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Eliga Consultancy Services Limited
The CMA has activated direct consumer enforcement under the DMCCA. Eight companies under investigation. 100 advisory letters issued. Drip pricing, fake urgency tactics, and pre-selected charges are now in the enforcement crosshairs. Your pricing architecture is a legal risk.
CMA Opens First Direct Enforcement Actions Under DMCCA: Pricing Architecture Now a Board-Level Risk
The CMA has opened its first consumer enforcement investigations under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), targeting eight companies across secondary ticketing, driving schools, gyms, and homeware retail for suspected use of hidden fees, misleading time-limited offers, and automatic opt-ins for optional charges. Simultaneously, the CMA has issued over 100 advisory letters to businesses across 19 sectors, including food delivery, fashion, event ticketing and travel, following a cross-economy review that identified concerns in 14 of those sectors.
This is not phased education followed by later enforcement. The CMA has moved directly to investigation and advisory letters in parallel. The CMA has confirmed it will impose administrative fines of up to 10% of global annual turnover without requiring court proceedings. The CMA’s stated position is unambiguous: “This is just the start of our work.” Any business selling to UK consumers online, regardless of sector or size, is now within enforcement scope.
Businesses must urgently audit their commercial terms, checkout flows, subscription structures, and promotional mechanics. SaaS and subscription businesses are directly exposed: auto-renewals, pre-selected upsell tiers, drip-priced add-ons, and cancellation friction are all enforcement targets.
Terms of service, pricing pages, and order confirmation flows are now contract risk surfaces, not merely UX decisions. Customer-facing contracts must be reviewed for compliance with the CMA’s final Price Transparency Guidance (published November 2025). Supplier-side procurement teams should require contractual warranties from platform and marketplace vendors confirming DMCCA compliance. In B2B contexts, indemnity clauses should be reviewed where pricing practices of a SaaS vendor could expose the customer to downstream regulatory or reputational risk.