A short statutory instrument has altered the implementation timetable for part of the consumer dispute resolution regime under the Digital Markets, Competition and Consumers Act 2024. According to the text published on legislation.gov.uk, 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. The operative change is limited but important. The Regulations replace the date of 5 October 2026 with 7 January 2027 in the earlier Commencement No. 3 and Transitional Provisions Regulations 2026, extending the transitional period that applies to ADR providers and special ADR arrangements.
In plain terms, ministers have allowed more time for part of the new ADR structure to bed in before the previous transitional window closes. The amendment does not reopen the wider consumer protection settlement in the 2024 Act. It adjusts the timing of implementation so that the handover to the next regulatory stage is less compressed. That matters because transitional provisions are the legal mechanism used to avoid an abrupt break between existing administrative arrangements and the incoming statutory model. Where provider approval or supervisory functions are still being settled, a short extension can prevent avoidable disruption for firms, regulators and complainants.
The explanatory note attached to the instrument sets out the reason for the change. The Government proposes to amend the Digital Markets, Competition and Consumers Act 2024 (Alternative Dispute Resolution) (Conferral of Functions) Regulations 2026, S.I. 2026/259, so that the Civil Aviation Authority can be appointed as a competent authority for ADR in areas where it already has regulatory responsibility or oversight under legislation. The extra time is aimed specifically at the aviation sector. By pushing the deadline back to 7 January 2027, the Government is allowing aviation ADR providers a longer period in which to prepare and submit applications to the CAA if that conferral of functions proceeds.
Within the ADR system, a competent authority performs a gatekeeping and supervisory role. It may approve providers, assess whether statutory criteria are met and oversee whether approved schemes remain within the legal framework. In aviation, assigning that role to the CAA would align consumer dispute oversight more closely with the regulator that already holds sector expertise. For passengers and aviation businesses, the immediate effect is procedural rather than substantive. The amendment does not create a new consumer entitlement from 17 September 2026, and it does not revise the underlying rules on aviation complaints or compensation. Its purpose is to keep the approval route workable while the sector-specific oversight model is prepared.
The legal basis for the amendment is section 339(5) and (6) of the Digital Markets, Competition and Consumers Act 2024. The instrument was signed by Kate Dearden, Minister for the Future of Work, on 16 September 2026. The drafting is concise because the policy change is confined to substituting one date for another in four provisions of the earlier commencement regulations. That approach is typical of commencement law. When a wider reform depends on further secondary legislation or on a regulator taking on additional functions, government often uses a follow-on instrument to reset dates rather than allowing the timetable to run ahead of the administrative arrangements needed to make the regime operate properly.
The explanatory note also directs readers to the impact assessments prepared for the Digital Markets, Competition and Consumers Bill when it was introduced to Parliament on 25 April 2023. Those documents set out the expected effect of the wider consumer reforms on business, the voluntary sector and the public sector. For policy and compliance teams, the practical reading is straightforward. The transition period for the relevant ADR provisions now runs until 7 January 2027, and organisations in the aviation complaints market have a longer window in which to prepare for an application route involving the CAA. For consumers, the amendment is a timing measure designed to support continuity while the regulatory architecture is adjusted.