On 14 October 2026, the UK’s main consumer law regulator, the Competition and Markets Authority (CMA), issued three fines totalling £6 million and ordered £440,000 in refunds for consumers in relation to breaches of consumer law.

Time-limited offers: Wayfair

Wayfair ran ‘Daily Deals’ and 24-hour ‘Flash Deals’ on its website, reinforced by slogans such as ‘Here Today, Gone Tomorrow’ and countdown timers – techniques usually implemented to create hype and encourage shoppers to act fast to secure the best price. The regulator found that a significant number of these products stayed on sale at the same (or lower prices) once the advertised deadline had passed. The CMA concluded that presenting offers in this way unfairly pushed consumers into buying products quickly when there was no need to rush. The CMA issued a £4.8 million fine to Wayfair.  

Time-limited offers and pre-ticked checkboxes: Appliances Direct

The CMA found that Appliances Direct was signing customers up automatically (without their express consent) to paid extras, such as an appliance recycling scheme and an installation service. The Consumer Contracts Regulations 2013 require that a business must obtain a consumer’s express consent to any additional add-on payments; pre-ticked boxes are not sufficient for this purpose.

Separately, the retailer displayed countdown banners on product pages advertising £10 – £25 discounts as only available for a limited time. However, the CMA found the same discount codes re-surfaced several times over the following days. The CMA considered that this unfairly pressurised consumers into making purchases. Appliances Direct was fined £1.2 million and ordered to repay around £432,000 to affected customers in relation to the additional charges.

Mandatory joining fee: Gold’s Gym

The CMA found that Gold’s Gym, a London-based UK gym franchise, omitted the joining fee from the headline price quoted to consumers, or otherwise failed to show the total price in a clear way. The regulator found that these practices infringed the ‘drip pricing’ rule under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). Under those rules, an “invitation to purchase” omits material information (in breach of consumer law), if it fails to state the total price of a product, which must include any fees, taxes, charges or other payments the consumer will necessarily incur. Gold’s Gym has been ordered to refund consumers £9,220 and has been fined £45,000.

Key takeaways

• Growing scrutiny: The CMA has been flexing its muscles since the introduction of direct fining powers under the DMCCA. In the last 18 months, it reports issuing fines of more than £12 million and ordering nearly £2.4 million in refunds for consumers. Online sales tactics are a live risk area, and enforcement in this space is ongoing. Business-to-consumer brands should be routinely checking their marketing claims and customer purchase journeys in light of this increasing scrutiny.
• Audit time-limited offers: Pressure selling and false urgency have been on the CMA’s radar for some time (at least since the March 2023 pressure selling guidance). If a deal is marketed as ending on a specific date, make sure it genuinely does not continue on discount (or a comparable discount) after that date. This type of practice is also relatively easy for the CMA to spot and evidence on its own initiative – simply by monitoring a website and recording prices over time.
• Remove pre-ticked boxes: Any optional extras (recycling, installation, insurance, etc.) must require the customer to actively opt in; default opt-ins are not sufficient consent.
• Show the total price upfront: Mandatory fees, including joining or admin fees, must be included in the headline price shown to the customer, and not revealed later in the purchase journey.

AUTHORS

Sophie Lewis Associate

Sophie Lewis is an associate specialising in commercial and regulatory work in the firm's interactive entertainment practice.

Sophie Lewis is an associate specialising in commercial and regulatory work in the firm's interactive entertainment practice.

Sophie advises video game studios, developers, publishers and platforms on digital regulation and compliance. Her practice covers consumer law, advertising regulation, AI law, age ratings, loot boxes, gambling regulation, virtual currencies, micro-transactions, subscription models and online safety. Sophie has direct experience managing regulators, including responding to ASA investigations and a six-month secondment in the Consumer Enforcement Team at the UK's Competition and Markets Authority. She often coordinates multi-country projects for clients expanding internationally, translating complex regulatory frameworks into practical compliance plans.

She also supports clients on a wide spectrum of commercial contracts, including development agreements, publishing agreements, IP licences, EULAs, terms and conditions, influencer agreements, talent contracts, subscription agreements, NDAs and other service agreements. Sophie has a keen personal interest in video gaming and is passionate about supporting this sector. She regularly provides training on games regulation and breaks down complicated compliance issues for a range of audiences, from developers to legal teams and business operations.

Sophie is recognised as a key lawyer and leading associate in Legal 500 for video games.

Sacha Wilson Partner

Sacha Wilson is a commercial and regulatory lawyer with particular expertise in advertising, digital and data privacy. He is head of the firm’s cross-departmental advertising practice.

Sacha Wilson is a commercial and regulatory lawyer with particular expertise in advertising, digital and data privacy. He is head of the firm’s cross-departmental advertising practice.

Sacha advises clients from a variety of sectors, including some of the world’s best known brands, agencies and platforms. He is ranked for advertising and digital media in both The Legal 500 and Chambers and Partners and is recognised as one of the UK’s leading advertising lawyers.

Sacha advises on a range of commercial transactions and has particular expertise in advertising-related agreements (such as creative agency, media planning and buying, production and brand partnerships). He is particularly well known for his expertise in digital marketing and adtech.

Sacha also has expertise in general advertising compliance (including prize promotions, native advertising and influencer marketing) as well as ecommerce and online consumer regulations.

Sacha also works within the firm’s retail and technology practices and regularly advises well-known retail brands on a range of retail-focused commercial agreements including distribution, licensing, and franchise agreements, as well as clients across a range of industries on tech focused agreements such as software development, SaaS, and IT services contracts.

In relation to data privacy, Sacha has advised on all the key compliance areas, and has worked with a large number of clients on their data protection compliance programmes. He has particular expertise in the data privacy aspects of marketing, adtech and digital media. He frequently advises on the compliance aspects of adtech vendor arrangements, programmatic advertising, and mobile apps.

Sacha also has expertise in the legal issues associated with AI, particularly in the context of advertising and marketing. He regularly advises clients on the privacy, IP, contractual and regulatory issues associated with the use and deployment of AI for a range of purposes in the advertising and marketing industries.