The Competition and Markets Authority (CMA) has published its Annual Plan for 2026 – 27, setting out how it will deliver the first year of its new 2026 – 2029 strategy. While the Plan is framed around economic growth and household prosperity, it carries a clear message for businesses: consumer protection enforcement is now a top priority.
The Plan follows the introduction of the Digital Markets, Competition and Consumers Act (DMCCA), which has fundamentally changed how consumer law is enforced in the UK. The CMA now has both the tools and the mandate to intervene more quickly where consumer harm is identified.
What is changing?
The Annual Plan confirms a decisive shift in how the CMA intends to operate in 2026 – 27. In particular, the CMA has said it will:
- prioritise consumer protection over more complex or novel competition cases;
- use its new direct enforcement and fining powers under the DMCCA;
- focus on practices that cause clear, everyday harm to consumers; and
- act with greater speed where the legal position is already well‑established.
This marks a move away from lengthy court based processes and towards faster, more visible enforcement, particularly in consumer facing sectors.
Areas the CMA is watching closely
The Plan highlights a number of practices that the CMA considers high risk. These align closely with issues already familiar to many businesses, including:
- Pricing transparency, such as hidden fees and drip pricing;
- Unfair contract terms, including exit fees and barriers to cancellation;
- Subscription models, particularly where renewal and cancellation processes are not sufficiently clear;
- Online choice architecture, where digital design influences consumer decisions;
- Banned practices, such as fake or misleading reviews.
As we discussed in our earlier blog on subscription traps and DMCCA compliance, these are precisely the areas where the CMA’s new powers are likely to be tested first. The Annual Plan makes clear that 2026 – 27 is when those powers move from theory into practice.
From guidance to enforcement
The CMA has emphasised that it will continue to support businesses that are genuinely trying to comply, and will use guidance and early engagement where appropriate. However, the Plan also makes clear that this is not a “soft” approach.
Where the CMA considers the law to be clear and the consumer harm significant, it has stated that it will not hesitate to act decisively. For businesses, this means that unresolved issues around pricing, contractual fairness or customer journeys are now more likely to result in formal action than they would have been under the previous regime.
What does this mean for businesses?
The Annual Plan reinforces several practical points for commercial teams:
- Existing practices are under scrutiny – particularly those that have long been flagged as problematic.
- Compliance needs to work in practice, not just on paper. Any mismatch between written terms and actual customer experience is a clear risk area.
- Digital interfaces matter. How choices are presented online is now a core consumer law issue.
- Reputational exposure is increasing, as enforcement action is expected to be quicker and more public.
What to do now
In light of the CMA’s stated priorities, businesses should consider:
- Reviewing consumer terms, pricing and exit routes;
- Stress‑testing subscription and renewal processes;
- Assessing online customer journeys for potential fairness issues;
- Ensuring issues raised internally can be escalated and addressed quickly; and
- Joining up consumer law compliance with wider commercial and product decision‑making.
Early review and remediation remains significantly lower‑risk than responding to a CMA investigation under the new enforcement regime.
How Beyond Corporate can help
The CMA’s Annual Plan for 2026–27 is not just a policy document. It is a clear signal of how consumer law will be enforced in practice under the DMCCA. For businesses, this marks a shift towards faster intervention and greater accountability for consumer facing practices.
Those that use this period to review and strengthen compliance will be better placed to manage regulatory and commercial risk as the new regime beds in.
Our Commercial team supports clients across all sectors with consumer law compliance, including preparing for CMA scrutiny under the DMCCA. If you would like to discuss how the CMA’s priorities affect your organisation, please get in touch at [email protected].
