Cross Border Compliance: Key Issues to Watch in 2025

In 2025, the legal environment for UK internet businesses will change significantly. With the Digital Markets, Competition and Consumers Act 2024 (DMCCA) going into effect in April 2025, e-commerce businesses are dealing with significant changes to consumer protection laws and increased regulatory scrutiny. Through the DMCCA, significant aspects of UK consumer law have been improved. At the same time, businesses must cope with cross-border challenges as various EU and non-EU regulations continue to evolve following Brexit. This article examines the most significant legal issues and offers advice on how businesses can stay compliant in 2025, covering everything from the complexities of cross-border consumer protection to new bans on particular online activities and improved enforcement capabilities.

UK Consumer Law Reform: The DMCCA 2024 Act

In recent years, the DMCCA 2024 has been the most significant change to UK consumer law. Significant adjustments are made especially for the digital economy, and regulators are given more power to enforce the rules more rigorously. Digital services, marketplaces, and online retailers are all directly impacted by a number of new provisions.

New Prohibited Practices: The Act includes a list of actions that are always considered unfair (and illegal). Specifically, it forbids:

1. False or deceptive reviews: Companies are required to take precautions to guarantee that any customer reviews are authentic and are no longer permitted to host or commission false reviews or testimonials. It is even illegal for third-party services to provide phoney reviews. After a CMA investigation into fraudulent review practices, Google agreed to make major changes to its online review policy in January 2025.
2. Ignoring crucial information: A product listing or advertisement, or any other online invitation to purchase, must include all the information a buyer needs to make an informed decision. This covers, among other things, the trader’s identity, the primary features of the product, the entire cost (including all fees), and the rights of the customer (such as the ability to cancel). Importantly, it is no longer necessary to demonstrate that leaving out such information could deceive customers because doing so is now intrinsically unfair and illegal.
3. Advertising a base price and then “drip” in additional charges (taxes, fees, and add-ons) at the point of sale is now strictly prohibited. Previously, hidden fees might have been argued to be deceptive omissions, but the new law makes it illegal to withhold the full cost upfront.
4. “Subscription Traps”: Part 4 of the DMCCA covers services that are easy to sign up for but difficult to stop. The Act calls for straightforward cancellation processes, frequent reminders before renewals, and clear pre-contract information about (some specific provisions, like some reminders for renewals, will be implemented by 2026 to give businesses time to adapt). Online companies should now review their subscription models; they should stop hiding auto-renewal clauses in fine print and making customers complete difficult cancellation processes.
5. More Powerful Enforcement: Most significantly, the DMCCA grants the CMA direct enforcement powers in the area of consumer protection. The CMA can now administratively decide whether consumer law has been broken for the first time and impose fines of up to 10% of a company’s annual global sales (or £300,000 for an individual). This is a significant change from the previous administration, when the CMA had to ask for a court order to stop unlawful activity. Violations of consumer law now carry deterrents, just like competition law. The CMA also has the power to order businesses to pay back consumers for losses. Due to these changes, UK consumer enforcement now enforces strict penalties for noncompliance, in line with the “GDPR-style”. Because the CMA has made it clear that it will use its newfound authority, companies that violate pricing, reviews, or other consumer rights regulations face severe penalties without the delays of legal action.

These legal changes require online businesses to take immediate action. Grey-area practices have been replaced by even black-and-white illegalities, and if you sell to customers in the UK, you must abide by these rules. Covertly posting unverified five-star “customer” reviews, hiding delivery costs until the very end of the checkout process, or failing to identify a seller on a marketplace will all be strictly prohibited in 2025.

Businesses should compare their websites and sales processes to the updated list of prohibited practices and promptly update any non-compliant designs or policies. UK authorities have “set a new benchmark for transparency and fairness in digital commerce” and backed it up with one of the world’s strictest enforcement regimes, signalling the end of the period of tolerance for dishonest online tactics.

CMA’s Enforcement Toolkit and New Priorities

The Competition and Markets Authority is now the primary enforcer of the new system. With a far more potent toolkit in 2025, the CMA will be able to act quickly and impose sanctions without waiting for the court to rule. Fake reviews and hidden fees are, predictably, at the top of the list of priority areas for early enforcement that it has already indicated. In April 2025, the government and CMA jointly issued a statement reaffirming that strong consumer protection not only protects consumers but also fosters fair competition by keeping dishonest companies from obtaining an unfair advantage.

The CMA’s CEO, Sarah Cardell, stressed that although the organisation will assist companies, particularly small businesses, in adhering to the regulations, those who do not “will face consequences.” During this transition, the CMA wants to be fair and provide businesses with clarity, but it will not put up with wilful disregard for the Practically speaking, we can anticipate that the CMA will target blatant infractions first—the types of actions that Parliament specifically called out.

Prime targets would include, for instance, a ticketing website that imposes unexpected service fees at the point of sale or a business that has been purchasing or fabricating phoney positive reviews for its goods. (The Competition Minister claims that the new rules shield consumers from “drip pricing” and fake reviews.

Recent enforcement actions illustrate the CMA’s direction of travel:

1. Fake Reviews: Prior to the implementation of its new powers, the CMA pressed major platforms on fake reviews in late 2023. It secured pledges from companies like Google to improve systems for detecting and punishing fraudulent reviews. The CMA said on gov.uk that fake reviews “left unchecked, damage people’s trust and leave honest businesses at a disadvantage.” The CMA may enforce remedies for such issues under the DMCCA or impose direct fines in lieu of relying on voluntary compliance. As a result, businesses should ensure that user reviews on their websites are authentic and that they aren’t contributing to the spread of fraudulent reviews (for instance, by failing to moderate obvious fakes).
2. Subscriptions and Auto-Renewals: From antivirus software to gym memberships, the CMA has long studied subscriptions that renew on their own. It used to negotiate changes with companies to make cancellations easier. Now, we anticipate CMA enforcement of “subscription traps” with unambiguous legal backing. Digital services that make it difficult to cancel or that don’t remind users to renew once those features begin may be the subject of investigations. Businesses should use simple online cancellation and clear reminder emails to avoid being an early test case.
3. Misleading Claims and Greenwashing: The DMCCA also equips the CMA to combat misleading or false environmental claims. This is in line with a larger campaign against “greenwashing” in the EU and the UK. For questionable eco-claims, the CMA has already looked into industries like fashion retail. Online companies should make sure that any sustainability claims they make on their websites, such as “carbon neutral,” “eco-friendly,” or “plastic-free”—are supported. The new law allows for the treatment of unsubstantiated claims as unfair practices. In order to establish precedents, expect the CMA to target well-known instances of greenwashing in e-commerce.

The CMA has been getting ready for its new role on the inside. Early in 2025, it released guidelines outlining how it would apply its direct enforcement authority, incorporating elements of its competition law processes (such as providing settlement discounts in exchange for cooperation). Additionally, the CMA is “carefully considering and preparing for [its] first cases” under the new regime, which means that companies that are in the CMA’s sights may soon face investigative action.

Compliance takeaway

In the UK, the risk of consumer law is now comparable to that of antitrust and corporate criminal laws. A violation of consumer protection laws should be taken as seriously by company boards and legal departments as a price-fixing or privacy violation. The CMA has stated clearly that its new enforcement will increase consumer trust and the confidence of fair-dealing businesses that they will not be undercut by criminals.

Companies that make compliance investments will be safeguarded, while those that don’t risk quickly being hit with orders and fines totalling millions of pounds. To put it briefly, maintaining honest reviews, open pricing, and simple consumer rights is important for levelling the playing field and preventing fines.

The Impact of Compliance on Cross-Border Commerce

Cross-border commerce has been significantly influenced by compliance requirements, especially as businesses navigate the complexities of international trade. In 2025, the global marketplace presents numerous compliance risks that can impact the ability to operate effectively across borders. Companies must ensure they are adhering to the various regulatory requirements and legal obligations that govern their operations in different jurisdictions. This entails not only understanding the local laws but also aligning them with international standards to mitigate potential legal repercussions.

Moreover, compliance in cross-border commerce is not merely about avoiding penalties; it serves as a strategic advantage. Companies that prioritise compliance can enhance their reputation and avoid reputational damage while fostering trust among consumers and partners. By demonstrating a commitment to ethical practices and adherence to regulations, businesses can differentiate themselves in a competitive global environment. Thus, the impact of compliance extends beyond mere legal obligations, influencing operational efficiency and market positioning.

Cross-Border Consumer Protection: Difficulties Following Brexit

In 2025, compliance for international online businesses will require both adherence to UK law and staying up to date with consumer protection regulations in other markets, particularly the EU. Although UK and EU consumer laws are similar (many EU reforms are mirrored in UK laws), they are not the same, and differences may increase over time.

EU developments: The EU has updated its consumer laws and passed its own “Omnibus Directive” in recent years, which EU nations have adopted. These include new information obligations and comparable prohibitions on fraudulent reviews. For example, online marketplaces are now required by EU law to disclose to customers whether the seller of a listing is a trader and whether payments or personalisation have an impact on search results.

UK-only websites might not be subject to all of these EU regulations because the UK’s DMCCA did not replicate them all. However, any UK company that sells to the EU is required to abide by them on a country-by-country basis. Furthermore, under Regulation (EU) 2017/2394, the EU’s Consumer Protection Cooperation (CPC) network has the authority to coordinate enforcement among member states and impose fines of up to 4% of global turnover for widespread violations—a power that is comparable to the UK’s 10% power, albeit slightly lower.

Tougher enforcement is the trend on both sides of the Channel. According to the Slaughter and May “horizon scanning” report, companies in the UK and EU should get ready for more public and private enforcement of consumer protection laws in 2025, particularly on topics like online choice architecture and greenwashing. In reality, the same mistake that leads to CMA action in the UK could result in a pan-EU action against a business that serves EU consumers.

Enforcement cooperation after Brexit: Since the UK is no longer a member of the EU’s CPC network, cross-border enforcement procedures have evolved. Through that network, the CMA can no longer as easily request action from an EU counterpart. Rather, agreements such as memoranda of understanding and international forums (like the International Consumer Protection Enforcement Network) are used to facilitate cooperation between the CMA and UK regulators.

Although the CMA has stated that it hopes to continue strong cross-border cooperation, enforcement may unavoidably be less efficient. A practice that is permitted in one jurisdiction might not be accepted in another, so businesses should not assume that. If they violate both regimes, they may actually be the subject of two separate investigations: one by the CMA and one by EU authorities. Meeting the highest standards in the jurisdictions where you operate is the safest course of action.

Contract enforcement and disputes

Enforcing consumer contracts and judgements internationally presents additional difficulties. The simple reciprocal enforcement of judgements between the UK and the EU has been lost since Brexit; the EU has so far rejected the UK’s bid to re-join the Lugano Convention, which permits cross-border civil judgements. This means that it can be more complicated and expensive for an online business or a consumer to enforce a judgement internationally (for instance, a UK business suing an EU supplier for indemnity, or a consumer seeking redress from a foreign online seller).

Employing arbitration agreements or making sure they take part in cross-border alternative dispute resolution programmes (like the EU’s Online Dispute Resolution platform for consumer disputes, if applicable) can help businesses reduce some of this risk. Furthermore, offering first-rate customer support and easily accessible refunds or other remedies can stop disagreements from ever reaching the point where legal action is necessary.

Challenges in Cross-Border Compliance

Navigating cross-border compliance presents unique challenges, particularly in the realm of differing regulatory compliance requirements and operational complexities. Businesses must implement rigorous compliance strategies to address varying local laws across different countries. Language barriers can hinder effective communication, while cultural nuances impact ethical practices, complicating compliance efforts. Furthermore, potential risks, such as data breaches or hefty fines, necessitate robust risk management frameworks. Developing a comprehensive compliance program that incorporates technology solutions and data analytics tools is crucial for operational efficiency and adherence to ethical standards.

Navigating Regulatory Differences

Navigating the diverse regulatory requirements and landscapes across different countries is a crucial aspect of effective cross-border compliance. Each jurisdiction enforces its own laws and regulations, creating a complex web of requirements that businesses must adhere to. This necessitates a robust risk management strategy that identifies potential compliance issues and ensures that operations align with local laws. By implementing a systematic approach to regulatory compliance, businesses can minimize legal risks and avoid costly penalties.

Moreover, regulatory compliance should not be seen as a mere checkbox exercise; it requires ongoing vigilance and adaptability. Companies must continuously monitor regulatory changes and adjust their practices accordingly. This involves establishing strong internal controls and fostering a culture of compliance within the organisation, where employees are educated about the importance of adhering to local laws and are empowered to report potential issues. Furthermore, implementing robust internal controls enhances the organisation’s ability to maintain compliance and mitigate risks effectively.

Understanding the nuances of regulatory compliance is essential for success in international operations. By prioritizing compliance and adjusting strategies to accommodate local regulations, businesses can navigate these common challenges effectively and maintain their competitive edge in the global marketplace.

Cultural and Ethical Considerations

Illustrating the CMA’s strategic direction, recent enforcement actions highlight how regulatory bodies are tightening compliance management in the UK. These actions emphasize the necessity for businesses to enhance their compliance practices to mitigate reputational risks and avoid hefty fines. As companies navigate different countries’ regulatory landscapes, adopting comprehensive risk management compliance programs becomes essential. Ensuring operational efficiency through effective risk assessment and due diligence enables better alignment with evolving legal obligations, ultimately safeguarding their international operations against potential breaches and reinforcing ethical standards across their businesses.

Overcoming Language Barriers

Language differences can pose significant challenges in cross-border commerce, particularly when it comes to compliance. Miscommunications arising from language barriers can lead to misunderstandings with regulatory authorities, contractual disputes, and potential compliance failures. To mitigate these risks, businesses must invest in effective communication strategies that ensure clarity and accuracy in all interactions, addressing any language barriers that may arise.

One approach is to employ multilingual staff or translation services to facilitate communication with international partners and regulatory bodies. This can help bridge the gap between language differences and ensure that compliance requirements are clearly understood and adhered to. Additionally, providing training and resources in multiple languages can empower employees to navigate compliance issues effectively and engage with local stakeholders.

Establishing clear channels of communication is essential for managing compliance risks. Regularly updating all parties involved about regulatory changes and compliance requirements can prevent misunderstandings and foster a culture of transparency. By overcoming language barriers, businesses can enhance their compliance efforts and build strong relationships in the global marketplace.

The Impact of Differing Regional Regulations on Businesses

The impact of differing regional regulations on businesses cannot be overstated. Companies engaged in cross-border commerce must grapple with a myriad of regulatory requirements that vary significantly from one jurisdiction to another. This regulatory divergence can create challenges, including increased compliance costs, operational inefficiencies, and potential legal liabilities.

To mitigate these challenges, businesses must adopt a proactive approach to compliance that involves staying informed about regional regulations and tailoring their operations accordingly. This requires conducting thorough market research to understand the regulatory landscape in each target market and ensuring that business practices align with applicable local laws and regulations. By prioritizing compliance, companies can avoid costly penalties and maintain their reputation in the global marketplace.

Furthermore, the ability to adapt to differing regional regulations can enhance operational efficiency. By implementing standardized compliance processes across jurisdictions, businesses can streamline their compliance processes and reduce the risk of non-compliance. This not only facilitates smoother cross-border transactions but also positions companies for success in an increasingly competitive global marketplace.

Adapting Strategies

Adapting strategies to meet the challenges of cross-border compliance is essential for businesses operating in multiple jurisdictions. A flexible approach that considers the unique regulatory requirements of each market can help organizations navigate compliance strategies and risks effectively. This may involve customizing products, marketing materials, and service offerings to align with local regulations and consumer expectations.

Moreover, investing in compliance technology solutions can streamline operations and enhance efficiency. Advanced solutions can help automate compliance processes, track regulatory changes, and provide real-time insights into compliance performance. By leveraging technology, businesses can stay ahead of evolving regulations and minimize the risk of non-compliance.

Additionally, fostering a culture of compliance within the organization is crucial. This involves training staff on compliance requirements and encouraging open communication about potential compliance issues. By creating a supportive environment where employees feel empowered to address compliance concerns, businesses can enhance their ability to adapt to regulatory changes and maintain a strong compliance posture.

Managing Compliance Across Supply Chains

Managing compliance across supply chains is a critical aspect of cross-border commerce. As businesses engage with multiple suppliers and partners in different jurisdictions, ensuring compliance with local laws and regulations becomes increasingly complex. Companies must establish robust supply chain compliance management systems that oversee compliance efforts across the entire supply chain.

This includes conducting thorough due diligence on suppliers and partners to ensure they adhere to relevant regulations. By implementing compliance assessments and audits, businesses can identify potential compliance risks and take corrective actions as needed. Additionally, fostering strong relationships with suppliers and partners can enhance communication and collaboration around compliance efforts.

Furthermore, utilizing technology can streamline compliance management across supply chains. Automated solutions can help track compliance obligations, monitor supplier performance, and ensure adherence to regulatory requirements. By integrating compliance management into supply chain operations, businesses can mitigate risks and enhance their overall compliance posture.

2025 Compliance Advice for Internet Companies

Considering the aforementioned, online companies should take the following specific actions to resolve these legal issues:

1. Re-audit Your Customer Journey: Check your online customer journey right away for any practices that are currently forbidden, including advertising, search result displays, product pages, checkout, and post-sale communications. Anything that might be an unfair business practice should be changed or removed. For instance, remove any pre-checked consent boxes or hidden costs; make sure that all necessary information (price, seller identity, important features, and rights) is disclosed in a clear and understandable manner prior to a purchase; and confirm the legitimacy of reviews and recommendations on your website.
2. Revise Cancellation Procedures and Terms: If you provide recurring services or subscriptions, revise your user interface and terms to conform to the new regulations. Verify that the terms of cancellation and renewal are explained in detail on sign-up pages. Provide simple cancellation options, such as a few online clicks that eliminate the need for a phone call. Even though some specific DMCCA requirements begin later, demonstrating good faith compliance now will give you an advantage. Be ready to send renewal reminders in compliance with the law.
3. Train Designers and Staff: Inform your web designers, developers, and marketing teams about the new consumer protection guidelines. Many violations happen not because of malicious intent but rather because designers think more like marketers than regulators. Make sure everyone is aware that some aggressive strategies, such as using scarcity countdown timers or hiding terms in hyperlinks, may be illegal. Establishing a culture of “fair trading” compliance is essential; in the same way that businesses have developed privacy-by-design initiatives for the General Data Protection Regulation, they should also implement a “compliance by design” strategy for consumer law.
4. Follow Guidance: Pay attention to CMA communications and guidance. An Approach to Consumer Protection document detailing the CMA’s enforcement tenets has been released. Additionally, it is anticipated to provide guidelines on particular practices (for example, in 2024, it provided advice on drip pricing and fake reviews). Verify that your legal counsel or compliance officers are keeping an eye on these resources. In their reports and press releases, regulators frequently provide useful compliance advice. For instance, the CMA’s case studies on pricing algorithms contain dos and don’ts that can direct online pricing tactics.
5. Align UK and EU Compliance: If you conduct business in both the UK and the EU, make an effort to comply with both sets of regulations in the procedures you use to interact with customers. Although laws vary slightly, they all adhere to the same fundamental ideas. It may be necessary to give EU customers additional information or follow slightly different cooling-off regulations, but these can frequently be applied globally. Additionally, consistency can enhance the client experience. But also be mindful of the areas where laws differ (for example, the UK expressly forbids certain practices, while the EU mandates that consumers be informed about personalised pricing and user review verification). It can be helpful to keep a comparative checklist of UK vs. EU consumer law obligations and to update it as laws change.
6. Dispute Resolution and Customer Support: Make your dispute resolution and customer support systems stronger. A responsive customer service team can resolve (or at least mitigate) a lot of consumer harm. Make it simple for clients to get in touch with you and get their problems fixed. If your industry has an Alternative Dispute Resolution (ADR) programme or trustmark, think about joining it. This can help identify problems before they become complaints from regulators or lawsuits, as well as increase consumer confidence. After Brexit, demonstrating a readiness to settle international conflicts amicably can also help to avoid the tension of international court cases.

Online companies can drastically lower their legal risks under the 2025 regime by implementing these measures. Because customers are becoming more astute and appreciate fair treatment, a strong compliance posture can be more than just defensive; it can become a selling point. Regulators have the resources and are committed to eliminating unfair practices in the UK and overseas.

However, this new environment also presents an opportunity for companies that follow the rules: a chance to compete on the basis of merit, establish credibility, and set themselves apart from less ethical rivals. According to the CMA, by fostering consumer confidence, efficient consumer law enforcement “supports spending and the adoption of new products and services across the economy.” Put another way, what benefits customers eventually benefits businesses as well.

Actionable Steps for Businesses to Stay Compliant

To stay compliant in the evolving regulatory landscape of 2025, businesses should take proactive steps to address compliance challenges. This includes conducting comprehensive compliance audits to identify potential risks and areas for improvement. Regularly reviewing and updating compliance policies and practices will ensure alignment with evolving regulations.

Additionally, businesses should invest in employee training programs to educate staff about compliance requirements and foster a culture of accountability. By empowering employees to understand and prioritise compliance, organisations can enhance their overall compliance efforts.

Furthermore, leveraging technology solutions can streamline compliance processes and improve efficiency by standardising compliance practices. Implementing automated compliance tools can help monitor regulatory changes, track compliance obligations, and reduce the risk of non-compliance. By embracing technology, businesses can enhance their compliance capabilities and position themselves for success in the global marketplace.

Benefits of Compliance for Businesses and Consumers

Compliance offers numerous benefits for both businesses and consumers. For businesses, adherence to regulations mitigates risks of legal penalties and enhances operational efficiency. By prioritising compliance, organisations can build trust with consumers and stakeholders, fostering a positive reputation in the marketplace, making it more attractive to potential investors.

For consumers, compliance ensures their rights are protected and that they receive safe, high-quality products and services. By upholding consumer rights and promoting transparency, businesses can cultivate trust and loyalty among their customer base.

Ultimately, a strong compliance posture benefits not only individual businesses but also contributes to a more secure and accountable global marketplace, including the private sector. As companies prioritise compliance, they can create a more sustainable and ethical business environment, driving long-term success for themselves and their consumers.

To wrap it all up

In conclusion, a comprehensive approach is needed to ensure cross-border e-commerce compliance in 2025. Since EU laws frequently impact international best practices, UK businesses should monitor developments in EU consumer law, and EU businesses that sell to the UK should do the same. Law differences can be handled with careful compliance planning; frequently, adding disclosures or changing interfaces will suffice to meet the more stringent requirements of the European Union.

For efficiency and user consistency, many businesses decide to adopt a uniform standard that satisfies both UK and EU requirements. Transparency and consumer justice are crucial everywhere, especially in light of the UK’s new government and the EU’s aggressive enforcement.

What is cross border compliance and why is it important for businesses?

Cross-border compliance refers to adhering to laws and regulations across different countries when conducting business internationally. It’s crucial for businesses to mitigate legal risks, maintain operational integrity, and build trust with consumers. Proper compliance ensures smooth transactions and protects against potential fines or legal repercussions in various jurisdictions.