UK Contract Law Update: Consumer Terms and Conditions (2025)
Over the past six months, significant developments have reshaped the legal and regulatory environment surrounding consumer-facing terms and conditions in the UK. These changes reflect a stronger push for transparency, fair pricing, and greater consumer rights—particularly in digital contracts, subscriptions, and pricing structures.
1. New Consumer Enforcement Powers
Since April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) has introduced wide-ranging reforms. Most notably, the Competition and Markets Authority (CMA) now has the power to enforce consumer protection laws directly, without the need to bring court proceedings. Businesses that breach consumer protection rules can face fines of up to 10% of global turnover.
This enforcement model marks a shift toward quicker, more decisive regulatory action and places greater pressure on businesses to ensure their terms are legally compliant and commercially fair.
2. Total Price Transparency
One of the most immediate impacts of the DMCC Act is the prohibition of so-called “drip pricing” practices. This includes situations where mandatory fees—such as booking charges or service fees—are added late in the online checkout process.
Businesses are now required to display all unavoidable costs upfront. The total price must be clear from the beginning of the transaction, and consumers must not be misled about the real cost of goods or services.
3. Regulation of Online Reviews
Consumer protection law now formally prohibits the use of fake or misleading online reviews. Specifically, businesses must not:
Post fabricated reviews or endorsements;
Incentivise reviews without clear disclosure;
Manipulate review systems by highlighting only positive feedback or suppressing negative commentary.
Retailers and platforms are required to take reasonable steps to monitor and remove deceptive or unreliable reviews. This includes having appropriate systems in place to assess the authenticity of user-generated content.
4. Subscription Contract Reform (Forthcoming)
While not yet in force, significant reforms to subscription-based contracts are expected to take effect in 2026. Businesses offering auto-renewing services will need to:
Provide consumers with clear pre-contractual information about renewal terms and costs;
Offer a 14-day cooling-off period at the start of the contract and at each renewal (for contracts lasting 12 months or more);
Send renewal reminders before auto-renewal occurs;
Make cancellation straightforward and accessible—particularly for online services.
Although these rules are not yet live, businesses should begin reviewing their subscription models to ensure future compliance.
5. Mid-Contract Price Increases in Telecoms
A separate regulatory development in early 2025 now requires telecom providers to display clear, pound-and-pence pricing for mid-contract increases, rather than using inflation-based percentages. While such increases are still permitted, consumers must be able to understand the exact cost implications at the time of signing.
This change reflects broader regulatory trends toward simplicity and transparency in consumer contracts across all industries.
Implications for Consumer-Facing Terms
These developments are not just regulatory tweaks—they require businesses to revisit and often revise the terms and conditions that underpin their customer relationships. In particular, companies should:
- Disclose full pricing information at the start of any transaction, including all unavoidable charges.
- Avoid ambiguous or one-sided variation clauses, especially those allowing the business to make changes without consumer agreement.
- Review review policies to ensure fake or incentivised reviews are not posted or featured on their websites.
- Prepare for subscription law reform by mapping current services, updating renewal notices, and building easy cancellation mechanisms into digital platforms.
- Align website and mobile interfaces with consumer protection standards, avoiding any misleading or obstructive designs.
- Recommended Next Steps
- Review and update your terms and conditions to reflect the DMCC Act’s new standards.
- Audit your pricing practices to ensure compliance with the total price disclosure rules.
- Implement a clear review management policy to identify and remove non-genuine or misleading feedback.
- Plan for upcoming subscription regulations, especially around cooling-off rights, reminders, and contract cancellation flows.
- Train relevant teams—including legal, customer service, and marketing—on the new consumer law requirements and expectations.
Conclusion
UK consumer law is now more robust and enforcement-ready than ever before. Regulators are focused on eliminating hidden fees, false endorsements, and confusing cancellation procedures. For businesses, this is both a compliance challenge and an opportunity to strengthen consumer trust by making terms and practices clearer, fairer, and easier to understand.
If you need help auditing your terms and conditions, drafting compliant policies, or preparing for upcoming legislative changes, we would be pleased to assist.
Focus on UK Logistics Sector: Legal and Regulatory Update (Mid‑2025)
The UK logistics sector has experienced a wave of legal and regulatory developments in the first half of 2025. From customs changes and new employment rules to cybersecurity reform and liability exposure, businesses involved in freight, transport, warehousing, and last-mile delivery should stay alert to evolving risks and compliance requirements.
1. Post-Brexit Border Delays and Uncertainty
The final phase of the UK’s post-Brexit border regime has once again been delayed. Full import declarations and safety requirements for EU goods are now expected to come into force by early 2026, prolonging uncertainty for logistics operators managing cross-border flows.
What this means for you:
Maintain flexibility in customs processes and prepare for last-minute regulatory changes. Contingency planning remains essential.
2. Low-Value Import Reforms on the Horizon
The government is currently reviewing whether to remove the duty exemption for imported goods valued under £135. While no firm decision has been made, this potential change could significantly impact e-commerce and parcel operators who rely on frictionless low-value imports.
Impact on logistics firms:
If implemented, this reform would create a larger volume of customs declarations, slowing delivery times and increasing compliance costs.
3. Proposed Freight Crime Legislation
Parliament is considering new legislation that would formally criminalise freight theft and enhance protection for delivery drivers. The proposed law includes stronger penalties and clearer categorisation of theft from commercial vehicles.
Business response:
Review and strengthen supply chain security, particularly around overnight parking, warehouse storage, and driver safety procedures. Ensure your insurance cover aligns with rising freight crime risks.
4. Cybersecurity in the Supply Chain
Draft legislation is expected later this year to strengthen cybersecurity rules for essential supply chain and logistics providers. It’s anticipated that certain operators will be required to report cyber incidents, maintain up-to-date digital infrastructure, and adopt specific resilience measures.
What to do now:
Assess current cybersecurity policies and training. Ensure your IT and operational teams are ready for stricter standards around digital threat response and incident disclosure.
5. Increases in Wages and Employment Costs
From April 2025, the National Minimum Wage has risen to £12.21 per hour for workers aged 21 and over. Employer National Insurance contributions have also increased. In addition, recent employment law changes are tightening rules around dismissals and contract variations, particularly concerning “fire and rehire” practices.
Implications:
Businesses must factor rising labour costs into budgets and review internal HR policies to remain compliant with evolving employment standards.
6. Transport Manager Certification and Licensing Changes
A transition period is currently underway for transport managers with long-standing experience but without formal qualifications. Until May 2025, such managers may qualify through “acquired rights” without sitting exams. After this date, a Certificate of Professional Competence (CPC) will be mandatory for all new transport managers.
Recommended action:
Logistics operators should audit their compliance with operator licensing requirements and encourage uncertified staff to obtain the necessary qualifications.
7. Expanding Product Liability Risks
Although UK law hasn’t yet followed the EU’s recent expansion of product liability rules, UK logistics firms involved in fulfilment or acting as de facto importers could still face increased exposure. Under the EU's model, logistics and warehousing providers may be liable for defective products they handle or deliver.
What this means for your contracts:
Logistics providers should ensure their commercial agreements include clear limitations of liability and adequate indemnity provisions. Insurance coverage should be reviewed to reflect emerging risk areas.
8. Market Consolidation and Competition Oversight
A major merger between two large UK parcel delivery companies is currently under investigation by the Competition and Markets Authority. If approved, the deal could reshape the competitive landscape in e-commerce logistics.
What to watch:
Mergers and acquisitions in the logistics sector may impact pricing, service levels, and subcontracting opportunities. Stay informed and review your competitive positioning accordingly.
Summary: What UK Logistics Operators Should Prioritise
- Customs & Border Changes:
Stay flexible and monitor the timing of post-Brexit border controls. Prepare for updated safety and security declaration requirements. - Freight Theft & Security:
Review your exposure to freight crime. Update driver safety protocols, parking procedures, and cargo security arrangements. - Cybersecurity Requirements:
Strengthen internal cybersecurity systems. Train staff to identify risks and prepare for forthcoming incident reporting obligations. - Employment Law Compliance:
Adjust budgets for increased wage and National Insurance costs. Review HR policies, especially around dismissals and contract variation. - Licensing & Certification:
Ensure all transport managers are qualified by May 2025 or meet the "acquired rights" criteria. Support CPC training where needed. - Liability Risk Management:
Revisit logistics and fulfilment contracts to manage product liability risks. Ensure your insurance reflects evolving responsibilities. - Market Consolidation:
Track developments in industry mergers. Assess how changes in courier market structure may impact your pricing, partnerships, or operations.
Conclusion
The legal environment for UK logistics is becoming more complex, with a renewed focus on compliance, transparency, and operational responsibility. From customs declarations to cyber resilience and employment law, logistics businesses must stay proactive. Legal reviews, risk assessments, and staff training are now essential tools for navigating the evolving regulatory landscape.
If you would like support with updating contracts, reviewing licensing obligations, or conducting a risk audit tailored to your logistics operations, we’re here to help.