The Digital Markets, Competition and Consumers Bill has completed its passage through the House of Lords and now returns to the House of Commons for what may be final approval.

The UK government has made some changes to the Bill concerning subscription contracts, fake reviews and drip pricing.  The CMA asked for changes to the law on secondary ticketing, which the government rejected, but interestingly the Bill now also contains provisions on secondary ticketing.

So what has changed in the Bill?

Subscription contracts
A significant change has been made to the rules: traders must enable consumers to cancel their subscription contracts “in a way which is straightforward” (rather than “in a single communication”). The UK government has also confirmed that it will put forward proposals to allow reminder notices to include promotional offers or other information, rather than requiring them to be provided separately from other information. It has also said it will consult on new rules on what consumers must pay if they cancel a subscription contract during the cooling-off period.

The Bill also contains powers for the government to make the Gift Aid rules compatible with the subscription rules. Membership subscriptions can qualify for Gift Aid if they only pay for membership of the charity and do not include personal use of the charity's premises or services. The 14-day cancellation right under the Bill automatically implies a repayment condition and this might have meant that charities that rely on membership subscriptions having Gift Aid claims rejected. 

The new rules on subscription contracts will apply from the spring of 2026, to allow businesses time to prepare. This is an extension from an earlier date of October 2025.

Fake reviews
With regard to fake reviews, the government recently consulted on, and agreed to introduce the following amendments which were tabled in the Lords.  The following practices will be considered unfair commercial practices:

  • submitting a fake review, or commissioning another person to write and/or submit a fake review or a review that conceals that it has been incentivised;
  • publishing consumer reviews, or consumer review information, in a misleading way; and
  • publishing consumer reviews, or consumer review information, without taking such reasonable and proportionate steps as are necessary for the purposes of preventing the publication of (i) fake consumer reviews, (ii) consumer reviews that conceal the fact they have been incentivised, or (iii) consumer review information that is false or misleading, and removing any such reviews or information from publication.

Most banned practices attract criminal liability, but the new practices on fake reviews will be subject to civil penalties.

Drip pricing
The Bill also introduces new rules about so-called “drip pricing” practices. Drip pricing is where only part of an item’s price is shown during the early part of the consumer journey, and the total amount to be paid is revealed at or near the end of the buying process, by which time the consumer may feel committed to the purchase. This is a practice the CMA has already declared potentially harmful as part of its investigations into online choice architecture. 

Drip pricing has not been added to the list of banned practices, as with fake reviews, but is dealt with in the definition of “material information” that must be considered when assessing whether there has been a misleading action or omission. The Bill prohibits presenting a headline price that does not:

  • incorporate in the price any fixed mandatory fees that must be paid by all consumers; and
  • disclose the existence of any variable mandatory fees and how they will be calculated.

The Bill has not been amended to cover optional fees, but the government says that it will keep this under review.

Secondary ticketing
The CMA had asked for changes to the laws on secondary ticketing. The government rejected this, but the latest version of the Bill includes a new chapter on secondary ticketing,  It states that secondary ticketing facilities must not allow tickets to be listed for resale without the business/trader providing proof of purchase or title to the tickets, and resellers must not be permitted to sell more event tickets than they can legally purchase from the primary market. In addition, the face value of the resale ticket (and the trader or business’s name and trading address) must be clearly visible, in full, on the first page of the ticket and not hidden behind an icon. 

A secondary ticketing facility must make it clear to traders and businesses based overseas that they are subject to UK regulation if they sell tickets to UK consumers and target UK consumers through paid or sponsored advertisements or paid infomercials.

Next steps
The Bill now returns to the Commons. It is likely that there will be more changes before the final form of the Bill receives Royal Assent (particularly in relation to the subscription rules), but businesses will now have a clearer idea of their new obligations and when they come into force.