Regulatory scrutiny is intensifying, particularly in consumer-facing areas, and franchisors must ensure robust governance across their networks. Three themes dominate the legal landscape for the year ahead: enforcement under the DMCC Act 2024, fake review compliance, and renewed political focus on franchise regulation.
DMCC Act 2024 enforcement: online pricing and sales journeys
The Competition and Markets Authority (CMA) has moved decisively from guidance to active enforcement under the Digital Markets, Competition and Consumer Act 2024. Investigations have already been launched into eight businesses suspected of breaching consumer law through practices such as introducing mandatory fees late in the purchase journey, using misleading urgency messaging, and pre-selecting optional extras without consumer consent.
This represents a significant shift for brands operating online booking systems, e-commerce platforms, membership models or lead conversion funnels. The CMA’s focus is on the entire consumer journey, not just headline advertising. Transparency and fairness must be demonstrated at every stage of the process.
For franchise networks, the risk is amplified. Many systems combine centralised digital infrastructure with local franchisee execution, including local landing pages, promotions and social media activity. While enforcement action may target a single entity, reputational damage and consumer harm narratives rarely remain contained. The CMA has also issued advisory communications to a wider group of businesses, signalling that this is a market-wide enforcement theme rather than a one-off intervention.
Practical steps for franchisors include ensuring mandatory fees are disclosed early in the customer journey, justifying urgency messaging with objective evidence, avoiding the pre-selection of optional extras, and auditing templates, platforms and third-party agency activity for compliance. Importantly, the CMA is assessing outcomes rather than intentions, so consistent implementation across the network is essential.
Fake reviews: new compliance expectations
The DMCC Act 2024 also introduced a banned practice relating to fake reviews, supported by detailed CMA guidance on what compliance looks like in practice. This extends beyond avoiding fabricated reviews and includes concealed incentivised reviews, as well as misleading presentation of review scores that distort reliability or representativeness.
For franchise networks, governance and consistency are critical. Risk increases where franchisees run local campaigns, procure marketing support independently, or encourage reviews through promotions. The CMA expects businesses to take reasonable and proportionate steps to prevent, identify and remove banned reviews and misleading review information.
Franchisors can add real value by setting clear network rules covering incentives and disclosure requirements, escalation routes for suspicious activity, approved review platforms, and defined remedial steps when issues arise. Beyond legal compliance, this is a brand protection issue. Reviews influence franchise recruitment, renewals and resale value, so review governance should be treated as a core control environment rather than a marketing afterthought.
Franchise regulation: renewed political focus
Franchise regulation has returned to the political agenda following scrutiny linked to the Vodafone dispute and broader commentary around franchisee protections. In early January, the Prime Minister stated in the Commons that he would review whether franchising legislation needs to change following the outcome of ongoing legal proceedings. While no draft legislation or formal consultation has been published, the increased visibility of this debate is significant.
Public and parliamentary attention tends to raise expectations around transparency, fairness and governance, particularly where there is a perceived imbalance of power between franchisor and franchisee.
This serves as a timely reminder for franchisors to ensure that internal processes, communications and documentation are robust and capable of withstanding scrutiny, especially in high-pressure situations such as performance enforcement, renewals and managed exits.
Conclusion
Compliance in 2026 is practical rather than theoretical, with enforcement under the DMCC Act 2024 now active and outcome-focused. Governance across franchise networks matters more than ever, particularly where risks sit across both central and local operations. Political attention on franchising is increasing, and while no legal changes have been introduced yet, expectations are clearly rising. Brand protection is closely linked to compliance, as pricing transparency, review integrity and fair practices directly impact reputation and growth.
Franchisors and franchisees alike should treat these developments as a call to action: review systems, strengthen controls and engage with industry forums to stay ahead of change.
