The UK Competition and Markets Authority published 'Complying with consumer law when using AI agents' in March 2026. The document is final, non-statutory guidance issued under the CMA's statutory consumer protection function. It sets out the CMA's enforcement position on how the Consumer Rights Act 2015 and the Digital Markets, Competition and Consumers Act 2024 apply to businesses that deploy AI agents in consumer-facing commercial transactions.
The Consumer Rights Act 2015, Part 2, prohibits unfair terms in consumer contracts. The Digital Markets, Competition and Consumers Act 2024, Part 4 and Schedule 18, prohibits unfair commercial practices and grants the CMA direct enforcement powers without a court order. The guidance applies those prohibitions to AI agent conduct and states that businesses bear liability for AI agent actions under the same principal-agent doctrine that applies to employee conduct. Specific obligations cover accuracy of product search results with transparent disclosure of coverage and ranking methodology, pricing completeness requiring all unavoidable charges to be disclosed, and ongoing supervisory review of AI agent responses by a qualified person.
UK retailers, financial services firms, telecoms operators, and travel platforms that deploy AI agents in consumer-facing interactions must assess whether their systems meet the guidance's accuracy, disclosure, and supervisory requirements. The CMA can enforce consumer protection law directly against firms without a court order under powers granted by the Digital Markets, Competition and Consumers Act 2024. Non-compliant businesses face fines up to 10% of worldwide annual turnover and may be required to compensate consumers who suffered harm.
The guidance applies to consumer-facing deployments only and does not cover B2B AI agent interactions. The CMA does not address the guidance's relationship to the EU AI Act 2024/1689, which imposes separate obligations on AI system providers and deployers in the European Union. Businesses serving both UK and EU consumers may face overlapping disclosure and supervisory obligations under distinct legal instruments.
Licentium advises digital businesses on UK and EU consumer protection and competition law, including AI agent deployment compliance. For matters requiring UK-qualified counsel, we coordinate through our partner network. To discuss how the CMA guidance applies to your AI product, contact us. Work we undertake includes: consumer law compliance audits, AI deployment regulatory reviews, unfair commercial practices assessments, Digital Markets Act compliance, and multi-jurisdictional regulatory strategy.
Source: UK Competition and Markets Authority, Complying with consumer law when using AI agents (March 2026)