This follows the UK’s consumer protection framework undergoing a landmark transformation with the introduction of the Digital Markets, Competition and Consumers Act 2024; a new legal regime set to replace the Consumer Protection from Unfair Trading Regulations 2008.
The Act, which was introduced last month, consists of sweeping changes aimed at curbing unfair commercial practices and strengthening consumer rights - most notably in the areas of fake reviews and drip pricing.
The new rules bring much-needed clarity and rigour to the digital marketplace, explicitly targeting practices that mislead or disadvantage consumers. Among the 32 unfair commercial practices specifically outlined in the Act, key provisions include prohibitions on fake or misleading consumer reviews, and on pricing tactics that hide true costs until late in the purchase process.
“These changes mark a watershed moment for consumer protection,” said James Sarjantson, Commercial and Digital Partner at LCF Law. “The Act sets clear expectations for all businesses - large or small - and failing to comply could have serious consequences with businesses that fall short of the new standards facing fines of up to £300,000 or 10% of global turnover, whichever is higher.”
The Competition & Market Authority’s guidance on fake reviews provides detailed expectations for businesses. Where companies make reviews available on their own websites or platforms, they are required to publish transparent policies on fake and incentivised reviews; conduct regular risk assessments; and take proactive and proportionate steps to detect, prevent and respond to fake or misleading reviews.
James added: “For pricing, the Act targets ‘drip pricing’ in particular by mandating clear, upfront disclosure of all mandatory fees, taxes and charges. For example, event ticket prices must include booking fees, and gym memberships must show the total cost over the contract period, not just a monthly rate”.
“Even small businesses must demonstrate a good-faith effort to meet these expectations. Clear review policies, visible total pricing, and proper consumer disclosures are now legal obligations, not best practices. Businesses must act swiftly to align their policies and procedures with the new regulatory framework and seek professional advice to avoid costly mistakes.”
For detailed guidance or legal advice, contact James Sarjantson or Thomas Taylor on 01423 502211 or visit www.lcf.co.uk