When did you last review your standard terms and conditions? If you can’t remember, now is the time. The Competition and Markets Authority (CMA) has made unfair contract terms a top enforcement priority for 2026–2027, and with new powers to impose penalties of up to 10% of global turnover, it has never been better placed to act.
New CMA’s enforcement powers
Under the Digital Markets, Competition and Consumers Act, the CMA can now take direct enforcement action against businesses that use unfair or unclear contract terms without first bringing court proceedings. Penalties can reach up to 10% of global turnover or £300,000, whichever is higher.
The CMA is actively monitoring business practices using AI and other tools to detect potential misconduct. Because unfair terms are often publicly visible on a company’s own website, they can be identified quickly through technology or picked up incidentally during wider investigations into other issues, such as fake reviews or misleading