UK CMA Issues Agentic AI Consumer Law Guidance for Businesses, March 2026

The UK Competition and Markets Authority published "Agentic AI and consumers" on March 9, 2026. This research and guidance document sets out the CMA's view of how existing consumer protection law applies to businesses that deploy agentic AI systems — AI that acts autonomously on a consumer's behalf, such as AI that books services, makes purchases, or manages subscriptions without requiring step-by-step human input. The guidance is not a new regulation; it applies existing statutory obligations to a new technological context.

The CMA grounds its guidance in the Digital Markets, Competition and Consumers Act 2024 and the Consumer Rights Act 2015. Under those statutes, a business must not engage in unfair commercial practices, must provide clear information to consumers, and must not use terms or conditions that disadvantage consumers in a way that courts or the CMA may find unfair. The guidance states that these obligations apply equally when the business deploys an AI agent to interact with consumers on its behalf. The CMA identifies specific risk areas: AI agents that steer consumers toward choices that benefit the deploying business rather than the consumer, agents that withhold material information, and agents that operate in ways consumers cannot understand or override.

AI businesses, platform operators, and any firm deploying AI agents that interact with UK consumers must review their agent system design and terms of service against the consumer protection standards the CMA describes. Firms whose AI agents make purchasing decisions on behalf of consumers face particular scrutiny over transparency obligations — consumers must be told when an AI agent is acting for them and must be able to override or cancel agent actions. Businesses whose agents operate in digital markets subject to the Digital Markets, Competition and Consumers Act 2024 designation regime face additional obligations under that Act's pro-competition interventions.

The guidance does not carry the force of binding rules, but the CMA may use it as the basis for enforcement action under the Digital Markets, Competition and Consumers Act 2024 or refer firms to the courts. Businesses should treat the guidance as an accurate statement of the CMA's enforcement priorities in the agentic AI space.

Source: Competition and Markets Authority, Agentic AI and consumers, published March 9, 2026. Available at: https://www.gov.uk/government/publications/agentic-ai-and-consumers. Confirmed March 17, 2026.

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.