transparency rules. It also has the power to fine businesses that fail to cooperate – and has fined one business £473,000 for failing to provide information requested by the CMA.
Our message to businesses is simple – get your house in order or deal with the consequences.
Hayley Fletcher, Competition and Markets Authority
What are the CMA’s enforcement priorities?
Price transparency when selling prescription eyewear
The new rules restrict so-called “drip pricing”. This is where consumers are shown an initial headline price for a product but, as they proceed through the purchase journey, additional non-optional charges are added (or “dripped” in), so that the price ultimately paid by the consumer is higher than originally presented to them. For opticians, this is particularly relevant when selling packages consisting of frames, lenses and additional services such as coatings, fittings or aftercare. Under the new rules, the “total” price shown upfront must include the minimum cost of each mandatory element of the package. If any component is unavoidable, its cost must be built into a “total price”, which must be presented from the outset. In many cases, this will require changes to the way prices are presented on websites, in-store displays and promotional materials.
Contact lens plans and subscription contracts
New rules on subscription contracts are set to land in Spring 2027. These will be directly relevant to contact lens plans which consumers buy on a rolling basis. Opticians will be required to provide detailed pre-contract information about the plan when consumers sign up (whether that’s online or in-store), to send reminder notices at key stages in the plan lifecycle and to provide additional cooling-off (cancellation) rights. For plans entered into online, opticians must also provide an easy way to cancel online, without unnecessary barriers like needing to call customer services separately. These new rules mark a significant change from existing laws and will require opticians to draw up new pre-contract information, review and update their sign-up processes, consumer notices and contractual terms for contact lens plans.
Consumer reviews
The DMCCA bans the commissioning and publication of fake and misleading consumer reviews, including reviews that conceal the fact they have been incentivised. If your website features consumer reviews – whether for products, services or the practice itself – you will need to ensure you have a clear consumer-facing reviews policy on your website that complies with the new rules. You must also carry out risk assessments and put in place processes and procedures to adequately monitor, investigate and sanction any rogue reviews, including removing banned content. The CMA is actively spot-checking websites to identify obvious breaches, and not having a policy is one telltale sign that a business is not compliant with the rules, exposing a practice to a potential investigation and a large fine.
Unfair contract terms
Although the law on unfair terms has not changed, the CMA has produced new draft guidance and has highlighted that clearly imbalanced and unfair contract terms, such as unfair exit charges, are a priority area for the next 12 months. True to its word, the CMA has now opened investigations into two well-known consumer brands for their potentially unfair contract terms. Given this new area of focus, it’s important that consumer terms are reviewed with the latest guidance in mind.
What should you do now?
Given the heightened regulatory scrutiny, it is vital for opticians to review their practices to ensure they are compliant with the new laws and guidance – particularly around the pricing of packages involving frames, lenses and additional services, and any consumer reviews featured on your website. And with the changes affecting subscription contracts – including contact lens plans – now only months away, there is no time like the present to review your sign-up processes and consumer communications to identify where changes are needed and to plan in the required changes. One of the key challenges for businesses trying to update their practices and procedures is that their technology isn’t built to accommodate the new requirements, so early planning is essential to ensure you have sufficient development time.
How can we help?
We are already advising businesses how best to adapt their websites, in-store practices and consumer communications to address the new rules. We provide pragmatic strategic advice on compliance, helping practices to mitigate risk whilst maintaining their competitive edge. If you would like to find out how we can help your optical practice get to grips with all the changes, please get in touch with Jen and Alex below.
