The DMCCA 2024: the CMA can now fine 10% of turnover for greenwashing
Since 6 April 2025, the Digital Markets, Competition and Consumers Act 2024 (DMCCA) has let the Competition and Markets Authority decide for itself that a business has broken consumer protection law — including with a misleading environmental claim — and impose a fine of up to £300,000 or 10% of the business's worldwide annual turnover, whichever is greater, without first going to court. There is no standalone "greenwashing offence": misleading green claims are caught through the DMCCA's general ban on unfair commercial practices, read with the CMA Green Claims Code. Only a court can ultimately decide a breach, so a claim that fails the Code is best treated as high-risk rather than automatically unlawful.
What actually changed on 6 April 2025
The Green Claims Code has existed since 2021, and the underlying rule that businesses must not mislead consumers is older still. The change the DMCCA made is about enforcement teeth, not new prohibitions.
Before the DMCCA, if the CMA thought a business was making misleading claims it generally had to persuade a court, which was slow. Under Parts 3 and 4 of the DMCCA — both in force from 6 April 2025 — the CMA gained direct enforcement powers: it can investigate, decide that consumer law has been broken, order the business to stop, and impose a monetary penalty itself. A court challenge is possible after the fact, but the CMA no longer has to win in court before acting.
The numbers
For an infringement of consumer protection law, the DMCCA sets the maximum penalty at the greater of £300,000 or 10% of the business's worldwide annual turnover. There are separate penalties for procedural failures — for example, not complying with an information notice or breaching an undertaking or direction the CMA has given. For a large business, the 10%-of-global-turnover ceiling is the figure that concentrates minds.
General information, not legal advice. This explains the DMCCA 2024 enforcement regime in general terms. It is not legal advice, and only a court can decide whether a specific claim breaches the law. The maximum penalty is a ceiling, not a tariff — actual outcomes depend on the facts.
Where "greenwashing" fits in the Act
There is no section of the DMCCA headed "greenwashing." Misleading environmental claims are caught by the Act's general prohibition on unfair commercial practices — specifically misleading actions (giving false information, or true information presented in a way that deceives) and misleading omissions (leaving out material information the consumer needs). The unfair-trading provisions sit in Part 4 of the Act. The CMA Green Claims Code is the guidance that shows how those general rules apply to environmental claims — which is why a claim that fails the Code's six principles is a claim at real risk under the DMCCA.
Is the CMA actually using these powers?
Yes — the regime is live, not theoretical. In November 2025 the CMA announced its first consumer-protection investigations using the new direct-enforcement powers. Those opening cases focused on online pricing practices rather than environmental claims, but they confirm the CMA is willing to use the powers, and its published green-claims work (the fashion-sector undertakings in 2024, and its scrutiny of environmental claims in fast-moving consumer goods) shows green claims remain firmly on its agenda. We describe only what the CMA has itself published; we don't attribute specific green-claims fines to the DMCCA that the CMA has not announced.
Why this is a today problem, not a 2026 project
If you also sell into the EU, you may be preparing for the EU's Empowering Consumers Directive, which switches on in September 2026. That is a separate regime with a future date. The UK position is the opposite: there is no future switch-on to wait for. The DMCCA regime is already live, and there is no grace period for claims already on shelves — a misleading green claim on your pack today is enforceable today. That makes reviewing your live claims a present task, not a diary entry.
Frequently asked questions
How much can the CMA fine a business for a misleading green claim?
Up to £300,000 or 10% of worldwide annual turnover, whichever is greater, for a consumer-protection infringement. Separate penalties apply for failing to comply with information notices or directions.
When did the CMA's direct enforcement power come into force?
On 6 April 2025, when Parts 3 and 4 of the DMCCA 2024 came into force. From that date the CMA can decide a business has breached consumer law and fine it directly, without first going to court.
Does the DMCCA specifically ban greenwashing?
No standalone greenwashing offence exists. Misleading environmental claims are caught by the general prohibition on unfair commercial practices — misleading actions and omissions — read with the CMA Green Claims Code. Only a court can decide an actual breach.
Sources
- Digital Markets, Competition and Consumers Act 2024 — Part 3 (enforcement of consumer protection law, incl. the CMA's direct enforcement powers and monetary penalties) and Part 4 (consumer rights; Chapter 1, "Protection from Unfair Trading", ss. 224–252). In force 6 April 2025. legislation.gov.uk/ukpga/2024/13
- CMA Green Claims Code (2021) — the guidance that applies the unfair-trading rules to environmental claims. gov.uk — Green Claims Code
- CMA consumer-protection enforcement under the DMCCA — the CMA's own updates on its new direct-enforcement powers, including the first investigations opened in November 2025. gov.uk — Competition and Markets Authority
Content current as of 9 July 2026. Penalty levels and commencement details are law-dependent — re-check the primary source before acting on anything time-sensitive.
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