The DMCC Act for UK Online Shops: A Practical Checklist for Pricing, Reviews and Subscriptions

If you sell online in the UK, the rules on how you show prices and reviews changed in April 2025. Since then the Competition and Markets Authority (CMA) can fine a business directly, without going to court first. New subscription rules are also on the way.

Most shops aren't doing anything deliberately dodgy, but small slips, like a delivery charge that appears at the last step, can still be a breach. This guide covers what changed and a self-audit you can run this week.

Please note: this is a practical overview, not legal advice. For your own situation, read the official guidance linked below or speak to a solicitor.

What the DMCC Act changed

The Digital Markets, Competition and Consumers Act 2024 (often shortened to the DMCC Act or DMCCA) received Royal Assent on 24 May 2024. The consumer protection parts arrived in stages:

• In force since 6 April 2025: the new unfair trading rules, the list of banned practices and the CMA's direct enforcement powers, brought in by the Commencement No. 2 Regulations. These replaced the old Consumer Protection from Unfair Trading Regulations 2008.
• Not yet in force: the subscription contract rules. Draft regulations say they are due to apply from 1 January 2027, but only once Parliament approves them and the government brings the subscription sections of the Act into force. More on that below.

The CMA's unfair commercial practices guidance (CMA207) explains the framework, including 32 practices that are always unfair. Fake reviews are one of them.

Drip pricing on product, basket and checkout pages

Drip pricing is showing a headline price, then adding charges the customer can't avoid as they go through the purchase.

The key rule is in section 230 of the Act. When you invite someone to buy, you must show the total price, including any fees, taxes or charges they will necessarily pay. If a price can't be worked out in advance, you must explain how it will be calculated, as prominently as the price. Information that is unclear, shown too late or unlikely to be seen counts as missing.

Product pages

Your product page price should be what the customer actually pays, before optional extras:

• Mandatory fees go in the price. A compulsory service, handling or small order fee belongs in the headline price, not a later line.
• "From" prices include mandatory charges. The CMA's price transparency guidance (CMA209) says "from" prices must include unavoidable charges too.
• Genuine extras can be separate. Optional gift wrap or engraving isn't a charge the customer necessarily pays, so it can sit outside the headline price.

Basket and checkout

A total that suddenly gains a fee at the payment step is the classic pattern the CMA looks for. Show every charge as early as you can and keep the total visible.

CMA209 also says mandatory per-transaction charges, such as a booking fee, belong in the price. Surcharges for paying by most consumer cards are already banned under the Payment Surcharges Regulations, so build card costs into your prices. Our guide to payment gateway options for UK eCommerce compares those costs.

Delivery and mandatory fees

Delivery often depends on the customer's address, so CMA209 sets out a practical approach:

• If delivery is mandatory and can reasonably be calculated, include it in the total price.
• If the customer must choose a delivery option, include the cheapest one until they pick another.
• If delivery varies by location, give the information customers need to work it out, with the same prominence as the price.
• Optional faster delivery, such as next-day, can be kept out of the total, but CMA209 says it must still be shown when you invite customers to buy.
• A prominent delivery fee with a running total throughout the purchase is given as one way a retail website can comply.

What customers see depends on your theme and settings. Shopify's Dawn theme can show a cart note that shipping is calculated at checkout, WooCommerce can show a shipping calculator on the cart page, and OpenCart has an optional shipping estimate box. None is automatically right or wrong. What matters is whether customers see what they'll pay early enough. Our post on optimising eCommerce checkout flows covers how to do this without adding friction.

Fake reviews and review widgets

The rules on reviews are in Schedule 20, paragraph 13. It bans:

• Writing, submitting or commissioning fake reviews. A fake review is one that claims to be, but is not, based on a genuine experience. It can be positive or negative.
• Hidden incentives. A review you have paid for or rewarded in any way, such as a discount code or a free product, must make that clear.
• Publishing reviews in a misleading way. For example, hiding negative reviews while showing positive ones, or giving positive reviews more prominence.
• Publishing reviews without reasonable steps to prevent and remove fake or misleading ones.

What the CMA expects from your shop

The CMA's fake reviews guidance (CMA208) says every publisher of reviews needs:

• A clear, published review policy in plain English that bans fake reviews and explains your approach to incentivised ones. Link to it near your reviews, not buried in the footer.
• A risk assessment and proportionate checks, such as checking reviewers have genuinely used the product and watching for spikes in very positive or negative reviews. Don't block a genuine review just because the reviewer didn't buy the product, for example a gift.
• Fair treatment of negative reviews. Don't edit or remove genuine bad reviews, don't only invite happy customers, and don't push people to make a complaint instead of leaving a review.
• Accurate star ratings. If you remove fake reviews, your average rating and review count should update promptly.

Third-party review widgets

If you show ratings from a review platform through a widget, the CMA calls you a "second-party publisher". You can rely on the platform's checks, but only if you've looked at its policies and are reasonably confident they work. Also check the widget's settings, as some let you filter which reviews appear.

In its one-year update, the CMA said it had written to 54 review publishers, 90% had taken action, and it had opened investigations into five companies over reviews.

Subscriptions: what's coming

If you sell subscriptions, such as a monthly box or a membership, a new regime is on the way. It is not in force yet, and much of the detail sits in the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026.

The draft regulations and the government's draft guidance, both published in October 2026, say the rules are due to apply to contracts entered into on or after 1 January 2027. That date isn't final. Parliament must approve the regulations and the government must bring the subscription sections of the Act (Chapter 2 of Part 4) into force, and neither had happened when we wrote this. A government statement in April 2026 had said spring 2027, so check the guidance page for updates.

Based on the draft guidance, you will need to:

• Give clear information before signup, including the price, how often you charge and how to cancel.
• Send reminder notices, for example before a free or discounted trial ends, before a renewal of 12 months or more, and roughly every six months on rolling contracts.
• Allow a 14-day cooling-off period at the start (for goods, it ends 14 days after the first delivery arrives), and another 14-day period after a trial ends or after a renewal of 12 months or more.
• Make cancelling easy. Once in force, section 260 says ending a contract must be straightforward. If customers signed up online, they must be able to cancel online. The draft guidance says a clearly labelled button or simple form will do, but an email address alone won't.
• Confirm the cancellation with an end-of-contract notice. The draft guidance says this should be sent within 24 hours if the customer cancelled online, or within three working days otherwise.

The draft guidance says the rules won't apply to existing contracts, though treating existing subscribers the same way is described as best practice. Business-to-business subscriptions are excluded. Check now whether your subscription app and reminder emails can do all of this.

The CMA's direct fines

Since April 2025 the CMA can decide for itself whether consumer law has been broken. Under section 182, a fine can be up to £300,000 or 10% of the business's turnover, whichever is higher. The CMA can also order compensation and a published corrective statement.

This is already happening. In its one-year update in April 2026, the CMA said a national driving school group admitted liability for drip pricing, agreed to refund over £760,000 to affected learner drivers, and was fined £4.2 million.

A step-by-step self-audit

Set aside an hour and use your shop as a customer would:

1. Pick three products and note the headline price on each product page and category listing.
2. Add them to the basket and note every charge. Is anything new that the customer can't avoid?
3. Go through checkout to the payment step with a test address. Does the total match what you expected?
4. Check delivery information. Is the cheapest option included or clearly shown early?
5. Check "from" prices in banners, ads and emails for missing mandatory fees.
6. Look at your reviews. Is there a published policy? Do you invite reviews from all customers, not just happy ones? Are incentives labelled and negatives shown fairly?
7. Check your review widget settings and the provider's fake review policy.
8. If you sell subscriptions, test your cancel journey and note what must change before 2027.
9. Write down what you found and fix the easy items first.

For a second pair of eyes on the technical side, our code audits can look over your checkout code and templates, and our eCommerce development team can make the changes on OpenCart, WooCommerce or Shopify. For questions about what the law requires of your business, speak to a solicitor.

Frequently asked questions

Does the DMCC Act apply to small online shops?

Yes. The unfair trading rules apply to traders of any size. The CMA's fake reviews guidance says even small shops publishing reviews from their own customers must take reasonable and proportionate steps.

Can I still show delivery costs at checkout?

Yes, if customers aren't surprised. CMA209 says mandatory delivery belongs in the total where it can reasonably be calculated. Otherwise, show how it's worked out as prominently as the price.

Are incentivised reviews banned?

Not completely. Concealing an incentive is banned. If you reward customers for reviewing, make that clear on the reviews, and make sure you aren't rewarding only positive ones.

When do the subscription rules start?

They are not in force yet. The draft date is 1 January 2027, but only once Parliament approves the regulations and the subscription sections of the Act are brought into force. Check the government's guidance page for updates.

Getting your shop ready

For most shops none of this needs a rebuild. It's a handful of template and settings changes: fees in the headline price, clearer delivery information, a review policy and a fair review display. Subscriptions take more planning, so start early.

If you'd like help with the technical changes, such as templates, checkout settings or review displays, get in touch. We're happy to talk through what you've found.