practices (or promotion thereof), and price reduction claims made misleading actions and omissions, by Emma Sleep and Wowcher. and aggressive commercial An investigation into Simba Sleep practices. followed the CMA’s Open Letter However, a tailored approach calling on UK businesses to stop to tackle harmful OCA is emerging, using online sales practices that as it has become a focus for the UK could mislead consumers or government and regulatory bodies apply undue pressure. which have recognised the significant Regulatory publications, such as impact OCA has on consumers. the CMA’s discussion paper and This approach encompasses evidence review into OCA, as well the following: as the joint position paper by the CMA and ICO on harmful designs New legislation, which is currently in digital markets. being drafted under the Digital Markets Competition and Industry resources, such as the Consumers Bill is intended (among CAP advice on dark patterns. other things) to reform the law on Public awareness initiatives, unfair commercial practices as such as the Online Rip-Off Tip-Off well as combat subscription traps. campaign which seeks to educate The government also plans to consumers about spotting and introduce secondary legislation avoiding misleading online sales under the Bill to combat fake tactics. Under this campaign, online reviews. consumers are urged to report Enforcement action, such as CAP’s online rip-offs via a digital Enforcement Notice targeted at reporting form. the misleading advertisement of The approach to address harmful free trials and promotional offer OCA is still evolving, but it’s important subscription services. that businesses carefully assess Investigations, including the their OCA and keep abreast CMA’s examination of urgency of new developments in the law. 112