On 22 January 2026, the UK’s Competition and Markets Authority (CMA) launched a consultation on updated guidance on unfair contract terms under the Consumer Rights Act 2015.

This initiative aims to modernise the existing guidance (CMA37) and make it clearer and more navigable for both businesses and consumers and clarifies the guidance around achieving transparency.

In effect, the CMA draft changes have further shifted the focus away from simply ensuring that the legal disclosure rules are complied with.

‍Why the emphasis on transparency is important for consumers

Unfair and un-transparent contract terms can lock consumers into one-sided, hidden or confusing obligations.  This undermines trust and can lead to financial or personal harm. Clearer guidance helps ensure that terms offered to consumers are transparent, intelligible and fair, so people can meaningfully understand what they’re signing up for.

In financial services we’ve already seen the FCA’s Consumer Duty emphasising the need for consumer understanding and a much bigger focus on ensuring communications lead to positive downstream outcomes rather than the previous focus on legal disclosure.

Enhanced clarity and transparency in contracts mean consumers are more likely to make informed decisions, better understand potential risks or costs, and challenge unfair practices where they arise. This supports broader regulatory trends toward consumer empowerment and evidencing better outcomes.

‍What it means for firms

For businesses, the consultation signals that the bar for communication clarity is rising. It’s no longer sufficient to avoid obvious unfairness; terms and notices must be structured, navigable and intelligible so an average consumer can understand them in context.

Key implications include:

• Intelligible language and structure: Firms will need to ensure terms are understandable by a range of consumers in real-world contexts.  It’s vital that consumers can grasp not just individual words but practical implications.
• Transparency by design: The draft Guidance emphasises outcomes for consumers rather than tick-box compliance, focusing on how information is presented and how easily consumers can find and understand critical terms.
• Documentation and governance: Firms should anticipate stronger expectations around how contracts are drafted and presented.  This could affect legal drafting, product design and customer communications teams.

The consultation itself includes questions on clarity, format, presentation, and helpfulness of tables and materials.  This signposts the CMA’s intent to judge terms against usability and consumer comprehension expectations.

The emphasis on practical intelligibility

One of the most significant shifts is how transparency is articulated. Regulators are placing increasing emphasis on consumer understanding:

• Intelligibility over form: It’s not just about using simpler words; communications must enable meaningful understanding of implications and risks.
• Consumer-centric structuring: Information should be logically organised and accessible.  It must help consumers find key rights, obligations and consequences without excessive effort.
• Outcomes-focused compliance: The CMA seems to be shifting toward judging firm behaviour on real consumer outcomes.

‍How Amplifi Can Help

At a time when guidance is placing heightened emphasis on intelligibility, consumer outcomes and navigable information, firms need tools that go beyond traditional readability checks.  They also need to challenge their ‘business as usual’ approach.

That’s where Amplifi comes in. Amplifi’s platform is designed to make communications measurable, trackable and demonstrably compliant with evolving expectations of intelligibility and transparency.

• AI-powered clarity assessment: Amplifi evaluates real consumer comprehension, not just surface readability. This helps firms ensure contract terms are meaningful and understood.
• Compliance you can prove: Generate audit-ready reports showing how communications meet regulator expectations. This is critical when firms are increasingly expected to evidence the work they have done to achieve understanding.
• Workflow governance: Amplifi includes tools for standardising drafting processes, tracking risk and embedding clarity into contracts. This reduces legal and regulatory risk.

For firms reassessing contracts in light of the CMA’s consultation, Amplifi offers a practical way to operationalise transparency and intelligibility at scale.

‍Conclusion

The CMA’s draft guidance refresh marks a shift toward clearer, more consumer-centric contract communication. For businesses, this means embracing structure, navigability and intelligibility as core compliance priorities. 

With tools like Amplifi, firms can stay ahead of regulatory expectations and deliver better outcomes for consumers and stakeholders alike.

‍