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ARTICLE · 29 MARCH 2026

CMA Focus On Agentic AI And Impact On Consumers

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

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The CMA has recently turned its attention to agentic AI and its impact on consumers. On 9 March 2026 the CMA published a research and analysis report on Agentic...

GlobalAntitrust/Competition Law
Susan Black
Susan Black
Natalia Rodriguez
Natalia Rodriguez
Kristien Geeurickx
Kristien Geeurickx
Morris Schonberg
Morris Schonberg
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The CMA has recently turned its attention to agentic AI and its impact on consumers. On 9 March 2026 the CMA published a research and analysis report on Agentic AI and consumers and separate guidance for businesses on complying with consumer law when using AI agents.

The CMA's report and guidance make it clear that the consumer protection provisions and the CMA's new direct enforcement powers as set out in the Digital Markets Competition and Consumers Act (DMCC Act) apply to conduct by AI agents in the same way as they do to conduct that is generated by humans.

The latest guidance is an important reminder for businesses who use AI agents to make sure their AI agents are designed and trained to comply with the relevant consumer protection rules. Failure to do so could result in fines of up to 10% of global annual turnover for the companies involved. Now is the time to carry out a careful audit and make the necessary changes as publication of the CMA's guidance signals this has very

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