Digital Markets, Competition and Consumers Act 2024 (DMCCA): What the UK’s new consumer rules now mean for consumer facing businesses

The UK’s Digital Markets, Competition and Consumers Act 2024 (DMCCA) is reshaping how consumer‑facing businesses price, sell and renew. While much of the regime is staged, one change is already live and highly relevant to the consumer sector across retail, e‑commerce, platforms and services. This brief update highlights the latest on subscriptions and drip pricing, with practical implications for businesses that sell directly to consumers or support consumer‑facing partners who may seek to flow obligations up the chain.

Subscriptions: commencement deferred to at least Autumn 2026

The DMCCA’s subscription contracts regime—covering enhanced pre‑contract information, cooling‑off rights, cancellation processes and periodic renewal reminders—has been pushed back. Initially expected in Spring 2026, ministers have indicated it will not take effect until Autumn 2026 at the earliest. The delay reflects the need for secondary legislation and detailed guidance to be finalised, including on notice content, refunds and operational mechanics. For now, consumer subscription practices remain governed by existing law, but product and engineering teams should budget sufficient lead time to build compliant journeys once the implementing rules are settled.

Drip pricing: in force from 6 April 2025

By contrast, the DMCCA’s drip‑pricing prohibitions are already in force. In essence, drip pricing is the practice of revealing unavoidable charges after the initial price is displayed. Under the new rules, fixed mandatory charges excluded from the headline price are unenforceable and expose firms to investigation, reimbursement claims and, in serious cases, fines.

The core principle is simple: whenever you make an “invitation to purchase”, you must present the total, all‑in price upfront. All fixed, mandatory charges must be included in the first price shown. Where a mandatory element cannot reasonably be calculated in advance, you must clearly and prominently disclose the basis of calculation at the outset so the consumer can estimate the total. Optional extras need not be included in the headline, but must be genuinely optional and not pre‑selected.

What the rules require in practice

For consumer‑facing journeys, advertising and search results must align with checkout so the first visible price matches (or exceeds) what the consumer will actually pay. Booking, service, platform and compulsory delivery or admin fees—together with any taxes and charges that form part of the trader’s price—belong in the headline figure. If a mandatory component varies and cannot reasonably be calculated in advance, the basis, factors and calculation method must be presented prominently from the outset, with a clear estimate surfaced before any commitment.

The Competition and Markets Authority (CMA) has issued guidance signalling a phased approach on some nuanced scenarios (for example, certain periodic fixed‑term charges), with more to come. However, practices squarely addressed—like adding unavoidable fees late in the journey—are already in scope for investigation and enforcement.

Enforcement risk and penalties

The DMCCA equips the CMA with direct enforcement powers and the ability to impose significant monetary penalties of up to the higher of £300,000 or 10% of worldwide turnover, alongside cessation orders. The regulator has been explicit that drip pricing is a priority and has highlighted recurring issues: late‑added “service”, “platform”, “booking” or “handling” charges; per‑unit prices that omit compulsory per‑order fees; pre‑ticked optional add‑ons; weak or buried disclosures for variable mandatory elements; and price mismatches between ads, search results and checkout.

Applying the rules across consumer sectors

For online retail and marketplaces, headline prices should include any fixed, unavoidable platform, service or handling fees. Optional extras—such as gift‑wrapping or expedited delivery—can sit outside the headline price if genuinely optional and not pre‑selected. Taxes and charges that are known (e.g., VAT) must be included. If a mandatory delivery charge varies (for example by postcode or weight) and cannot reasonably be calculated on first display, disclose the basis prominently and provide a clear estimate as soon as the basket contents and address are known—well before commitment.

For digital services and apps, base prices must include compulsory activation or set‑up fees. Optional add‑ons—like premium features or cloud storage—may be excluded from the headline figure if they are genuinely optional; any mandatory security, compliance or payment processing charge must be included upfront.

For utilities and telecoms, the first quoted price should reflect unavoidable connection, installation or network fees. If a mandatory usage‑based element cannot be calculated at the outset, explain the pricing basis clearly and provide a realistic estimate before sign‑up.

For events and ticketing, per‑ticket prices should not exclude compulsory per‑order fees; the first visible price must reflect what the consumer will pay for their intended quantity.

Bottom line: act now across the consumer sector

The drip‑pricing rules are live and enforceable now. Consumer sector businesses—and their upstream partners—should map every fee, classify mandatory versus optional, and ensure the first price a consumer sees is the price they must pay. With subscriptions coming next, this is the moment to align commercial models, product design and legal sign‑off to the DMCCA’s “total price upfront” standard.