A narrow amending statutory instrument has reset one deadline in the UK’s new consumer ADR regime under the Digital Markets, Competition and Consumers Act 2024. The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026 were made on 16 September 2026 and came into force on 17 September 2026. (legislation.gov.uk) The operative change is simple in drafting terms. Wherever regulations 3(3)(b)(i) and (ii) and 4(3)(b)(i) and (ii) of the earlier commencement instrument referred to 5 October 2026, the new instrument substitutes 7 January 2027. (legislation.gov.uk)
The earlier Commencement No. 3 Regulations, made on 11 March 2026, brought Chapter 4 of Part 4 of the 2024 Act into force on 6 April 2026, together with Schedules 25, 26 and 27. Those provisions form the statutory basis for the revised ADR framework for consumer contract disputes. (legislation.gov.uk) They also created transitional rules for ADR providers and for special ADR arrangements. In broad terms, those rules disapplied certain prohibitions for cases that started within the relevant period and preserved the bridge to an accreditation decision where an application was made before the deadline. (legislation.gov.uk)
On the text of regulation 2, this is not a wider policy reset. It does not reopen the 6 April 2026 commencement date, and it does not amend the substantive ADR duties in Chapter 4 itself. The legal effect is confined to extending the end date used in the two transitional provisions. (legislation.gov.uk) That matters because the relevant period controls when unaccredited ADR can continue for legacy cases and when special ADR arrangements can keep operating for disputes that entered the system before accreditation is determined. The amendment therefore extends the life of that temporary bridge by just over three months. (legislation.gov.uk)
The Government’s stated reason is aviation. According to the explanatory note on legislation.gov.uk, ministers propose to amend the 2026 Conferral of Functions Regulations so that the Civil Aviation Authority can be appointed as competent authority for ADR in areas where it has regulatory responsibility or oversight. (legislation.gov.uk) The same note says the additional time is intended to let ADR providers in the aviation sector make their applications to the CAA during the extended transitional period. In policy terms, the deadline change appears designed to avoid a gap between the new statutory regime and the sector’s regulatory handover. (legislation.gov.uk)
The wider framework helps explain why the extension is narrow but still operationally important. Department for Business and Trade material on the related Conferral of Functions Regulations says the 2024 Act moved from a voluntary ADR accreditation model to a mandatory one, with functions conferred on the Chartered Trading Standards Institute to run applications, approvals and reporting under the new regime. (legislation.gov.uk) Against that background, adding the CAA to the structure would change where some aviation providers apply and who oversees them. For firms already preparing accreditation paperwork, the revised 7 January 2027 date reduces the risk that live consumer disputes fall outside the transitional window before that sector-specific change is ready. This is an inference from the published note and the earlier transitional provisions. (legislation.gov.uk)
For consumers and traders, the immediate effect is administrative rather than substantive. The instrument does not alter the underlying consumer rights regime or create fresh redress routes; it adjusts the timetable governing who may continue to run ADR, and on what transitional basis, while the accreditation system beds in. (legislation.gov.uk) The explanatory note also points back to impact assessments produced for the Digital Markets, Competition and Consumers Bill when it was introduced on 25 April 2023, rather than describing any further policy package in this amending SI. For compliance teams, the date to track in regulations 3 and 4 is now 7 January 2027, unless an application is granted, refused or withdrawn earlier under the existing wording. (legislation.gov.uk)