UK–EU consumer protection post‑Brexit: divergence and compliance guide to information, cancellations, price labelling, digital content and goods, subscriptions, enforcement, sustainability and unfair practices (DMCCA 2024; EU Omnibus, DSA)
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Practice notes
This Practice Note offers a high-level overview of the principal strands of divergence between UK and EU consumer protection legislation that have emerged since the UK left the EU on 31 December 2020 (IP Completion Day).
It contrasts differences across the following areas:
- consumer information and cancellation rules,
- consumer saving schemes,
- dark patterns (ie harmful online choice architecture practices),
- enforcement,
- the sale of goods, the provision of services and digital content,
- subscription contracts,
- sustainability and unfair commercial practices.
Background
Consumer protection law in the UK stems partly from assimilated EU law and partly from UK-specific law.
In many respects, Brexit had a more limited immediate effect on consumer protection because regulatory fragmentation already existed across EU Member States, and traders selling to consumers in the EU were used to taking account of particular requirements in cross‑border situations too.
While the short-term impact was modest, there have subsequently been a number of notable changes to consumer protection legislation in both the UK and the EU since IP Completion Day, allowing the UK to move away from the EU’s framework and institutions.
In this Practice Note, ‘divergence’ denotes differences in legislation, guidance, or mandated standards that have come about to date herein...
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Web page updated on 21/05/2026
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