Policy Briefing — UK Digital Markets, Competition and Consumers Act Comes into Force

Executive briefing: The United Kingdom’s Digital Markets, Competition and Consumers Act 2024 received Royal Assent on 24 May 2024, giving the Competition and Markets Authority (CMA) new powers to regulate firms with Strategic Market Status (SMS) and to police subscription and fake-review abuses directly. The Act formalises the Digital Markets Unit (DMU), letting it set tailored conduct requirements for dominant digital platforms, impose pro-competition interventions, and levy fines of up to 10% of global turnover for breaches. Consumer provisions mandate easier subscription cancellations, clearer pre-contract disclosures, and bans on commissioning fake reviews, expanding the CMA’s toolkit beyond undertakings and court orders.

Key obligations

Strategic Market Status regime. The DMU can designate firms meeting revenue thresholds and entrenched market power as SMS entities, then impose conduct requirements covering self-preferencing, interoperability, data use, default settings, and reporting.
Pro-competition interventions. Following investigations, the DMU may require structural or behavioural remedies—such as data separation, interoperability mandates, or user choice screens—to address entrenched market failures.
Consumer protection upgrades. Businesses must present key subscription information upfront, send renewal reminders, enable single-step cancellations, and refrain from facilitating or soliciting fake reviews.

Implementation timeline

Secondary legislation and guidance. The CMA will consult on SMS designation guidance, conduct requirements, and enforcement procedures through late 2024 before the regime commences.
Subscription reforms. Consumer protection measures will phase in once commencement regulations take effect—expected within 2024/25—requiring rapid UX and billing updates.
Penalty regime. Civil fines for breaches of consumer law and information notices will apply once commencement orders activate the enforcement provisions, replacing reliance on court undertakings.

Program actions

Assess SMS exposure. Map UK revenues, user reach, and strategic dependencies to determine whether business units could be designated and prepare data access and reporting workflows.
Subscription governance. Audit acquisition funnels, renewal notices, and cancellation UX against the Act’s requirements; build design and engineering sprints to deliver compliant flows.
Review partnerships and ecosystems. Update developer terms, marketplace policies, and interoperability commitments to anticipate DMU conduct requirements and pro-competition directions.

Sources

Zeph Tech partners with UK product, legal, and growth teams to rehearse SMS readiness assessments, redesign subscription journeys, and coordinate CMA engagement plans.