The Competition and Markets Authority (“CMA”) has wasted no time in using its enhanced enforcement powers – including the ability to impose multi-million-pound fines directly, without first going to court. For dental practices, the implications are significant. The DMCCA governs how practices communicate their pricing, manage patient reviews online and – once new subscription contract rules land in Spring 2027 – how they administer dental membership or care plans. Dental practices would be wise to act early. With the CMA already showing an interest in the sector, having launched a market study into private dentistry in March 2026, the sector’s mix of ongoing care plans, variable pricing structures and digital patient engagement makes it a natural focus for consumer regulatory scrutiny.

Four key areas where dental practices should focus their compliance efforts

1. Getting pricing right from the start

One of the headline changes introduced by the DMCCA is a crackdown on “drip pricing” – where an initial headline price is advertised but additional compulsory charges are revealed only as the consumer moves through the booking or treatment process. Dental practices are particularly exposed here. A treatment quote that omits unavoidable costs such as the initial examination fee, diagnostic X-rays, laboratory or materials fees, or sedation or anaesthetic costs risks breaching the DMCCA’s new pricing rules.

The principle is clear: any price presented to a patient must reflect the full minimum cost of every compulsory element from the outset. Practices should audit how fees are presented across their websites, in reception areas, on treatment plan documents and in any marketing or promotional materials.

2. Dental membership plans and the subscription rules

It is increasingly common for dental practices to offer membership or care plans – typically providing routine check-ups, hygienist appointments and a discount on further treatment for a fixed monthly fee. These rolling subscription arrangements will fall squarely within the scope of the new subscription contract rules when they come into force in Spring 2027.

The new subscription contracts regime will ensure people have the information they need to manage their money and have clear rights so they can easily exit contracts they do not want.

Government response to consultation on the implementation of the new subscriptions contract regime, April 2026

Under the new regime, dental practices will be required to provide comprehensive pre-contract information at the point a patient signs up to a subscription product such as a care plan, whether that is done online or in person at the practice. Prescribed reminder notices must be issued at key points during the plan’s term, and patients will benefit from strengthened cooling-off and cancellation rights. For plans taken out online, an equally straightforward online cancellation mechanism must be available on the website – it will no longer be sufficient to require patients to telephone or visit the practice to cancel.

The practical impact of the changes should not be underestimated. Enrolment processes, ongoing patient communications and the contractual documentation underpinning dental membership and care plans will all need to be reviewed and, in many cases, substantially revised. Where system or software changes are needed to facilitate online cancellation or automated reminder notices, the lead time can be considerable – so early preparation is strongly recommended.

3. Online reviews and reputation management

Patient reviews play a central role in how dental practices attract new patients, whether on the practice’s own website, Google, or specialist healthcare review platforms. The DMCCA introduces a prohibition on commissioning or publishing fake or misleading reviews and extends this to any reviews where an incentive (such as a discount on future treatment) has been offered without that fact being disclosed.

Practices that feature patient testimonials or reviews on their website, or that actively encourage reviews on third-party platforms, should ensure they have a robust, publicly available reviews policy. The CMA expects businesses to conduct risk assessments, implement monitoring procedures and take steps to identify and remove non-compliant content. Given that the CMA is already carrying out spot checks across consumer-facing websites, the absence of a compliant reviews policy could itself invite regulatory attention.

4. Ensuring fairness in patient-facing terms

Unfair contract terms – and in particular excessive cancellation or exit charges – have been identified by the CMA as a priority enforcement target. The regulator has already launched investigations into prominent consumer brands on precisely this basis, and healthcare providers are not immune.
For dental practices, this means that all patient-facing contractual documentation warrants careful review against the CMA’s latest guidance. Dental plan agreements and patient consent forms are the most obvious starting point, but practices should also scrutinise any standard terms and conditions – including those governing private treatment, payment plans or missed appointment charges – for provisions that could be considered unfair or one-sided.

Next steps for your practice – and how we can help you

The consumer regulatory landscape has fundamentally changed, and dental practices that delay compliance risk significant financial penalties and reputational damage. Now is the time to audit fee presentations, review patient-facing communications, begin preparing for the new subscription contract rules and assess whether your standard terms are fair and defensible.

We have extensive experience advising consumer-facing businesses on these changes – whether that involves updating websites and patient materials, redesigning membership plan documentation or ensuring contractual terms meet the CMA’s expectations. For practical, tailored advice on preparing your dental practice, please contact Jen and Alex below.