A lot has happened since our spring update. The CMA has shown it is eager to flex its new direct enforcement powers under the DMCC Act 2024, and the pace is only accelerating. Two developments stand out: the subscription contracts regime has been brought forward to January 2027, giving businesses very limited time to prepare; and the High Court has handed down its long-awaited judgment in the Emma Sleep case, rejecting the CMA's proposed blanket volume ratio for discount claims.
The CMA has now opened 19 investigations since November 2025, issued its first fine of £4.2 million for drip pricing, and ordered substantial consumer redress alongside headline penalties. With maximum fines of up to 10% of annual global turnover, consumer law compliance remains firmly a board-level issue.
In this edition, we cover:
- The subscription contracts regime: what the new rules require and what businesses should be doing now to prepare before January 2027.
- Price transparency: the CMA's enforcement activity on drip pricing and misleading discounts, and a deep dive into the Emma Sleep judgment and what it means for retailers.
- Fake reviews, unfair terms and green claims: continued regulatory scrutiny, with new CMA investigations and updated guidance across each of these areas.
We have also updated our trackers of key consumer law developments and CMA cases, so you can see at a glance the full timeline of recent activity.
