Schedule 20 banned commercial practices come into force

The 32 commercial practices listed in Schedule 20 of the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025 by S.I. 2025/272¹. The schedule is headed "Commercial practices which are in all circumstances considered unfair"¹. Section 225 of the Act states that "Unfair commercial practices are prohibited", and a practice is unfair if it is likely to cause the average consumer to take a transactional decision they would not otherwise have taken, or if it is listed in Schedule 20².

The banned list covers false claims about accreditation and endorsements, including "Claiming to be a signatory to a code of conduct when the trader is not" and "Displaying a trust mark, quality mark or equivalent without having obtained the necessary authorisation"¹. It also covers bait advertising, where a trader invites a purchase at a specified price having "reasonable grounds for believing that it will not be possible" to supply at that price in reasonable quantities for a reasonable period, and does not disclose that fact¹. Falsely stating that a product is available for a limited time only, to force an immediate decision, is listed, as is describing a product as "gratis", "free" or "without charge" where the consumer must pay anything beyond the unavoidable cost of responding and collecting or paying for delivery¹.

On reviews, the schedule bans "Submitting, or commissioning another person to submit or write" a fake consumer review or one that conceals that it was incentivised, and defines a fake review as one that "purports to be, but is not, based on a person's genuine experience"¹. Publishing reviews in a misleading way includes "failing to publish, or removing from publication, negative consumer reviews whilst publishing positive ones (or vice versa)"¹. Other listed practices include pyramid promotional schemes, prize promotions that do not award the described prizes, creating the impression a consumer cannot leave premises until a contract is formed, persistent and unwanted solicitations, requiring irrelevant documents from an insurance claimant or failing systematically to respond to correspondence in order to dissuade a claim, direct appeals to children in advertisements, and supplying unordered products and demanding payment¹.

The Consumer Protection from Unfair Trading Regulations 2008 are revoked². Enforcement is the duty of every local weights and measures authority in Great Britain, and of the Department for the Economy in Northern Ireland; the Competition and Markets Authority may also enforce the chapter². A trader commits an offence if it engages in an unfair commercial practice involving a misleading action, punishable on indictment by up to two years' imprisonment, a fine, or both⁴.

Why it matters for households

The provisions apply to traders dealing with consumers, defined as individuals acting for purposes wholly or mainly outside their business². Consumers have rights of redress where a prohibited practice, meaning an unfair commercial practice involving a misleading action or an aggressive practice, meets four conditions². Those rights are a right to unwind a relevant contract or consumer payment, a right to a discount, and a right to damages for financial loss, distress or physical inconvenience or discomfort². A consumer with such a right may bring a claim in civil proceedings to enforce it⁴. Where a trader supplies products a consumer did not request, the consumer is exempted from any obligation to pay for them, and the absence of a response does not constitute consent².

Which? reports that the right to undo a contract and receive a refund applies if claimed within 90 days of entering into the contract, that a percentage discount reflects the seriousness of the misleading action, and that damages may be sought for actual financial loss, or for alarm, distress or physical inconvenience⁵. It adds that these rights require showing a misleading action was a significant factor in encouraging the purchase⁵. Which? also states there is no ombudsman for complaints about a retailer, and that a local trading standards department addresses the issue with the retailer rather than recovering money⁵.

What happens next

No further commencement dates for these provisions are given in the sources. The legislation.gov.uk record notes outstanding changes not yet applied, including the insertion of section 151(1)(ha) by 2026 c. 18¹. Which? advises consumers who believe misleading advertising has occurred to contact their local trading standards department, and notes that enforcing rights may require court action if a retailer refuses⁵.