No more false impressions: UK government crackdown on hidden fees and fake reviews to take effect from April 2025

The UK government’s crackdown on hidden pricing and fake reviews in consumer marketplaces takes effect from 6 April 2025. From this date, businesses may also face direct enforcement action from the Competition and Markets Authority (CMA).

Online retailers must review and update their platforms promptly to avoid unwanted attention from the CMA, the UK regulator of unfair consumer practices. As we highlighted in our coverage of the Digital Markets, Competition and Consumers Act (DMCCA), there are several practical steps businesses should take to ensure their website content is clear and transparent ahead of the rule changes. The CMA has confirmed that the new consumer protection rules will apply from 6 April 2025, although a grace period of three months appears to be in place for retailers to make necessary adjustments.

Transparent pricing

While some quick fixes may help improve content clarity, the new rules will have a longer-term impact on pricing strategies. This could present challenges for retailers already working to attract and retain customer loyalty in a competitive market.

Fashion retailers are increasingly charging for delivery and returns to discourage customers from bulk-buying multiple sizes or colours of the same item. Under the new rules, such fees must be clearly communicated before customers complete the checkout process. Similarly, retailers that advertise attractive headline prices before adding mandatory costs such as installation fees will need to reconsider how they present overall pricing.

The CMA has indicated that further guidance — particularly on drip pricing — will be issued later this year, so keep an eye out for updates to help shape your pricing approach.

Misleading reviews

Businesses that engage social media influencers to promote their products will already be familiar with the requirement to acknowledge paid promotions. In our view, a similar approach should now be adopted for displaying product reviews. Using hashtags or other clear indicators could be an effective way to identify commissioned reviews.

The new rules require retailers to take reasonable steps to prevent fake or misleading reviews, though the exact compliance threshold remains unclear. As we outlined in our previous DMCCA coverage, businesses should implement a clear content review process and a policy setting out how misleading reviews will be handled. This proactive approach will help demonstrate compliance should the CMA investigate.

Enforcement

In respect of the areas discussed above, and the other unfair commercial practices covered by the DMCCA, the risk of getting it wrong will increase substantially with the CMA able to directly impose monetary penalties up to £300,000 or 10% of their worldwide turnover (whichever is higher). However, the CMA has provided some comfort in stating that enforcement will focus on the most extreme breaches and it will support those businesses that want to do the right thing but may be unclear on exactly what is needed to ensure compliance, especially in areas where the law has been updated.

How can we help?

If you need advice on aligning your business with these new requirements or would like to discuss your approach before rolling out any changes, please get in touch.