UK CMA Issues AI Agents Consumer Law Guidance, March 2026

The Competition and Markets Authority (CMA) published its guidance titled "Complying with consumer law when using AI agents" on 9 March 2026. The guidance is a final, effective publication directed at businesses that deploy agentic AI systems to interact with consumers, process orders, or handle complaints. It does not amend existing statute; it interprets the CMA's existing consumer protection enforcement priorities. The guidance applies immediately and is addressed to all businesses in the United Kingdom that use AI agents in consumer-facing operations, regardless of sector.

The CMA's guidance derives its authority from the Consumer Rights Act 2015 and the Digital Markets, Competition and Consumers Act 2024. It identifies specific obligations that apply when AI agents act on behalf of consumers or businesses. The guidance states that a business deploying an AI agent remains legally responsible for the agent's actions toward consumers, including where the agent creates contracts, accepts returns, or processes refunds. The CMA applies sections 62–65 of the Consumer Rights Act 2015 (unfair terms) and Part 2 of the same Act (consumer contracts) to AI agent interactions without modification.

Businesses deploying AI agents in consumer-facing contexts must train and configure those agents to comply with applicable consumer protection law. Specifically, an AI agent must not create unfair contract terms, must not engage in misleading or aggressive commercial practices under the Consumer Protection from Unfair Trading Regulations 2008, and must provide accurate information about prices, cancellation rights, and complaint procedures. Retailers, financial services firms, travel operators, telecoms companies, and technology platforms using AI chatbots or automated purchasing systems to interact with UK consumers must audit their AI agent systems against this guidance. Any AI agent that autonomously enters contracts on behalf of a business triggers full consumer law obligations for that business.

The guidance does not create a safe harbour for AI errors. A business cannot rely on the argument that a consumer contract was concluded by an AI agent, rather than a human, to avoid liability for unfair terms or misleading information. The CMA has not announced a grace period; it may take enforcement action under its existing powers at any time following the guidance's publication. Businesses with ongoing agentic AI deployments face immediate compliance exposure.

Our firm advises businesses on AI regulatory compliance, including agentic AI deployment and consumer law obligations in the United Kingdom. We maintain a dedicated partner network to support technology companies, retailers, and financial institutions implementing AI systems subject to CMA oversight. Contact us to assess your AI agent deployment against this guidance. Our practice covers AI governance, consumer protection compliance, digital markets regulation, automated contract formation, and consumer-facing technology law.

Source: Competition and Markets Authority, "Complying with consumer law when using AI agents," published 9 March 2026, https://www.gov.uk/government/publications/complying-with-consumer-law-when-using-ai-agents, confirmed 30 March 2026.

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