UK consumer law: AI agents and chatbots (DMCC Act 2024, CMA guidance)
United Kingdom · Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 1 (unfair commercial practices); CMA, Complying with consumer law when using AI agents (9 March 2026) · effective 2025-04-06
Summary
The UK has no AI-specific disclosure statute. Its general consumer law applies instead: since 6 April 2025 the Digital Markets, Competition and Consumers Act 2024 bans misleading actions and omissions that could change a consumer's decision, and the Competition and Markets Authority can enforce it directly. The CMA's March 2026 guidance on AI agents says that if dealing with AI rather than a person might affect a customer's decision, the business should tell them, and that an AI agent should be labelled so customers are not misled into thinking a real person is providing the service. It gives customer-service chatbots as an example.
Who must comply
Every business that deals with consumers in the United Kingdom, including through a chatbot, voice agent or other AI agent.
What you must disclose
Do not lead a customer to believe a person is serving them when it is AI, where that could affect their decision. Label the AI agent.
When: Before the consumer relies on the interaction; practically, at the start of a conversation.
Other duties
- The business is responsible for what its AI agent says, as it is for an employee.
- Keep records showing what the customer was told and when.
Exemptions
- No formal exemption; the test is whether the practice could affect the average consumer's decision.
Penalties
CMA direct enforcement: fines up to 10% of worldwide turnover, orders to compensate affected consumers.