Five Stars or False Advertising? Key Consumer Law Developments

What do you need to know? There have been various changes to the consumer law regime in the UK as a result of the introduction of the Act, large parts of which came into force last year. Now we are well into the new consumer protection regime, we take stock of some of the key changes and the CMA’s approach so far.

What are the key changes? The Act sets out a list of practices that are always considered unfair and are prohibited, as well as expanding on prohibited practices that already existed under the previous UK consumer law framework. This expansion includes changes in relation to false consumer reviews, pressure selling, and persistent and unwanted solicitations. The Act also imposes a complete ban on ‘drip pricing’. The CMA gained significant new consumer protection investigation and enforcement powers and can now directly (i.e. without needing to go to court) impose fines on infringing businesses of up to £300,000 or 10% of worldwide turnover, if higher.

Why does it matter and what should businesses consider? The Act applies to consumer-facing businesses and provides important updates to English law in respect of information that businesses are required to show to customers. As such, it has important implications for rightsholders and sports governing bodies that sell goods or services to consumers, including tickets, merchandise and experiences.

This note summarises the key updates that are most relevant to organisations operating in the sports industry, and practical steps that can be taken to ensure compliance with the new consumer law regime.

Fake Reviews

The Act prohibits businesses from publishing misleading or fake reviews. This includes concealing incentives by offering free products, discounts or perks in return for reviews without clearly disclosing this is the case. Hiding or suppressing negative reviews and using unrelated reviews on a product is also banned.

Example: A sports club sells a range of merchandise, including replica shirts. The club provides free shirts to a number of influencers in order for them to post glowing reviews about them, but the influencers fail to disclose the fact that the club gifted the shirts to them free of charge. In this situation, both the influencers and the club can be held liable for breaching the Act.

The CMA issued its first notification on the topic of fake reviews in July 2025. Following a website review of over 100 businesses, the CMA found that over 50% needed to do more to ensure compliance with the new regime, with some businesses failing to have a policy in place that bans fake reviews.

Practical suggestions:

• Take reasonable and proportionate steps to detect, prevent and remove any fake or misleading reviews.
• Review any existing policies you have in place on how reviews are collected and implement proactive systems that capture any suspicious reviews.
• Mark incentive-related reviews clearly.

Drip Pricing

The Act imposes a complete ban on the practice known as ‘drip pricing’, which occurs when a business shows a consumer an initial price, and additional fees are subsequently introduced (or ‘dripped’) as consumers proceed with a transaction. A typical example of this would be the imposition of a booking fee on tickets to a sporting or music event at the point of purchase.

Under the Act, businesses must inform consumers upfront of the total price of the goods or services in question, including any fees, taxes, charges or other payments that the consumer will necessarily incur if the consumer makes a purchase. Where there are charges that cannot be definitively calculated in advance (such as delivery/postal charges), businesses must clearly inform consumers at the outset that such charges may apply.

The CMA has already shown that it is taking active steps to investigate infringements. For example, it opened investigations into ticketing platforms StubHub and viagogo towards the end of 2025, regarding their pricing practices where mandatory fees were not clearly presented at the start of the purchase process.

Example: A football club provides a price of £65 for a general sale match-day ticket on its website. When the consumer prepares to pay for the ticket, they are informed of an additional mandatory £3.50 booking fee in order to purchase the ticket. The consumer was initially provided with a total, headline price of £65, whereas the total price of the ticket is in fact £68.50. Under the Act, the club should have provided this total price at the outset of the purchasing process.

Practical suggestions:

• Consider if updates are needed to terms and conditions.
• Review and update sales processes regarding drip pricing, including checking with third party platforms that they are compliant and ensuring that you have included relevant protections within contracts with such third parties.
• Ensure that all pricing information is displayed clearly, in a timely manner and in a way that the consumer is likely to see it. For example, it is unlikely to be sufficient to include additional mandatory pricing information in small print or alongside an asterisk.
• Provide the mandatory fee in real terms – it is not sufficient for businesses to inform consumers that they will be charged a mandatory fee in percentage terms on the basis that this is too opaque.
• Ensure that you have processes in place to identify and respond to any requests from the CMA efficiently.

See the flow chart, which shows what certain provisions of the Act require and the information that businesses must show to consumers.

Please contact a member of the team at Onside if you would like to discuss any of these changes to UK consumer law.