April 2026

Consumer, Competition and Sustainability

CMA orders refunds and fines for drip pricing

On 15 April 2026, the CMA ordered the AA’s AA Driving School and BSM Driving School to refund learners and pay a penalty for unlawful drip pricing.

The CMA found that over 80,000 customers booking online between April and December 2025 were not shown the total price upfront because a mandatory booking fee was added later in the process.

The AA must refund over £760,000 and pay a £4.2 million penalty, discounted by 40% from £7 million following an early settlement and admission, totalling almost £5 million.

This is the CMA’s first consumer-law financial penalty using new powers under the Digital Markets, Competition and Consumers Act 2024, under which fines can reach 10% of global turnover.

For further information on the DMCC Act 2024, see our quick read from Louise Popple here.


European Commission signs agreement with EUIPO to support DSA enforcement

On 1 April 2026, the European Commission signed an agreement with the EUIPO, effective 1 April, to strengthen enforcement of IP rights under the Digital Services Act (DSA).

The agreement aims to bolster the Commission’s capability to take DSA enforcement action addressing systemic risks to IP rights posed by VLOPs and VLOSEs, including dissemination of IP-infringing content such as counterfeit goods and online piracy.

The EUIPO will expand work to enhance capabilities to combat IP infringement risks among judicial and enforcement authorities, online intermediaries not designated as VLOPs or VLOSEs, and IP rights holders.

For more on the DSA's enforcement framework, including the Commission's powers in relation to VLOPs and VLOSEs, see our article by Elisa-Marlen Dietrich, here.


Government consultations on reform of UK product safety regime

On 31 March 2026, the government published two consultations around reform of the UK product safety regime, which are to be read alongside each other.

The first consultation on the general product safety framework and proposed reforms to UK market surveillance and enforcement for product safety and legal metrology would affect manufacturers, importers, distributors, fulfilment service providers and overseas sellers targeting UK consumers, with particular impact on online marketplaces, including:

  • a duty to prevent dangerous products being listed and to remove them once identified, supported by due diligence to identify bad actors
  • designation of a point of contact for enforcement authorities
  • clearer duties to monitor products, maintain traceability records, handle complaints and manage recalls.

Further proposals include:

  • a potential requirement for overseas sellers to appoint a UK representative
  • extended risk assessments covering not only physical harm but also cybersecurity and AI-related risks
  • an expanded product scope, including products intended for business use.

The second consultation on market surveillance and enforcement regime reform proposes merging these regimes, giving regulators broader powers, and introducing fines and undertakings as alternatives to criminal sanctions.

Both consultations close at 11:59pm on 23 June 2026.

For more on product safety and liability reforms in the UK, see our article by Katie Chandler, Matthew Caskie, Dr. Philipp Behrendt and Kerstin Bär, here.


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