Consumer protection

Insights for In-house Counsel | Spring 2025

Consumer protection

UK's tough new consumer protection regime is now live

Most of the consumer law provisions of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025. These changes give the UK one of the toughest enforcement regimes in the world, with the prospect of fines of up to 10% of global turnover on B2C businesses for infringing UK consumer law.

We expect the UK Competition and Markets Authority (CMA) to take prompt action to show that it is making an impact on behalf of consumers (having been strongly encouraged to do so by the Government's draft "strategic steer" to the CMA). The legislation also introduces new rules on fake reviews, "drip pricing" and (from next year) subscription contracts. For more detail, see our briefings:

If you would like to discuss the implications for your business, please get in touch with any of the contacts below.

B2C online terms: another million-pound mistake

Paddy Power's consumer terms and conditions recently failed to protect it against having to pay out over £1 million, after an online game mistakenly indicated that a player had won a "Monster Jackpot". Our briefing discusses what lessons can be drawn from this dispute and two previous cases involving similar claims for million-pound wins. We also look at the wider implications for B2C contracts, beyond the sphere of online games.

B2C contracts: what's a fair outcome if services can't go ahead as planned?

Many B2C businesses face the possibility that services they have agreed to provide may not go ahead as planned – but is it fair for the business to retain or demand any payments where this has happened? The Court of Appeal has recently ruled that a term in a contract for legal services was unfair, because it required the consumer to pay the full projected fees, even where the relevant hearing was delayed. Our briefing explains why the Court reached this conclusion and looks at the wider lessons for providers of consumer-facing services.

For further information, please contact

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