The UK’s Digital Markets, Competition and Consumers Act (DMCCA) 2024 is now live. The Competition and Markets Authority (CMA) can fine companies up to 10% of global revenue (or £300,000) for non-compliance with the new rules.

So what does that mean for your online business? Let’s get to the part you actually care about.

What the CMA Says

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The image above is taken from the CMA’s official guidance on unfair commercial practices. It outlines how the CMA determines whether a vulnerable consumer group is being negatively impacted by a trader’s practices.

Here’s the CMA’s logic:

  • Is a group of consumers particularly vulnerable to a commercial practice (e.g. because of their age, physical or mental health)?

  • Could the trader reasonably be expected to foresee the impact of that vulnerability?

  • Would this commercial practice likely cause an average member of that group to make a different transactional decision?

Let's Talk About Your Website

One of the most immediate compliance risks for online businesses lies in your website's accessibility especially around key transactional flows like:

  • Signing up or subscribing
  • Cancelling or unsubscribing
  • Requesting refunds
  • Accessing customer service

Accessibility & Vulnerable Groups

Let’s run the CMA’s test with a common example: people with visual impairments trying to cancel a subscription.

  • Is this a vulnerable group?

    ✅ Yes, people with physical disabilities are explicitly identified as vulnerable consumers.

  • Could the trader be expected to foresee the impact?

    ✅Yes, accessibility standards (like WCAG 2.1) have been best practice in web development for over a decade.

  • Does the commercial practice affect this group?

    ✅ Yes, if your unsubscribe flow doesn’t work with screen readers or keyboard navigation, the average person in this group could be misled or prevented from cancelling.

That’s a full match on the CMA’s unfair practice test.

Overly Complicated Design & Age Discrimination

Now let’s run the CMA’s test with another common but overlooked example: overly complicated user interfaces, especially those that confuse or overwhelm older users trying to complete a transaction.

  • Is this a vulnerable group?

    ✅ Yes, older adults are explicitly considered vulnerable under consumer protection law — particularly if cognitive load or unfamiliarity with tech affects decision-making.

  • Could the trader be expected to foresee the impact?

    ✅ Yes, there's decades of research on age-related usability challenges, and design best practices for older users are well-established (e.g., Nielsen Norman Group guidelines).

  • Does the commercial practice affect this group?

    ✅ Yes, complex UI patterns — like hidden buttons, aggressive upsells, or multi-step cancellations — can lead older consumers to give up, subscribe unintentionally, or miss key refund windows.

That’s another full match on the CMA’s test for unfair commercial practices.

So, How Do You Fix It?

  • Start by reviewing our guide on common accessibility fixes that your developers should already know.
  • Check your designs for Scroll depth, click depth, mouse movement and dark patterns.
  • Better yet book a full audit of your key transactional flows. We’ll review your site against UK & EU compliance standards, focusing on risk areas the CMA will scrutinize first.

If you want to avoid fines (and just do the right thing), it’s worth getting this right now — before regulators or class actions knock on your door.