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Unfair contract terms: the CMA publishes updated guidance
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Fusion42 · 28 July 2026 · Fusion42 review
The UK CMA published updated guidance on unfair contract terms under the Consumer Rights Act 2015, with streamlined rules and practical examples. The guidance carries enhanced enforcement teeth under the DMCCA 2024, with the CMA already investigating potentially unfair terms and flagging unilateral charge clauses, refund reductions, and blanket security deposit retention as high-risk areas.
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The CMA now has direct financial penalties for unfair contract terms and has just published a clearer map of which ones it will prosecute—unilateral charges, refund reductions, and deposit holds are explicitly flagged as high-risk. Any business charging customers after sale needs to audit its terms immediately; the CMA is already investigating.
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