The 2026 Consumer Law Landscape for Leisure & Tourism: The Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) represents a significant shift in consumer protection for all businesses, including those in the leisure and tourism sector.
The unfair commercial practices provisions within Chapter 1 of Part 4 came into force on 6 April 2025, with a clear focus on transparency, fairness and ensuring consumers are able to make informed transactional decisions.
For leisure and tourism operators, this places particular scrutiny on the purchase or booking journey, including how pricing, key information and terms are presented at the invitation to purchase stage.
The rules apply to any consumer facing purchase including self-catered holiday bookings, hotel bookings, attraction tickets and events.
Key Compliance Risks: the areas operators need to address
Three of the core areas operators need to address are:
- Pricing – Ensuring headline prices are clear, complete and transparent from the start of the booking journey.
- Reviews and advertising – Making sure promotional content and consumer reviews are fair and not misleading.
- Terms & material information – Giving consumers material information up front and ensuring booking terms are clear, accessible and available before they decide to book.
Importantly, the Competition and Markets Authority (“CMA”) now has direct enforcement powers, including the ability to issue fines of up to £300,000 or 10% of turnover.
Against this backdrop, operators need to ensure that their booking journey is complaint.
Transparent Pricing: drip pricing, fees and pressure selling
A central principle of the DMCCA is that the headline price must be the total price payable, including all mandatory fees, taxes and charges. This total price is material information and must be provided at the invitation to purchase stage, being the start of the booking journey.
“Drip pricing”, where additional mandatory charges are revealed later in the booking journey, is prohibited. If a consumer must pay a charge in order to complete a booking, it needs to be included in the initial headline price.
Where it is not possible to calculate the total price at the outset (for example, due to variable stay duration or guest numbers), operators must provide consumers with sufficient information to calculate the price themselves.
A clear distinction must also be maintained between mandatory charges and optional extras. Optional extras should not be pre-selected by default, as this risks amounting to harmful online choice architecture (OCA), which may pressure consumers into unintended purchases.
Overall, operators should ensure that pricing is clear, complete and accurate at the earliest possible stage, and that promotional messaging does not distort consumer decision‑making.
Reviews and Advertising: avoiding misleading practices
The DMCCA introduces strengthened rules around consumer reviews and advertising practices, including a specific prohibition on fake and misleading reviews.
Operators must ensure that:
- they do not commission or publish fake reviews;
- any incentivised reviews are clearly disclosed; and
- reviews are presented accurately and not selectively edited, withheld or manipulated.
There is also a positive obligation on businesses to take proportionate steps to detect and remove fake or misleading reviews. This includes having internal processes in place for monitoring reviews and an external facing policy.
Booking Terms: getting the fundamentals right
The booking journey must enable consumers to access and understand the terms on which they are contracting before making a purchase. Terms need to be:
- accessible;
- transparent and fair; and
- available before the consumer decides to book.
Best practice includes ensuring that terms are visible throughout the booking journey (for example, via footer links, on product pages and at the checkout stage), so that consumers can make an informed decision.
Next Steps: reviewing your booking journey
Is your booking journey giving consumers all the information they need, at the right time, and in the right way?
With the CMA’s enhanced enforcement powers and increased scrutiny on unfair commercial practices, now is the time to review your website and purchasing process. Our Commercial Practices Purchase Journey Audit identifies areas of risk and provides practical, commercially focused recommendations to help you achieve compliance and improve the consumer experience.
If this topic is something you require assistance with, please contact our Intellectual Property, Data Protection & Technology team.