The Digital Markets, Competition and Consumers Act 2024: What Changed for Online Sellers

If you sell to consumers in the UK, one law has changed the ground under your feet since April 2025. The Digital Markets, Competition and Consumers Act 2024, usually shortened to the DMCC Act, did not invent consumer protection. It rewrote the rules on unfair trading, added two headline bans that matter a great deal to online sellers (fake reviews and "drip pricing"), and gave the Competition and Markets Authority (CMA) the power to decide breaches and issue fines itself, without going to court first.

This guide goes through what the Act says, using the Act on legislation.gov.uk and the CMA's own guidance on GOV.UK, all read in October 2026. It covers who counts as a "trader", the 32 practices banned outright, what the review and pricing rules require in practice, how enforcement works and what it has produced so far, and an audit you can run on your own eBay listings. It leaves out the Act's competition and digital-markets sections, which are aimed at very large firms.

1. What the Act is and when each part started

The Act is large. It has parts on digital markets regulation for the biggest technology firms, competition and mergers, and consumer protection. Its contents page on legislation.gov.uk shows Part 3 (enforcement of consumer protection law), Part 4 Chapter 1 (protection from unfair trading), Chapter 2 (subscription contracts) and Chapter 3 (consumer savings schemes). The consumer parts are what concern a seller.

The sections we opened on legislation.gov.uk, including the CMA's penalty power in section 182, carry the note "in force at 6.4.2025 by S.I. 2025/272". The CMA's guidance on unfair commercial practices says the new rules apply to practices from 6 April 2025 onwards, and the CMA's press release of 7 April 2025 described the provisions as now in force, with the CMA able to decide whether consumer law has been infringed rather than litigating through the courts.

The subscription contracts rules in Chapter 2 were not part of that start. The CMA's blog of 14 October 2026 says a new subscription contracts regime will come into force in January, with secondary legislation and guidance to follow first. It does not give the year, so check GOV.UK before relying on a date. This only matters if you sell something that renews automatically.

Worth remembering: the rules apply to practices from 6 April 2025, and a listing that stays live is a practice that continues. Do not assume an old listing is exempt because you wrote it before the change.

2. Are you a "trader"? Almost certainly, if you sell for profit

The rules apply to "traders" dealing with "consumers". The CMA's guidance defines a trader as a person acting for purposes relating to their business, or acting in the name of or on behalf of someone else's business, and "business" includes a trade, craft or profession whether or not carried on for gain.

It then gives examples that fit online selling directly. The definition can capture "individuals who regularly sell goods from their homes through online marketplaces". Someone who purchases items in order to resell them would be likely to fall within it, while an individual selling unwanted goods from time to time would not be likely to. It is assessed case by case, looking at things like whether the activity is for profit, the number and frequency of transactions, and the time between buying and selling. That describes a dropshipper, who buys from a supplier to fulfill each sale. Our guide to business versus private selling on eBay covers the platform side, but the legal test is separate from your eBay account type.

A consumer is an individual acting for purposes wholly or mainly outside their business. For practices aimed only at businesses the guidance points to a different regime, the Business Protection from Misleading Marketing Regulations 2008. If your buyers are a mix, assume the consumer rules apply to the whole listing.

Two further points from the guidance. First, platforms are covered too: where a trader lists a product on a marketplace and the invitation to purchase does not comply, both the marketplace operator and the selling trader may be held responsible. Second, being abroad is no shield: an invitation to purchase directed at UK consumers must comply even if the trader is outside the UK, and a footnote explains the CMA may enforce against a trader outside the UK who carries on business in the UK or directs activities to UK consumers.

3. What actually changed, and what did not

The guidance says the Act's unfair-trading provisions replace and update the 2008 regulations, with some changes, and that traders can generally expect the same or similar requirements and prohibitions. If you already tell the truth in your listings, most of your habits remain compliant. The changes that matter are:

• Fake reviews are a named banned practice (paragraph 13 of Schedule 20), with duties on those who publish reviews.
• Drip pricing is prohibited through the rules on what an "invitation to purchase" must contain, backed by CMA price transparency guidance (CMA209).
• The CMA can enforce directly. Under section 182 it can give a final infringement notice requiring directions and a monetary penalty, with no court order first.
• Penalties can be expressed as a share of turnover.
• Numbering moved. The guidance notes the list of banned practices was rearranged from the old Schedule 1, so references to a numbered banned practice in older articles may point at a different practice now.

One more detail: the guidance says consumers currently keep the private rights of redress in the old regulations until a new statutory instrument replaces them.

4. The 32 banned practices: the ones a seller can trip over

Schedule 20 lists 32 practices that are unfair in all circumstances. The guidance stresses that there is no need to consider the likely effect on consumers: if the practice is on the list, it is unlawful. Many concern doorstep selling, prize draws and pyramid schemes. The table picks out those an online seller is most likely to meet. The numbers follow the guidance and the wording is paraphrased, so read the guidance for the exact text.

Practices 25, 7 and 11 in more detail

For practice 25 the CMA's example is a car dealership leaving a car by the road with a handwritten sign giving the impression the seller is not a trader. If you run a business, do not write listing copy that implies you are a household clearing a spare room.

For practice 7 the guidance gives a countdown clock that tells the consumer an offer will end, then continues and restarts. It adds that if the statement that the offer will end is true and not otherwise misleading, it is unlikely to be a problem. Only claim an end date if the offer really ends.

Practice 11 catches shops by accident. The CMA's example is "if you aren't happy with your purchase, you can return it within 14 days and we'll refund you, no questions asked, you won't find this offer elsewhere". Under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 the consumer ordinarily has 14 days anyway. You can state your returns terms, but not sell the statutory right as a favor. Our guide to returns and refunds for dropshippers covers the practical side.

For a dropshipper, practices 5, 6 and 20 are the sharp end. The guidance says "reasonable" is judged by the nature of the product, the extent of advertising and the price offered. Keeping stock and price in sync with your supplier is not just good practice but a legal protection.

5. Fake reviews: the rule in detail

Paragraph 13 of Schedule 20 is the longest of the 32. The CMA published a dedicated guidance document, "Fake reviews" (CMA208), on 4 April 2025, plus a short guide for businesses that publish reviews. In plain terms, paragraph 13 bans:

1. submitting, or commissioning another person to submit or write, a fake consumer review or a review that conceals the fact it was incentivised;
2. publishing consumer reviews or review information in a misleading way;
3. publishing reviews without reasonable and proportionate steps to prevent and remove fake or concealed-incentive reviews and false or misleading review information; and
4. offering services to traders to do any of the first two.

What counts as a review

The guidance says reviews can be text, speech or graphic representations, such as a star rating or a thumbs-up on a "helpful" review. A consumer review is a review of a product, a trader or any other matter relevant to a transactional decision, and it does not need to be written by a consumer. Likely topics include how quickly the item was delivered, its quality and after-sales care. "Consumer review information" covers aggregated ratings, summaries, counts and rankings. Whether any particular platform's feedback system falls inside this definition is for the CMA and the courts; the safe approach is to treat anything buyers read to judge you as something that must reflect real experience.

A fake review is one that purports to be, but is not, based on a person's genuine experience, and it can be positive or negative. A review is not fake just because the trader dislikes it, if it reflects the reviewer's genuine experience.

Incentives: allowed if disclosed and honest

The guidance says it is not prohibited per se to publish an incentivised review, although many platforms do not allow them. Where permitted, the review must be clearly identifiable as incentivised. A trader who incentivises reviews, by paying, offering future discounts or free products, must tell consumers the review was incentivised, and the review must still reflect the reviewer's genuine experience. Commissioning is not limited to money: the guidance lists discounts, vouchers, free products and more, and the CMA's October 2026 blog notes unlawful conduct could include asking staff to write reviews. A footnote says entering reviewers into a prize draw is unlikely to be commissioning.

Its examples of commissioning banned reviews include offering a customer a free or discounted product for a five-star review that does not reflect their experience, sharing a social post asking for five-star reviews in exchange for free products, and contacting a customer who left a negative review to offer a refund or gift card if they change it. Paragraph 3.6 says encouraging genuine reviews without predetermining their content, "for example by merely emailing customers generally to ask if they wish to provide a review", is not prohibited.

Suppressing and cherry-picking

A trader may infringe if they suppress genuine negative or positive reviews or selectively promote reviews. The guidance says traders should not interfere with reviewers' willingness to leave negative reviews, for example through threats of harm or legal action, by arbitrarily stopping and starting review invitations, or by making dispute resolution contingent on a consumer not leaving a negative review. It describes cherry-picking as including encouraging only satisfied customers to review.

It also treats "catalog abuse" as misleading: showing reviews of a different product as relating to the one a consumer is considering, such as merging reviews of materially different products to boost a rating. Merged reviews are more likely to comply where the consumer's experience is materially the same, and the guidance gives different sizes made to different quality standards as a counter-example. It also covers outdated genuine reviews: if a product changes materially, older reviews that remain visible could mislead. That is worth remembering if you change the supplier behind a long-running listing.

What eBay says

Separately from the law, eBay's feedback manipulation policy says feedback manipulation, meaning any attempt to artificially increase your feedback score or lower another member's, is not allowed, and its list of examples includes offering discounts, free items or any other compensation, benefit or incentive in exchange for positive feedback. The action it says eBay may take includes removing the listing or other content, issuing a warning, restricting activity or suspending the account. The platform rule is stricter than the law on incentives, so never trade a benefit for feedback. See how eBay feedback actually works and what happens after a bad review.

If you republish buyer comments on your own site or social pages, you become a publisher. The CMA's short guide expects a published policy that prohibits fake reviews and states your approach to incentivised reviews, a regularly repeated risk assessment, and processes to detect, investigate and act on banned content, scaled to what is reasonable for your circumstances.

6. Drip pricing and the total price

The CMA's price transparency summary says it is illegal to hide additional fees, taxes or other charges that the customer will have to pay until later in the purchase process, and that traders must provide total prices up front. It adds that if you break the law you could be fined up to 10% of your turnover or £300,000, whichever is greater, and ordered to compensate affected customers.

What must be in the price

When you tell a customer about a product and its price, that is normally an "invitation to purchase". The guidance lists an item listing on an online store or marketplace as an example, and says it need not include an opportunity to buy. The total price must be given clearly and in a timely way, where the customer is likely to see it, and should normally include any mandatory charge: a fee such as delivery, a tax such as VAT, or any other unavoidable payment. Providing them separately will not normally be enough.

Section 230(2) of the Act adds other material information that must appear unless apparent from context:

• the main characteristics of the product, corresponding to the price shown (a basic-model price needs a basic-model description);
• the total price, or how it will be calculated if it cannot reasonably be worked out in advance;
• optional delivery or postal charges not in the total price;
• the trader's identity and business address, plus any business email address the trader has;
• any right of withdrawal or cancellation; and
• any payment, delivery or complaint-handling arrangements that differ from your published practice.

The guidance says omitting this information is unfair regardless of whether it is likely to affect any decision, which is stricter than the ordinary misleading omissions test.

Delivery charges

Postage is where listings most often change the price late. The summary guidance says mandatory delivery charges must be in the invitation to purchase, and if you can reasonably calculate them they go in the total price too. Optional charges, such as next-day delivery, must be shown but can be separate. If the customer must choose between delivery charges, include the cheapest option until they choose another. Where a mandatory charge varies and you cannot know it in advance, give enough information to work out the total with the same prominence as the headline price.

Worked example (illustrative): an item is £24.99 and the only postage option is £4.95. The total to receive the product is £24.99 + £4.95 = £29.94. If the £4.95 is unavoidable, a £24.99 headline with postage appearing only at the end is the pattern the guidance targets. If instead the buyer can pick £4.95 standard or £3.50 economy, the cheapest option goes in until they choose: £24.99 + £3.50 = £28.49.

What you control on a marketplace is your item price, your postage options and any wording you add. Do not add surcharges the buyer meets only in the description, a message or after payment, and if you charge more for certain ZIP codes, set that up as a postage rate. Our guide on why free postage is never actually free covers the margin side. The guidance also says to include mandatory taxes, so a VAT-registered seller's consumer prices must include VAT; see VAT for UK dropshippers.

7. Misleading listings: claims, delivery times and origin

Beyond the banned list, the Act prohibits misleading actions and omissions that are likely to make the average consumer take a different decision. The guidance lists four kinds of misleading action (false or misleading information, deceptive overall presentation, confusion with a competitor's products or marks, and breaking a code of conduct you claim to follow) and three misleading omissions (leaving out material information, legally required information, or the commercial intent).

Its list of information that may influence a decision reads like a listing checklist: availability, quantity and specification; fitness for purpose; composition or accessories; origin; delivery; after-sale assistance and complaint handling; the extent of the trader's commitments; price and any price advantage; and the consumer's rights. It says factual claims should be supported by evidence, and that true information presented misleadingly can still mislead. One example is a pop-up saying "Be quick! We've sold 10 in the last 5 mins" where the claim is literally true but stock is high and there is no need to hurry.

For dropshippers, three weak spots follow from that list. Delivery claims: set handling and delivery figures to what your supplier actually achieves (see handling time). Specification and origin: check the supplier's description against the product before copying it. Accessories: supplier photos that show items not included mismatch the "composition or accessories" entry. The test is not whether any real buyer complained, as the guidance says there is no requirement to show actual consumers were affected.

8. How enforcement works now

Before April 2025 a finding that a trader had broken consumer law normally needed a court. Now the CMA can run the process itself.

Under section 182, after the CMA has given a provisional infringement notice and the respondent has had time to make representations, the CMA may give a final infringement notice if satisfied the respondent has engaged, is engaging or is likely to engage in a relevant infringement. The notice can require directions (including enhanced consumer measures such as redress) and a monetary penalty, must state the grounds and the right of appeal, and can require the respondent to publish the notice or a corrective statement.

The penalty limit in section 182(6) is a fixed amount not exceeding £300,000 or, if higher, 10% of the total value of the respondent's turnover. A separate limit for breaching an undertaking, in section 190, is £150,000 or, if higher, 5% of turnover, or a daily rate of £15,000 or, if higher, 5% of daily turnover.

These turnovers are made up to show the arithmetic. For a small shop the £300,000 figure is the cap, not 10% of turnover. It is a ceiling, not a typical outcome, and the CMA says its early action focuses on clear and egregious cases.

Criminal liability remains. The guidance says engaging in a Schedule 20 banned practice, omitting material information from an invitation to purchase, and most misleading and aggressive practices are offenses, strict liability apart from the professional diligence offense, so intent need not be proved. Defences of due diligence and innocent publication exist under section 238, and the person relying on them must prove them. Officers of a company can be prosecuted where an offense involves their consent or connivance or neglect. Under section 240, conviction on indictment can bring up to two years' imprisonment or a fine or both. A footnote says most banned practices are criminal offenses except those in paragraphs 12, 13 and 30 of Schedule 20, so the reviews rule is enforced through the civil and CMA route. No prosecution may start more than three years after the offense or one year after the prosecutor discovered it, whichever is earlier. For the wider enforcement picture, see what Trading Standards actually does.

9. What has happened since April 2025

• The CMA's April 2025 press release said early action would focus on aggressive sales practices, hidden fees, objectively false information, unfair terms, and areas where it had already set a marker, such as drip pricing and fake reviews.
• Its one-year blog (17 April 2026) says that from April 2025 to April 2026 it opened investigations into 14 businesses and settled with 2, ordered £760,000 to be refunded, imposed fines totalling £4.7 million, issued 157 advisory and warning letters and sent 46 information notices. One settlement involved a driving school business admitting drip pricing, agreeing to refund over £760,000 and a £4.2 million fine.
• On reviews, it sent advisory letters to 54 review-publishing firms, 90% of those contacted then took action to improve their policies, and in March 2026 it opened investigations into five companies.
• Its 14 October 2026 blog says that since April 2026 the CMA has opened 6 new investigations, taking the total opened to 20, settled 7 cases, ordered redress of over £2.3 million and imposed fines of over £11.8 million. It says it settled 7 of its 8 original online pricing investigations from November 2025, is reviewing how online retailers disclose delivery fees, is watching for misleading discounts, and expects the total price to be shown clearly throughout the journey without pre-selected extras.

The headline cases involve large businesses and the CMA says it prioritizes significant harm, but the volume of advisory letters shows its approach is to support compliance first and enforce second. Small traders are not exempt from the law.

10. A practical audit for an eBay shop

Run this once on your live listings, then repeat when you add a category or supplier.

1. Price and postage. Open ten listings as a buyer. Is the total obvious before commitment? Move any charge mentioned only in the description, messages or after payment into proper postage options.
2. Free and discount claims. Does a "free" item cost the buyer anything beyond delivery? Was the higher "was" price a real price? The CMA's advice on urgency and price reduction claims (published 29 March 2023) defines a price reduction claim as any discount or special offer that refers to a higher comparison price.
3. Time pressure. Remove "ends tonight" or "only a few left" wording that is not literally true.
4. Legal rights. Search descriptions for "money back guarantee" or "no questions asked" and make sure you are not selling statutory rights as a perk.
5. Availability and delivery. Check that live listings match what the supplier can supply at the advertised price, and compare handling claims with your last ten orders.
6. Claims and marks. Remove any quality, safety or "approved" logos or statements you cannot back with documents.
7. Seller identity. Check your business details are accurate and nothing implies you are a private seller.
8. Reviews and feedback. Delete any message template that offers something for feedback. Write a one-paragraph shop rule: ask every buyer the same neutral question, never trade benefits for reviews, never discourage negative ones.
9. Evidence. Keep dated copies of listing text, photos and supplier descriptions for your top sellers, since the guidance says factual claims should be backed by evidence.

To price with the total in mind, our eBay fee calculator shows what is left after fees, and Sellhelm, the eBay dropshipping software this blog belongs to, prices every listing from your real fees. The legal point stands regardless of tool: the number the buyer sees must be the number the buyer pays.

11. Common mistakes

• Assuming the law only targets big companies. "Trader" is defined broadly, and the penalty ceiling is the higher of a fixed sum and a share of turnover.
• Treating the platform as responsible. The guidance says both marketplace and selling trader may be responsible for a non-compliant listing.
• Undisclosed rewards for reviews. Incentives must be disclosed and the review must be honest, and eBay separately bans them for feedback.
• Chasing a customer to change a negative review. The CMA lists offering a refund or gift card in return as commissioning a banned review.
• Advertising a price you cannot honor. Ending the listing when a supplier raises prices is safer than advertising what you cannot supply.
• Marketing the statutory 14-day right as a perk. It is on the banned list.
• Relying on old articles. Numbering moved when the Act replaced the 2008 regulations, and the CMA updated its guidance on 18 November 2025 and its price transparency summary on 7 January 2026.

The core of the Act is plain: tell the truth, show the whole price, and let genuine experience speak for itself.

Sources and how we checked

Facts in this guide were checked against these official pages in October 2026. Rules and figures change, so confirm anything that affects a decision. This is general information, not legal or tax advice.

• Digital Markets, Competition and Consumers Act 2024, contents (legislation.gov.uk)
• DMCC Act 2024, section 182: Final infringement notice (legislation.gov.uk)
• DMCC Act 2024, section 190: Monetary penalties for breach of undertakings (legislation.gov.uk)
• DMCC Act 2024, section 230: Omission of material information from invitation to purchase (legislation.gov.uk)
• DMCC Act 2024, Schedule 20: commercial practices always unfair (legislation.gov.uk)
• DMCC Act 2024, section 240: Penalty for offenses (legislation.gov.uk)
• Unfair commercial practices, CMA207 (Competition and Markets Authority)
• Fake reviews, CMA208 (Competition and Markets Authority)
• Short guide for businesses publishing consumer reviews (Competition and Markets Authority)
• Price transparency summary, CMA209 (Competition and Markets Authority)
• CMA press release, 7 April 2025 (GOV.UK)
• Direct consumer enforcement: one year on (CMA blog)
• Direct consumer enforcement: 18 months on (CMA blog)
• Using urgency and price reduction claims online (Competition and Markets Authority)
• Feedback manipulation policy (eBay UK)

Questions people ask