AutoSmart GuidebooksWhat this guidebook covers
Since April 2025, the Digital Markets, Competition and Consumers Act lets the CMA decide consumer law breaches itself and fine directly, up to 10% of global turnover, without going to court. Its first fine, in April 2026, was £4.2 million over a £3 hidden fee.
This guidebook covers 6 consumer standards with 18 checkpoints: all-in pricing with no drip fees, honest reviews, accurate vehicle descriptions, the right to reject and repair, 14-day cancellation for distance sales and no pressure selling.
The 6 consumer protection standards
Open a standard to see the law behind it, what is checked, what it can cost and the evidence. Ideal fix times are counted from audit submission.
CON-01All-in pricing, no drip fees72 hours
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · DMCCA s.226–230 misleading actions and omissions · material pricing information
- What we check
- Every advertised car price includes all mandatory fees (admin, preparation, delivery if unavoidable), so the price shown is the price the customer pays.
- What it can cost
- A £3 fee cost the AA £4.2M. For a dealer group, 10% of turnover is the ceiling.
- Evidence
- Screenshots + invoice sample
CON-02Honest reviewsImmediate
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · DMCCA Schedule 20 banned practices: fake reviews, concealed incentivised reviews, misleading presentation of reviews
- What we check
- The dealership never writes, buys or filters reviews, doesn't hide negative ones, and discloses any incentive given for a review.
- What it can cost
- A banned practice needs no proof of harm: straight to up to 10% of global turnover.
- Evidence
- Review policy + platform settings
CON-03Accurate vehicle descriptions72 hours
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · DMCCA s.226 misleading actions · CRA 2015 s.11 goods to match description
- What we check
- Adverts and descriptions accurately state mileage, service history, previous keepers, write-off category, known faults and outstanding recalls.
- What it can cost
- A misleading description can bring a CMA fine, a Trading Standards prosecution and the car coming back.
- Evidence
- History reports + listings
CON-04Right to reject and repair honoured72 hours
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · Consumer Rights Act 2015 s.9–24: satisfactory quality, 30-day right to reject, repair or replace, final right to reject
- What we check
- Faults reported within 30 days get a full refund if the customer wants one. After that, one repair or replacement, then a final right to reject. Faults in the first 6 months are presumed to have been there at sale.
- What it can cost
- Refusing statutory rights leads to court claims, Trading Standards action and CMA scrutiny of the whole process.
- Evidence
- Complaint files + sales docs
CON-05Distance sales: 14-day cancellation7 days
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · Consumer Contracts Regulations 2013: pre-contract information and 14-day cancellation for distance and off-premises sales
- What we check
- Cars sold online, by phone or delivered to the customer come with the pre-contract information and a clear 14-day cancellation right, with refunds within 14 days.
- What it can cost
- Missing cancellation information extends the right to 12 months: the customer can hand the car back for most of a year.
- Evidence
- Distance sale files
CON-06No pressure selling72 hours
- The law
- Digital Markets, Competition and Consumers Act 2024 (Part 4, in force 6 Apr 2025) · Consumer Rights Act 2015 · DMCCA s.227 aggressive practices · Sch.20 false urgency and limited-time claims
- What we check
- No fake deadlines, invented rival buyers, false stock claims or pressure tactics. Offers that say they end, really end.
- What it can cost
- An aggressive practice is both a civil breach (10% turnover) and a criminal offence.
- Evidence
- Mystery shop + scripts
How to run a UK consumer protection audit, step by step
- Confirm what applies. Sales to consumers and sole traders are covered; business-to-business sales such as fleet are outside most of these protections.
- Walk the site, standard by standard. Score each of the 18 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Compare advertised prices with what customers pay at the desk, and check how reviews are collected and shown.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: adverts and price lists, invoices, the review process, vehicle descriptions and cancellation records.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 7 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals
- Sales and marketing managers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
