The UK’s Digital Markets, Competition and Consumers Act: how direct “10 % turnover” fines are rewriting global compliance rules

When the Digital Markets, Competition and Consumers Act 2024 entered into force on 6 April 2025, it quietly shifted enforcement in the United Kingdom from slow, court‑based proceedings to an administrative regime in which the Competition and Markets Authority can decide a breach of consumer law, issue an infringement notice and levy a penalty of up to ten per cent of a firm’s worldwide annual turnover—or an escalating daily fine—without first litigating in the Competition Appeal Tribunal. The change is not cosmetic: powers that once required years of litigation under the Enterprise Act 2002 now sit with officials who can act in weeks, compelling rapid undertakings, publication of corrective statements and financial remedies that equal the largest antitrust penalties in Europe. The Act reaches beyond Big Tech by adopting an effects‑based jurisdictional hook: any business whose online conduct produces a “material impact” on UK consumers falls within scope, whether or not it is incorporated or headquartered in Britain. That extraterritorial clause is already felt. In June 2025 Amazon closed a four‑year investigation into fake reviews by promising structural reforms; the CMA signalled that under the new Act the same behaviour could have attracted an immediate turnover‑based fine instead of a negotiated pledge, underscoring how the legal burden has flipped from regulator to trader . Because the statute also modifies the Competition Act 1998—introducing ex‑ante “strategic market status” duties that mirror, but exceed in territorial reach, the EU’s Digital Markets Act—digital platforms must now embed compliance for self‑preferencing, data portability and drip‑pricing at product‑design stage, not during late‑stage defence. For exporters in emerging markets, including Iraqi e‑commerce ventures that advertise on UK‑facing marketplaces, the risk is no longer abstract: a single misleading endorsement aimed at British consumers can trigger a penalty that dwarfs annual profit. Prudent firms are therefore adopting quarterly marketing audits, evidence‑traceability protocols for user reviews and contingent‑liability disclosures in financial statements. By converting consumer protection into a high‑velocity administrative tool, the UK has created a de facto global standard; companies that adjust early gain certainty and reputational advantage, while laggards face sanctions that arrive faster than any court summons. In practice, the Act rewards anticipatory compliance and punishes reactive defence, making legal foresight a core element of commercial strategy in every jurisdiction that sells—even digitally—into Britain’s market .