The Government has set 6 April 2026 as the start date for the Digital Markets, Competition and Consumers Act 2024’s alternative dispute resolution (ADR) framework. The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026 (SI 2026/284), made on 11 March 2026 and signed by Parliamentary Under-Secretary of State Kate Dearden, also establish a temporary transition running to 5 October 2026.
The instrument commences Chapter 4 of Part 4 of the Act in full and activates three linked schedules: Schedule 25 (exempt ADR providers), Schedule 26 (accreditation criteria) and Schedule 27 (consequential amendments and revocations). This is the third set of commencement regulations under the Act and is targeted at moving the UK consumer ADR system onto a single statutory footing with accreditation at its centre.
From the commencement date, a person must not carry out ADR for a consumer contract dispute unless they are accredited or exempt; this is the new statutory prohibition in section 293. The regime also restricts charging fees to consumers, with section 294 setting the conditions under which an accredited provider may levy consumer fees and prohibiting such fees where ADR is undertaken under special ADR arrangements. Section 296 creates the formal accreditation route, while section 308 introduces a duty on traders to inform consumers about available ADR or other complaint-handling arrangements when responding to complaints. Schedule 27 revokes the 2015 ADR Regulations and updates cross-references across legislation. (legislation.gov.uk)
The Regulations add transitional measures to those in section 310 of the Act. For ADR carried out by an ADR provider, the prohibitions on acting without accreditation and on charging consumers a fee do not apply where the ADR started between 6 April 2026 and 5 October 2026. ADR is taken to start when the consumer contract dispute is first referred to the provider in line with its rules. If the provider applies for accreditation before 5 October 2026, the temporary relief ends on the date the application is granted, refused or withdrawn.
A separate transitional route applies to ADR carried out under special ADR arrangements. During the same period-6 April to 5 October 2026-the prohibition on charging consumer fees for ADR under such arrangements is disapplied, and the Act’s general transitional rules do not prevent a person from continuing to operate those arrangements for cases that started in that window. For this purpose, ADR is taken to start on the earlier of the consumer dispute being referred to the person who made the special arrangements or to the person carrying out the ADR under those arrangements, in each case according to that person’s rules.
Accreditation is the organising principle of the new regime. Applications to the Secretary of State under section 296 can be limited to particular descriptions of ADR or of special ADR arrangements. Schedule 26 then sets the criteria that an accredited provider must meet, including accessible procedures, fairness, transparency, independence and effective communication with parties about process and outcomes. (legislation.gov.uk)
Exemptions are tightly framed. Schedule 25 provides for exempt ADR providers or exempt redress schemes and enables limits to be placed on the scope of any exemption, including in relation to carrying out ADR and making special ADR arrangements. Providers that consider themselves within scope of an exemption should confirm both the description and any limits that apply. (legislation.gov.uk)
Trader-facing duties also change from 6 April 2026. When communicating the outcome of a complaint, traders must tell consumers about any ADR or other arrangements available to them, for example where participation is mandated by law or contract. The Act makes clear this duty does not apply to complaints received before section 308 comes into force, so businesses should update response templates and scripts ahead of 6 April. (legislation.gov.uk)
In practice, ADR bodies intending to continue beyond the transition should file accreditation applications promptly and map their case intake to identify the precise point at which a dispute is ‘referred’ under their procedures, as this determines whether a case falls within the temporary relief. Providers charging consumer fees today will need to plan for post-transition compliance, including obtaining any required approval for fee provisions or ceasing to charge where the Act prohibits it.
For in‑house counsel and customer operations teams, the priority is signposting accuracy. From 6 April 2026, references to ADR in consumer-facing materials should point only to accredited or exempt providers or schemes. Complaint-handling processes should incorporate the section 308 notification in plain English and reflect the fact that transitional relief ends on 5 October 2026 or earlier if a provider’s accreditation application is determined sooner.
This commencement creates a defined runway for the sector to move onto the new statutory model. The policy intent is continuity of service during the changeover, followed by a clearer accreditation-led market with consistent consumer information and fee rules once the transition closes in early October 2026. Providers and traders now have fixed dates and definitions to plan against.