Three consumer protections were due this autumn. None of them is in force.

On 16th September 2026 a statutory instrument was made. SI 2026/1040, the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026, came into force the next day. It does one thing. It substitutes "7th January 2027" for "5th October 2026" in four sub-paragraphs of an earlier commencement order.

Four sub-paragraphs. Three months. The explanatory note is a single sentence: the effect is to extend "the transitional period from 5th October 2026 to 7th January 2027".

Business guidance written before 17th September still carries the old date, because a four-sub-paragraph amendment to a commencement order is not news. It is, however, the thing that decides whether a right exists. And it is not the only date that moved this autumn.

The three

Alternative dispute resolution. Chapter 4 of Part 4 of the DMCCA 2024 came into force on 6th April 2026 under SI 2026/284. It replaced the voluntary regime in which ADR providers were "approved" under the Alternative Dispute Resolution for Consumer Disputes Regulations 2015 with a mandatory accreditation regime, applications made under section 296 of the Act. Regulations 3 and 4 of that commencement order carved out a transitional period during which a legacy provider is exempt from two prohibitions: the ban on carrying out ADR without accreditation, and the restriction on charging consumers a fee. That transitional period was to run to 5th October 2026. SI 2026/1040 now runs it to 7th January 2027.

Read the second of those exemptions again. Until 7th January 2027, an unaccredited legacy provider can still charge you a fee to handle your dispute, and that is lawful, because the commencement order says so.

Subscription contracts. Chapter 2 of Part 4 of the same Act is the regime that gives you a 14-day cooling-off right when a subscription renews, including when a free trial converts, with a proportionate refund if you cancel inside it. The government's consultation response of 2nd April 2026 confirmed it rejected proposals to let traders obtain a tacit waiver of that renewal right. It is a genuinely strong consumer protection, and it is also not law yet. The published commencement target has been, in order: no earlier than October 2025, then spring 2026, then autumn 2026 at the earliest, then spring 2027, and now January 2027. Five dates, none of them reached.

Motor finance redress. The FCA published PS26/3 on 30th March 2026, an industry-wide redress scheme covering around 12.1 million agreements. On 2nd July 2026 the Upper Tribunal suspended parts of it, on terms the FCA agreed with four challengers including Volkswagen Financial Services, Mercedes-Benz Financial Services and the consumer group Consumer Voice. Under the partial suspension firms are not required to calculate redress, pay it, or send communications about compensation owed. The FCA's own statement lists the hearing windows as 14th to 18th December 2026 or 16th to 26th February 2027.

The scheme's published implementation dates are still in the policy statement. Search for the motor finance deadline this morning and you will find a date in September 2026. It is in PS26/3. It is not in force.

Why this costs consumers cases

Here is the mechanism, and it is not subtle.

A consumer reads about a new right. The coverage is accurate about what the Act says and silent about whether it is commenced, because commencement is boring and the Act is news. The consumer writes to the company and cites the new right. The complaints handler, who has been briefed by a compliance team that reads commencement orders for a living, replies that the provision is not in force and the complaint is not upheld.

The consumer has now done three things, all bad. Pinned the case to an unenforceable provision. Shown the handler they have not checked the current legal position. Used up the first exchange, which is the one with the most leverage, on an argument that cannot win.

None of that happens if the consumer cites the law that is actually in force. Which, in every one of these three cases, exists.

What to cite instead

For a subscription cancellation, the governing law until commencement is the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, plus Part 2 of the Consumer Rights Act 2015 on unfair terms. The 2013 Regulations give you 14 days from entering a distance contract, not from renewal, which is weaker. Part 2 of the CRA 2015 is the stronger argument: a term that makes cancellation disproportionately difficult, or that auto-renews at a materially higher price without clear notice, is challengeable as unfair now, and does not need the DMCCA to arrive.

For a dispute heading to ADR, ask the provider directly whether it is accredited under section 296 or operating under the transitional exemption, and ask in writing. If it is the latter and it wants a fee, you now know why it can ask, and you know the exemption expires on 7th January 2027. In several sectors a free statutory route exists in parallel and you are not obliged to use the paid one.

For motor finance, the live obligations under the partial suspension are not the redress ones. Firms must still identify affected complaints, gather commission data, and respond to complainants who are not owed compensation. Those response deadlines are 18th November 2026 for agreements from 1st April 2014, and 18th January 2027 for earlier agreements. Those are the dates worth diarising. A complaint that the firm has missed one of those is a complaint about something that is actually in force.

The principle

A right exists on the date a commencement order says it exists, not on the date the Act received Royal Assent, and not on the date a minister announced an intention. Three protections slipped this autumn by three different mechanisms: a statutory instrument, a ministerial restatement, and a tribunal. The pattern is that commencement is where consumer rights quietly go to wait, and almost nobody checks it.

Before you cite a right, check whether it has commenced. It takes two minutes and it is the difference between a letter that lands and a letter that gets filed.

Also worth your time this week

A quiet week on paper and a consequential one underneath it. Three separate consumer protections turned out not to be in force, and the energy price cap started moving in the wrong direction again.

• The DMCCA alternative dispute resolution deadline moved, quietly. SI 2026/1040, made 16th September and in force the next day, pushes the transitional period for unaccredited ADR providers from 5th October 2026 to 7th January 2027. During that period a legacy provider can still charge you a fee to handle your dispute. Guidance written before 17th September still carries the old date.
• Energy price cap: 4 per cent up now, 16 per cent forecast for January. The October 2026 cap is £1,723 a year for a typical dual-fuel household on a standard variable tariff, affecting around 22 million households. Cornwall Insight forecasts £1,999 in January, up £276. Ofgem must confirm the January figure by 25th November.
• A VAT cut on electricity has already taken effect, said to hold the cap £45 lower than it would otherwise be. It applies to standard variable tariffs, not fixed deals.
• South West Water fined £7.8m. Plymouth Magistrates Court imposed the fine on 1st October after 18 guilty pleas covering illegal discharges between 2015 and 2021, including 231 untreated sewage discharges at Harlyn beach. No customer refund was announced.
• The car carrier cartel claim is open. Bought or leased a new car or van between October 2006 and September 2015? A £55.87m distribution was approved by the Competition Appeal Tribunal on 23rd September. Register at cardeliverycharges.com. Resolver's explainer notes the window is time-limited, and warns against paying anyone to register for you.
• E.on's takeover of Ovo Energy has been cleared, creating Britain's largest supplier at roughly 9.6 million customers. Tariffs and Warm Home Discount continue for now. What happens to credit balances mid-migration has not been spelled out.
• The FCA opened its cryptoasset authorisation gateway on 30th September. Firms must apply by 28th February 2027; the regime bites on 25th October 2027. Until then, most crypto disputes sit outside the FCA complaints regime.
• A Surrey village lost broadband for about a month. Openreach reconnected Frensham after a burst water pipe. An outage that long engages Ofcom's automatic compensation scheme.
• Citizens Advice says it is seeing almost 200 people a day with water debt, and is pressing for a national water social tariff on the grounds that support is currently a postcode lottery.
• Diesel hit £2 a litre for the first time on record.

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