The DMCC Act 2024 and What It Means for UK Businesses

The internet has spent the last two decades rewriting the rules of commerce. Platforms that started as tools for discovery; Google for search, Amazon for retail, Meta for social networking; have become market gatekeepers, dictating where consumers go as well as how businesses reach them. Governments have struggled to keep up, and when regulators have acted, it’s often been too little, too late.

That’s about to change. The Digital Markets, Competition and Consumers Act (DMCCA), coming into force in April 2024, is the most significant shift in UK consumer law in decades. It is an attempt to rebalance power in the digital economy, introducing stricter rules on anti-competitive behaviour, subscription models, misleading advertising and consumer rights. Unlike past attempts at regulation, which relied on drawn-out legal battles, the DMCCA gives the Competition and Markets Authority (CMA) real enforcement teeth, including fines of up to 10% of global turnover for non-compliance.

For small and medium-sized businesses (SMEs), this is both an opportunity and a challenge. The Act is designed to curb the dominance of Big Tech, theoretically creating a fairer marketplace. But it also introduces new compliance obligations that could be burdensome for smaller businesses that lack dedicated legal teams. What follows is a compliance checklist as well as an exploration of what this law really means for SMEs, what challenges it presents, and where the opportunities lie.

Why This Law Exists and Why SMEs Should Care

At its core, the DMCCA addresses two long-standing issues in digital markets: unfair competition and consumer harm. Large tech platforms have been accused of tilting the playing field in their favours; self-preferencing their own products in search results, undercutting competitors with predatory pricing, and leveraging user data in ways smaller businesses cannot. At the same time, consumers have been subjected to misleading advertising, fake reviews, hidden fees, and subscription traps that are easy to sign up for but infuriatingly difficult to cancel.

For SMEs, this creates both risks and opportunities. The risk is that compliance will introduce costs and bureaucracy that smaller businesses are less equipped to handle than their larger counterparts. The opportunity is that a fairer digital economy could make it easier for them to compete; particularly if dominant platforms are forced to open up distribution channels or stop privileging their own services.

This law reshapes how digital markets operate, shifting power dynamics between large corporations, smaller businesses, and consumers. SMEs face a choice: adapt early and position themselves for new opportunities or take a wait-and-see approach as enforcement unfolds.

Subscription Models and the End of Dark Patterns

The DMCCA takes direct aim at subscription-based business models, particularly those that rely on deliberately confusing pricing structures or make it hard for users to cancel. Consumers must now receive clear, upfront information about pricing, renewal terms, and cancellation options. Businesses must also offer a straightforward way to cancel, meaning no more forcing customers to call a number that only operates between 9:00 and 9:15 AM on weekdays.

This is bad news for companies that rely on inertia-driven revenue; the kind where customers forget they are subscribed or cannot be bothered to go through a complicated cancellation process. But for businesses that offer genuine value, this should not be a problem. If your service relies on customers misunderstanding how they are being charged, you do not have a business model. You have a loophole that is about to be closed.

SMEs running subscription-based services; whether SaaS platforms, membership sites, or subscription boxes; should review their terms now. If cancellation involves hidden menus, misleading confirmations, or unnecessary delays, it’s time to fix it before the CMA forces the issue.

The Crackdown on Misleading Advertising and Fake Reviews

Digital advertising thrives on trust, and trust has been in short supply. Fake reviews, influencer marketing without disclosure, and misleading pricing tactics have all contributed to an erosion of consumer confidence in online advertising. The DMCCA mandates that businesses must now verify that reviews are genuine and that all paid endorsements; whether influencer collaborations, product placements, or review incentives; must be explicitly disclosed.

This is particularly important for SMEs that rely on customer reviews and influencer marketing to build credibility. Platforms like Amazon and Google will likely introduce stricter policing of reviews, meaning fake testimonials, undisclosed sponsorships, or exaggerated claims could result in enforcement actions. Businesses will need to prove that their marketing practices can withstand regulatory scrutiny.

SMEs should be proactive in auditing their marketing to remove questionable reviews, educate influencers on disclosure requirements, and ensure that all sponsored content is clearly identified as such.

The CMA’s New Powers and the Risk of Enforcement

The Competition and Markets Authority (CMA) is no longer just a watchdog. Under the DMCCA, it has the power to impose fines without needing to take companies to court. Previously, most consumer law violations required litigation, which meant many smaller infractions went unpunished. Now, the CMA can issue fines of up to 10% of global turnover directly; a significant deterrent, even for SMEs.

While the CMA is expected to focus primarily on larger firms, SMEs are not immune from enforcement. If a small business engages in misleading marketing, opaque pricing, or anti-competitive behaviour, it could still face fines and reputational damage. This means compliance is not optional; every business, regardless of size, should be reviewing its practices before the law comes into effect.

Opportunities for Smaller Businesses

The DMCCA introduces new regulations while creating opportunities for SMEs to compete on a more level playing field. Platforms like Amazon, Google, and Facebook will no longer be able to privilege their own products or services over independent sellers. This could mean better visibility for SMEs that have historically been sidelined by big platforms prioritising their own offerings.

For example, an independent retailer selling on Amazon may now have a better shot at ranking fairly in search results rather than being automatically pushed below Amazon’s private-label products. Similarly, businesses that rely on Google Search for traffic may benefit from restrictions on Google favouring its own services.

The businesses that stand to gain the most will be those that are ready to take advantage of these changes. This means reassessing digital strategies, looking for new advertising and SEO opportunities, and preparing to compete on a more level playing field.

Final Thoughts

The Digital Markets, Competition and Consumers Act represents a fundamental shift in how digital business is regulated in the UK. SMEs face new compliance requirements, but they also stand to benefit from greater market fairness and consumer trust. Businesses that proactively adapt; by updating their subscription models, ensuring marketing transparency, and taking advantage of fairer competition rules; will be the ones that thrive.

For nearly 20 years, we have helped businesses navigate changes in digital regulation and online marketing. Our main hub is in Horley, Surrey, with additional locations in Peckham and Hampstead, London. Whether reviewing compliance risks, developing new marketing strategies, or preparing for regulatory shifts, we work with businesses to create practical, effective solutions. If you want to get ahead of these changes, now is the time to act.