The DMCC Act and self storage: what applies when

The Digital Markets, Competition and Consumers Act 2024 (the DMCC Act) lets the Competition and Markets Authority (CMA) decide for itself that a business has broken consumer law and fine it, without going to court. For a storage operator selling to the public, two parts matter. The rules on showing prices came into force on 6 April 2025. The rules on subscription contracts have not: the Act contains them, but they wait for a start date.

This guide sets out what each part says, what the CMA has done so far and what is still unpublished, as at 9 October 2026. It summarises official sources. It is not legal advice, and it does not say whether a storage agreement is a subscription contract: that is a question for a solicitor.

What is in force and what is not

Since 6 April 2025 the Act has prohibited unfair commercial practices (section 225), and a commercial practice is unfair if it leaves material information out of an invitation to purchase. Section 230 says that information includes the total price of the product. The total price includes “any fees, taxes, charges or other payments that the consumer will necessarily incur if the consumer purchases the product” (section 230(4)). The CMA’s guidance on the rules, CMA209, says that showing a headline price and then adding mandatory charges later, often called drip pricing, is prohibited.

The same chapter of the Act (Part 4, Chapter 1) replaced the Consumer Protection from Unfair Trading Regulations 2008 (section 251). The CMA says that practices such as leaving mandatory charges out of the headline price had been unlawful for years under those regulations. Two things changed in April 2025. The Act wrote an express total-price requirement into the law (section 230), which the CMA describes as strengthening the rules on price transparency. And the CMA can now rule on a case itself, without going to court, and impose a penalty of up to £300,000 or 10% of the business’s turnover, whichever is higher (section 182). It can also order refunds.

The rules protect consumers, meaning individuals acting wholly or mainly outside their business (sections 225(3) and 280(1)). A customer that is a company, or an individual who takes a unit wholly or mainly for their business, is outside them. The Act also bans fake reviews and reviews that hide an incentive, from the same date (Schedule 20, paragraph 13). Our guide to self storage SEO has practical advice on asking customers for reviews.

The subscription rules, in Part 4, Chapter 2 of the Act, are a different matter. They are covered below.

What counts as a mandatory charge

The CMA’s test is short: “If the consumer cannot purchase the advertised product without the payment of a charge … then that charge is mandatory” (CMA209, paragraph 4.2). Two points follow from the guidance:

• Calling a charge an extra does not make it optional. Showing a charge separately from the headline price, or describing it as an extra service, does not make it optional (paragraph 4.3). A charge stays mandatory even if the customer could in theory avoid it by buying an additional product or paying an additional membership fee.
• Optional add-ons stay outside the total price. The CMA’s example is an extended warranty on a television.

The CMA’s list of mandatory charges includes administration fees “however described”, such as booking or processing fees; fees for additional services that cannot be avoided; joining fees paid on top of the first regular payment; and purchase taxes such as VAT (paragraph 4.4). A charge that not every customer pays still belongs in the total price if it is reasonably foreseeable that most customers will need to pay it and leaving it out would be misleading (paragraph 3.8).

The guidance’s one storage example is a luggage storage provider that advertised £5 per bag per day and added a £2 per day service charge. The CMA says the £2 should be included in the headline price, so that the price is £7. In November 2025 the CMA also sent advisory letters to 100 businesses about additional fees and online sales tactics, and luggage storage providers were among the sectors it named. The guidance does not mention self storage or padlocks. Whether a padlock, a goods-protection charge or a deposit is a mandatory charge at your site depends on your own terms and on that test, and it is a question for your adviser.

Showing a monthly price

If you charge by the week or month, the CMA’s guidance on periodic contracts is the part you most need to read.

• Rolling contracts, where the customer can leave at any time: show the total the customer will pay each month, including every mandatory charge in that month (paragraph 5.32). The CMA describes a rolling contract as one where the consumer is “free to cancel at any time” (paragraph 5.31) and does not mention a notice period, so whether yours counts is a question for your adviser.
• Minimum-term contracts: show either the total cumulative price over the minimum term, or the monthly price with a prominent statement of the number of months the customer is committed to pay it (paragraph 5.33).
• A one-off fee at the start: if a minimum-term contract is priced by the month and has a one-off administration, set-up or installation fee, the advertised pricing must give a total monthly price for the first month that includes it, and say what the later monthly payments are. The CMA’s example is a 12-month leisure centre membership at £20 a month with a £10 joining fee, shown as “£30 for the first month, then £20 per month for the next 11 months”. Where the total cumulative price is given, the CMA’s example allows the joining fee to be shown separately.
• A part month and a deposit: the monthly price rule does not prevent a pro-rata price for part of the first month, or taking part of the first monthly charge at sign-up (the CMA’s words: “eg as a deposit”), as long as the customer does not pay more overall (paragraph 5.34). The guidance also says that a deposit or pre-authorisation on a payment card that is refunded automatically if not called upon is not a mandatory charge (footnote 35). It does not say how any other deposit that is paid and later returned is treated, so ask your adviser how yours is treated.
• “From” prices are allowed if they include all the applicable mandatory charges and do not mislead the customer about what the price covers.
• Introductory and new-customer offers: the CMA lists introductory offers as an example of a targeted price reduction (paragraph 1.4), and special offers for new customers as another (paragraph 5.50). Such an offer must not mislead other consumers about the price they will pay, and the invitation to purchase must make explicit which consumers qualify; presenting it as a price for everyone when it is not is likely to be misleading. The total-price rule does not stop a later discount that brings the final price below the advertised total, such as a sale or a promotional code (paragraph 3.26). The guidance gives no storage example, and we found no source that says how to show an introductory rate on a storage unit, so put that to your adviser.
• VAT: a business that sells to both consumers and other businesses may keep VAT-exclusive price lists for trade customers, but prices offered or directed to consumers must include VAT (paragraph 4.7). Our guide to VAT on self storage covers the tax itself, and the guides to pricing your units and what a storage website should show cover the commercial side.

The rules govern how a price is shown, not how or when it is paid: the CMA says they do not affect how a trader takes payment (paragraph 3.24). Charges for paying a given way fall under separate payment-surcharge rules, which our guide to taking payments for self storage sets out.

What the CMA has done so far

The CMA opened its first cases under the new powers in November 2025 and has since reported fines in several. They concern businesses far from storage. The AA and StubHub cases show how it reads the price rule; Marks Electrical concerns a different rule:

• AA Driving School and BSM Driving School, 15 April 2026: a fine of £4.2 million (£7 million before a 40% settlement discount) and refunds of over £760,000 to more than 80,000 customers. A mandatory £3 booking fee had not been in the upfront price. It was the CMA’s first financial penalty under the new powers.
• Marks Electrical, 18 June 2026: a fine of £720,000 and refunds of around £600,000, for pre-ticked boxes that opted customers into paid extras. The rule was the ban on opting customers into extra payments without their express consent in the Consumer Contracts Regulations 2013; the CMA used its powers under the Act to fine.
• StubHub UK, 23 June 2026: a fine of £889,200 and refunds of over £590,000 to 51,350 customers, for hidden fees.
• The CMA’s own running total: by 19 August 2026 it said it had secured more than £1.95 million in refunds and levied fines close to £6.2 million under its new powers. The three cases above account for about £5.8 million of those fines; we could not match the rest, about £0.4 million, to a named case.

The CMA is also investigating Gold’s Gym over how it presents a one-off joining fee on an annual membership; the case was still open when we checked. A search of the CMA’s case list for “storage” on 9 October 2026 found no consumer enforcement case about self storage.

Subscription contracts: announced, not yet law

Part 4, Chapter 2 of the Act sets rules for subscription contracts. It is not in force: on 9 October 2026 legislation.gov.uk still showed it as prospective. It starts on a day the Secretary of State appoints by regulations.

On 9 August 2026 the Prime Minister’s Office said the new rules “will now come into force in January 2027”. We found no commencement regulations, no draft regulations and no CMA guidance for the chapter on 9 October 2026, and the announcement gave no day.

Three official pages still say spring 2027: the Government’s response to its consultation and the Department for Business and Trade’s press release, both dated 2 April 2026, and the CMA’s guidance “Writing a fair contract for customers”, last updated on 22 July 2026.

In April 2026 the Government also promised businesses “a period of implementation” (in the annex to its response, question 27); we found no official source that says whether that survives the earlier date.

Section 254 defines a subscription contract as a contract between a trader and a consumer to supply goods, services or digital content in exchange for payment, that is not an excluded contract, and that either:

• provides for an automatically recurring or continuing supply, for an indefinite or a fixed period, and makes the consumer automatically incur liability for each supply, or recurring liabilities for the continuing supply. It must also give the consumer a right to end the contract: a right they can use before any fixed period ends and without more than a nominal penalty (section 254(4)); or
• supplies goods, services or digital content free of charge or at an introductory rate for a set period, after which the consumer automatically becomes liable for payments or for payments at a higher rate, and gives the consumer a right to end the contract before that liability starts.

In this chapter “goods” includes “immoveable property” and “rights and obligations” (section 280). Schedule 22 lists the excluded contracts in 13 paragraphs, from utilities, financial services and medical supplies to package travel, timeshares, childcare and gambling; the only paragraph about accommodation covers contracts for residential accommodation. We searched its text for storage, land, hire and a licence to occupy and found none of them. That describes the wording of the Act, not its effect.

If the chapter applies to an agreement, the Act would require, among other things:

• key information before the contract is made, including how often and how much the customer pays, the minimum total payable and the notice needed to end the contract (section 256 and Schedule 23);
• for online sign-ups, a final step in which the customer expressly acknowledges that the contract obliges them to pay, failing which they are not bound (section 257);
• reminder notices about renewal payments, tied to six-month periods (section 258);
• a straightforward way to end the contract, online if it was made online (section 260); and
• cooling-off periods of 14 days: the first ends 14 days after the day the contract is made (or, where goods are supplied under it, 14 days after the day the consumer receives the first supply of goods) and another follows certain renewals, with no charge for cancelling during either (sections 264 and 265).

Some of these, including how much of a payment is refunded on cancellation, depend on regulations that have not been made. The chapter does not apply to contracts entered into before section 254 comes into force (section 275(3)); we found no official source that says how an older agreement is treated when it renews.

The cancellation rules for consumer contracts made online are those of the Consumer Contracts Regulations, which the chapter changes only for subscription contracts; our guide to the cooling-off period for self storage booked online sets out what they say and what the sources leave open about a storage licence.

Questions to put to your adviser

Put these to a solicitor, and to an accountant for the VAT points, before relying on a reading. The CMA’s guidance answers some of them in general terms, set out above. On the padlock, goods-protection, deposit, notice-period, introductory-offer and subscription points, the sources we read do not address storage:

• Is any charge on your price list, such as an administration fee, a padlock you require customers to buy or a goods-protection charge, one a customer has to pay to take the unit? If it is, the CMA’s test puts it in the price you show.
• Does the price shown for each size, on the first screen where it appears, include every such charge and VAT?
• If nobody is on your site and customers book online, does the price on the booking page include every mandatory charge? Our guide to automated self storage covers how an unstaffed site works.
• On a monthly licence with a minimum term and a one-off fee, if you show the monthly price rather than the total over the term, does the first month’s price include the fee, with the later monthly price stated?
• Do your “from” prices include every applicable mandatory charge?
• Does a licence that needs notice to end count as a “rolling contract”, where the customer is “free to cancel at any time” (CMA209, paragraph 5.31), or as a minimum-term contract? The guidance does not mention notice periods.
• Is a refundable security deposit taken at move-in a mandatory charge, given that the CMA’s footnote covers only card deposits and pre-authorisations that are refunded automatically if not called upon?
• If you run an introductory or first-period discount, does the booking page say who qualifies and what the price is afterwards, and if the price then rises automatically, could the subscription rules above catch the agreement once they start?
• Is a storage agreement a subscription contract once those rules start, and if it is, how are agreements made before the start date treated when they renew?
• Do your business customers and your consumer customers see different prices, and is each list addressed to the right group?
• Who will read the regulations when they are published, and when will you check this page’s facts again?

Sources

All read on 9 October 2026.

• Digital Markets, Competition and Consumers Act 2024, section 230, with section 225, section 182, section 248 and section 249 (what a product is), section 251 (the 2008 regulations revoked), section 338 (extent) and Schedule 20, paragraph 13 (fake and hidden-incentive reviews).
• The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 2) Regulations 2025, which brought the price rules and the CMA’s enforcement powers into force on 6 April 2025.
• The CMA’s price transparency guidance (CMA209) and its summary.
• The CMA’s news releases on AA Driving School and BSM Driving School, Marks Electrical, StubHub UK, three new investigations and its online pricing drive, and the Gold’s Gym case page.
• Part 4, Chapter 2 of the Act (subscription contracts), with section 254, Schedule 22 and Schedule 23.
• The Prime Minister’s Office release of 9 August 2026, the Government’s response to the subscription consultation with its Annex B, the Department for Business and Trade release of 2 April 2026 and the CMA’s Writing a fair contract for customers.