The Digital Markets, Competition and Consumers Act 2024 has strengthened UK consumer protection enforcement and introduced clearer rules on pricing and reviews. For online retailers, compliance requires attention to the whole customer journey, from advertising and checkout to cancellation and refunds.
This guide explains the principal consumer protection laws for online businesses selling to UK consumers. Herrington Carmichael considers what these obligations mean in practice and where businesses should focus their reviews.
Which UK Consumer Protection Laws Apply to Online Businesses?
The Consumer Rights Act 2015 governs product quality, remedies and unfair consumer contract terms. The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 govern pre-contract information and cancellation rights for most online purchases.
The Digital Markets, Competition and Consumers Act 2024 governs unfair commercial practices, including misleading pricing and fake reviews. Its unfair commercial practices provisions replaced the previous Consumer Protection from Unfair Trading Regulations 2008 framework for practices occurring from 6 April 2025.
These protections concern consumers buying mainly outside their trade or profession. Business-to-business sales require a separate contractual analysis; retailers serving both markets should distinguish their terms and processes. Our business services support commercial arrangements across these markets.
What Should Website Terms and Conditions Include?
Online retailers must provide clear information before consumers commit to a purchase, including business identity, contact details, product/service characteristics, total price, delivery arrangements and applicable cancellation rights.
Terms should explain when the contract is formed, payment, delivery, complaints and returns. Consumers must receive confirmation in a form they can retain, such as email. Relevant information should be accessible before checkout, rather than appearing only after payment.
Under the Consumer Rights Act 2015, unfair terms are not binding on consumers. Broad exclusions of liability or blanket “no refunds” clauses may conflict with statutory rights. HC’s commercial team can review whether contractual wording reflects the transaction and the applicable protections.
What Are Online Retailers of goods Returns and Refund Obligations?
For most online goods purchases, consumers have 14 days after delivery to notify the retailer that they wish to cancel, followed by another 14 days to return the goods. This change-of-mind right is separate from rights relating to faulty products.
Cancellation refunds generally include the cheapest option for delivery costs. Retailers may usually withhold the refund until receiving the goods or evidence of dispatch, whichever comes first. Consumers can bear return costs if properly informed in advance. Retailers can make a deduction from refunds where the consumer has used the goods in a manner, they wouldn’t have been able to do in a shop.
Faulty, misdescribed or unsuitable goods may attract a short-term right to reject, usually within 30 days, followed by other statutory remedies. A voluntary returns policy cannot remove these rights. The government’s returns and refunds guidance explains the distinction.
Pricing Transparency Rules for Online Businesses
Online businesses must present required pricing information clearly, including mandatory charges that can reasonably be calculated in advance. Unavoidable fees should not emerge only late in checkout. They need to all be included upfront in a single price.
Where a mandatory charge cannot reasonably be calculated beforehand, businesses must clearly explain how it is calculated. Optional extras require appropriate consumer agreement; pre-selected paid additions can create compliance problems.
Discounts, reference prices and countdown offers must not mislead consumers. Businesses should retain evidence supporting savings claims and review the entire purchasing journey against the CMA’s unfair commercial practices guidance.
Subscription and Auto-Renewal Compliance
Subscription businesses already need fair terms and clear information about recurring charges, contract duration and cancellation. Automatic renewal clauses should not obscure the financial commitment or create unfair barriers to leaving.
The 2024 Act also introduces a dedicated subscription regime covering information, reminders, cancellation and cooling-off rights, though this is not yet in force. As at 7 October 2026, government guidance anticipates commencement in spring 2027; businesses should distinguish these forthcoming requirements from existing obligations.
Our ecommerce services can assist with reviewing subscription arrangements and the contractual implications of changes to customer journeys.
Online Reviews and Advertising Rules
Fake reviews and reviews that conceal incentives are prohibited under the 2024 Act. Businesses publishing reviews must take reasonable and proportionate steps to prevent and remove prohibited reviews and misleading review information.
Incentivised reviews are not automatically unlawful, but incentives must not be concealed.
Selective presentation of reviews or manipulated ratings can also mislead consumers.
Advertising claims need supporting evidence, and paid endorsements should be identifiable. Alongside consumer law, advertising rules and intellectual property considerations may affect how businesses use endorsements, images and branding.
Common Consumer Law Enforcement Risks
Misleading prices, unfair terms, obstructed refunds and prohibited review practices can attract enforcement. The Competition and Markets Authority can impose penalties for consumer law infringements of up to the higher of £300,000 or 10% of worldwide turnover.
Consumer claims may also require dispute resolution support. Businesses should consider:
- Reviewing terms, checkout information and refund procedures together;
- Testing price disclosures and cancellation journeys;
- Documenting advertising evidence and review moderation;
- Training staff to recognise statutory consumer rights;
- Checking customer-data practices separately against data protection requirements.
How We Can Help Your Online Business
Herrington Carmichael’s commercial team can assist with website terms, returns policies and ecommerce contracts. A review should consider how documents operate alongside the actual checkout and customer-service processes.
If you are launching an online store or updating existing arrangements, contact us to enquire about a review of your website terms, refund policy or subscription contracts.
