In a written statement made to Parliament by the Minister for Employment Rights, Competition and Markets (Justin Madders MP), the Government noted that several key steps are necessary to implement the Act. This includes secondary legislation being laid before Parliament for scrutiny before it can enter into force, the Competition and Markets Authority (CMA) publishing guidance on how it will carry out its functions and use its powers, and the Secretary of State for Business and Trade approving the CMA’s digital markets guidance.
DMCC Act implementation timeline
To ensure those affected by the operation of the DMCC are made aware of when its changes will come into effect, the Government has set out the expected commencement dates for each part of the Act. The table below provides an overview of the implementation timeline.
Commencement dates
December 2024 / January 2025
Digital markets regime (Part 1 of the DMCC Act): Secondary legislation will be laid before Parliament in the Autumn for scrutiny before it comes into force. The CMA has recently closed a consultation on the guidance on the regime and we expect to see an updated draft – which will require Secretary of State approval – in the coming months. The CMA has made clear its enthusiasm to get on with the SMS regime and has already clearly signalled some of its first priorities, so the first Strategic Market Status designation investigations should be expected to follow commencement very swiftly.
Amendments to the wider competition regime and enhancement of the CMA’s powers, including changes to merger control thresholds (Parts 2 and 5): These changes will include a new ‘no increment’ share of supply jurisdiction for global deals, a safe harbour where each party’s UK turnover is less than £10 million and procedural changes for merger reviews.
April 2025
CMA’s new direct enforcement powers for consumer protection (Part 3): The CMA will have the power to directly enforce consumer protection laws in the UK and sanction breaches, meaning that cases will no longer need to go through the courts.
Unfair trading protections (Part 4, Chapter 1): Consumer rules, which the CMA can directly enforce, will include the existing broad prohibitions on unfair contract terms in consumer contracts and unfair commercial practices which includes misleading consumers, acting aggressively, or contravening the requirements of professional diligence.
New savings scheme rules and reforms to alternative dispute resolution (ADR) (Part 4, Chapters 3 and 4): New rules on consumer savings schemes and ADR mechanisms for consumer contract disputes will follow and are not expected to commence before April 2025.
Spring 2026
Subscription contract rules (Part 4, Chapter 2): Reforms to subscription contracts include specific rules on providing specified pre-contract information and issuing clear reminder notices to consumers.
Looking ahead
The Government’s implementation plan provides UK businesses with a clear roadmap to ensuring their readiness for the forthcoming changes. In parallel, both the Government and the CMA will continue providing further direction on the application of the DMCC in the coming months, as further secondary legislation and guidance are drafted and consulted upon.
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