The UK’s Digital Markets, Competition and Consumers Act 2024 (DMCCA) marks a significant overhaul of UK consumer protection law. The headline change is that the stakes for non-compliance with UK consumer protection law have been significantly raised: businesses may now face fines of up to £300,000 or 10% of global turnover for breaches, whichever is higher.

The DMCCA also introduces new consumer protection rules for businesses to comply with. Two of its most impactful provisions are the explicit prohibition of “drip pricing” and a new regime for subscription contracts. The drip pricing measures have been in force from April 6 2025 – the new rules on subscription contracts will come into force no earlier than spring 2026.

The new rules will impact any UK business selling goods or services to consumers online. As above, non-compliance can lead to potentially significant fines. Given this jeopardy, businesses should expect clear guidance on how to comply. However, we see that they are currently dealing with significant uncertainty.

Drip Pricing

Drip pricing refers to when a consumer is shown an initial price for a product, and additional mandatory fees – such as booking charges and service fees – are introduced throughout the sales process.

Before the DMCCA, drip pricing practices were potentially unlawful, but are now explicitly banned. The rules require businesses to be completely transparent upfront about the final price that a consumer will have to pay if they purchase a product. Optional extras can still be offered, and do not have to be included in the price that is communicated, but they must be clearly distinguishable and not pre-selected.

Fees that cannot reasonably be calculated at the start are exempt from this rule. However, businesses must still provide clear information about how this price will be calculated, and it must be displayed as prominently as the headline price.

On their face, these rules appear relatively straightforward, and indeed compliance may be straightforward for many businesses. However, businesses that have complex pricing structures – for example charge based on volume usage or offer a wide range of options – utilise dynamic pricing or offer rolling subscription contracts may be particularly affected.

Businesses have also been grappling with the interpretation of what constitutes an “unavoidable” fee versus an optional one, especially where they offer different subscription levels or bundled services.

The CMA did produce guidance on drip pricing in April 2025. However, this guidance is high level and thin on illustrating acceptable practices and may be of little practical use for more complex pricing structures. In light of this the CMA has consulted on new, more detailed guidance which may result in final updated guidance being issued shortly. Based on the text of the updated draft guidance issued it may go some way to clear some of the issues – in particular it in respect of rolling subscription contracts.

It should be noted however that it is inevitable that it will not cover every issue, there may be a significant compliance burden on businesses that operate complex pricing models. Businesses might easily inadvertently find themselves on the wrong side of the law if they do not actively plan and monitor how prices are being presented to consumers.

Subscription Contracts

A subscription contract is a contract that either auto-renews (whether for an indefinite or fixed period); or if there is a free trial/reduced price after which the contract renews onto a higher payment.

The DMCCA seeks to protect consumers where subscriptions may be onerous to exit, requiring higher levels of transparency. The new requirements

• enhance pre-contractual information requirements;
• require regular renewal notices linked to the customer’s renewal payment dates and the length of the subscription period; and
• provide for 14 day cooling-off periods at the start of the contract and on renewals.

To date the entry into force of the rules remains unclear, although no earlier than spring 2026. Implementation will rely on further regulations so important details on the content of the rules are also still outstanding. Of particular relevance for businesses supplying digital content is whether they will be able to obtain consent from consumers to waive their cooling-off rights to avoid situations where a consumer ‘binges and cancels’ and then receives a full or partial refund.

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It is hoped that businesses are given sufficient time to adapt between the further regulations being made and the subscription contract provisions coming into force.

What businesses need to do now

• Education – educate staff and establish internal compliance mechanisms with the caveat that current guidance on drip-pricing may be unhelpful and many businesses may require changes to be made to consumer journeys once new guidance is finalised;
• Proactive Monitoring – monitor regulator (i.e. CMA) guidance for clarity on achieving compliance; and
• Audit pricing and subscription models – review existing pricing models and marketing materials including websites and existing subscription offerings, and revise terms to meet new requirements.