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ARTICLE · 07 OCTOBER 2026

Consumer Law Revolution: Autumn 2026 Update

Lewis Silkin
Lewis Silkin
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Lewis Silkin

Lewis Silkin

Joint managing partners: Jo Farmer, Richard Miskella International offices: Dublin, Hong Kong...

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The UK consumer law landscape is undergoing rapid transformation as the CMA exercises its new direct enforcement powers under the DMCC Act 2024, with subscription contract regulations accelerated...

United KingdomConsumer Protection
Geraint Lloyd-Taylor
Geraint Lloyd-Taylor
Brinsley Dresden
Brinsley Dresden
Rebecca Moore
Rebecca Moore
Jen Dinmore
Jen Dinmore
Alex Meloy
Alex Meloy
Fleur Chenevix-Trench
Fleur Chenevix-Trench
Pearl Agyemfra
Pearl Agyemfra
Ella Nawaro
Ella Nawaro
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We are pleased to share with you our Consumer law revolution: autumn 2026 update, the second edition of our twice-yearly report designed to keep you at the forefront of the evolving UK consumer law landscape.

A lot has happened since our spring update. The CMA has shown it is eager to flex its new direct enforcement powers under the DMCC Act 2024, and the pace is only accelerating. Two developments stand out: the subscription contracts regime has been brought forward to January 2027, giving businesses very limited time to prepare; and the High Court has handed down its long-awaited judgment in the Emma Sleep case, rejecting the CMA's proposed blanket volume ratio for discount claims.

The CMA has now opened 19 investigations since November 2025, issued its first fine of £4.2 million for drip pricing, and ordered substantial consumer redress alongside headline penalties. With maximum fines of up to 10% of annual global turnover, consumer law compliance remains firmly a board-level

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