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The Competition and Markets Authority has published its draft Annual Plan for 2026-27, signalling a
year of increased focus on consumer protection.

While still subject to consultation, the draft Annual Plan gives
a clear steer on the CMA’s priorities for the year ahead.
We’ve blogged separately about the CMA’s new consumer enforcement powers under
the Digital Markets Competition and Consumers Act 2024. The
draft plan commits the CMA to implementing this new enforcement
regime and to double down on clear breaches of the law,
particularly in areas of essential household spend.

The CMA’s overarching goal is simple, to “put money
back in people’s pockets” while supporting fair
competition. It intends to use its new enhanced powers to deliver
this.

The consultation on the draft Annual Plan is open until 18
February 2026, with the final version due in March 2026.

The big picture

This plan is the “first detailed implementation
step” under the CMA’s 2026-2029 Strategy, which puts
“championing consumers” at the heart of driving economic
growth and improving household prosperity. The CMA wants people to
trust the markets they buy from and for fair-dealing businesses to
compete on a level playing field.

A central part of the CMA’s strategy is its transformational
“4Ps” operating model: pace,
predictability, proportionality and process.
The CMA says it will embed these principles in its consumer
protection work by actively streamlining cases to focus on the most
important concerns and by publishing regular information about
investigation progress including timings and next steps.

Where the CMA will put its enforcement energy

While the CMA says it will help businesses understand the new
rules and sort out problems early, it is also clear that where the
law is certain, and the harm is serious, it will not hesitate to
act decisively.

Priority also goes to tackling “egregious practices”
(i.e. practices that are obviously and seriously wrong),
including:


providing objectively false information to consumers;

aggressive sales practices that prey on vulnerable
consumers;

banned practices, such as fake reviews;

hidden fees; and

clearly imbalanced and unfair contract terms (e.g. unfair exit
charges).

The CMA commits to progressing its first investigations under
the new regime with a focus on price transparency and online choice
architecture, in sectors such as secondary ticketing, homeware and
personal fitness. It will also drive sector-wide change by issuing
advisory letters, highlighting compliance risks and encouraging
fixes without the need for a formal investigation.

What this means for consumer-facing brands

Consumer facing businesses should check their customer journeys
for price transparency and to ensure there are no design choices
that could unfairly steer or mislead consumers. Now is the time to
get compliant!

Given the explicit focus on “cost-of-living”
pressures, businesses should also expect closer scrutiny of pricing
claims, how add-ons and options are presented, and whether key
terms are fair, especially when operating in sectors that are key
to household budgets.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.