Consumer protection law across EMEA continues to evolve rapidly in response to digitalization, emerging technologies (particularly AI) and the continued expansion of online commerce. As we move into 2026, regulators are preparing significant reforms that will reshape business obligations and strengthen consumer‑protection enforcement. Below is an overview of the most important developments to watch this year.

I. European Union

As the EU enters a pivotal regulatory year, 2026 will bring a wide set of reforms across consumer and product‑market governance. Key developments include:

Changes to Consumer Rights

  • Digital Fairness Act (expected Q4 2026): The Commission plans to publish a new draft law designed to close gaps in existing consumer‑protection rules and reduce fragmentation between Member States. It is expected to (further) regulate influencer marketing, AI chatbots in consumer interactions, personalized advertising and pricing, and digital subscriptions.
  • Mandatory “withdrawal button” (from June 19, 2026): Traders selling online must offer consumers a clear online withdrawal button for all distance contracts, under recent amendments to the Consumer Rights Directive.
  • New guarantee notice and durability label (from September 27, 2026): Businesses must provide a harmonized statutory guarantee notice and a standardized commercial durability guarantee label across the EU, following Member State transposition of Directive (EU) 2024/825 and its implementing rules.
  • Audiovisual Media Services Directive (AVMSD) review (evaluation due in 2026): As part of its wider consumer‑protection agenda in digital environments, the Commission is reviewing the AVMSD to assess whether existing rules remain effective given the rise of influencer content, short‑form video formats, and increased online media consumption. The evaluation will examine scope, advertising rules, media prominence obligations, and protections for minors, as well as alignment with newer EU digital legislation.

New Rules for Digital and Connected Products

  • Cyber Resilience Act reporting duties (from September 11, 2026): Manufacturers of products with digital elements must begin reporting actively exploited vulnerabilities and serious cybersecurity incidents.
  • Updated Product Liability Directive (applies to products placed on the market from December 9, 2026): The new rules modernize EU liability frameworks to clearly cover software, AI and cybersecurity‑related defects. Member States have already begun rolling out the new regime.
  • Emerging neurotechnology governance (expected developments in 2026): The Commission’s Joint Research Centre published a foresight study and accompanying press release on neurotechnology applications that can monitor or stimulate brain activity, highlighting consumer‑protection questions for EU policymakers as devices move into consumer and quasi‑consumer contexts, including cognitive privacy, neural‑data handling, transparency, and fairness of claims and marketing. The study is expected to inform EU policy reflections in 2026, with UNESCO’s new global ethics framework on neurotechnology providing an additional reference point for future governance.

Product Safety and Compliance Reforms

  • Review of the New Legislative Framework and Market Surveillance Regulation (during 2026): In 2026, the Commission will continue examining ways to simplify CE‑marking rules, modernize digital compliance documentation and address enforcement gaps—particularly in online sales of unsafe goods. The review will also explore new EU‑level enforcement structures, potentially including steps toward an EU Market Surveillance Authority anticipated later this year.
  • General Product Safety Regulation (GPSR) review (during 2026): The Commission will assess business implementation of the GPSR and consider whether further simplification or targeted adjustments are needed, as part of the EU’s 2030 Consumer Agenda.

Rollout of Product, Sustainability and Consumer‑Information Requirements

  • Right to Repair Directive rollout (applies from July 31, 2026): Member States will continue transposing the new Right to Repair Directive up until the July 31 deadline. The Commission will support harmonized implementation of new repair obligations for product categories already subject to EU reparability requirements—such as mobile phones, tablets, major household appliances, electronic displays, vacuum cleaners, and servers—and will monitor preparations for the Directive’s European‑wide repair platform and standardized repair information form. The legislative framework also anticipates future expansion of repair requirements to additional product groups as part of the 2025–2030 Ecodesign for Sustainable Products Regulation (ESPR) rollout.
  • Digital Product Passport rollout (key developments expected in 2026): Under the ESPR, the Commission is preparing the first delegated acts setting Digital Product Passport (DPP) requirements for product groups including textiles, batteries, and certain electronics. These acts will also define rules for unique identifiers and interoperability of the EU-wide DPP registry. In addition, the Batteries Regulation already mandates a Digital Battery Passport for industrial batteries and electric vehicle batteries. Technical implementation work in 2026 will support alignment between the ESPR DPP and the Batteries Regulation DPP system.
  • Greenwashing Directive rollout (from September 27, 2026): The Empowering Consumers for the Green Transition Directive will apply from September 27, 2026. It introduces clearer rules for environmental claims, restricts generic sustainability terms, regulates sustainability labels and aims to improve the reliability of environmental information provided to consumers. Member States must transpose the Directive by March 27, 2026. For more detail on the Commission’s recent guidance on the implementation of the Greenwashing Directive.
  • Packaging and Packaging Waste Regulation (PPWR) starts applying (from August 12, 2026): The new PPWR introduces significant circular economy and safety requirements for packaging placed on the EU market. Of particular relevance for consumers are the strict limits on PFAS in food‑contact packaging. Businesses will need to adapt packaging materials, labelling and supply chain documentation to comply with the new rules, given that the Regulation prohibits placing food‑contact packaging on the market if PFAS concentrations exceed the applicable thresholds.

Stronger Cross‑Border Enforcement

  • Revision of the Consumer Protection Cooperation (CPC) Regulation (expected Q4 2026): A proposal is expected to improve cross‑border enforcement and coordination between national authorities, including exploring whether some enforcement powers should shift to the EU level. This was also mentioned as part of the EU’s 2030 Consumer Agenda. In parallel, the Commission continues to oversee Member States’ implementation of the Representative Actions Directive, which provides consumer organizations with collective redress tools across areas such as unfair terms, pricing practices, digital platforms and financial services.

For information about additional EU consumer‑protection initiatives planned for this year and over the next four years, you can also read our blog post on the EU Consumer Agenda 2030.

II. United Kingdom

As the UK’s consumer‑protection landscape continues to develop following several major legislative reforms, 2026 is expected to be a year of consolidation rather than sweeping regulatory change. The Digital Markets, Competition and Consumers Act (DMCCA) and Online Safety Act (OSA) were the two major developments of recent years, and both are now entering their implementation and enforcement phases. Several developments merit close attention:

  • Digital Markets, Competition and Consumers Act’s Subscriptions Regime Comes into Effect (from April 2026): The DMCCA’s new subscription‑contract rules will enter into force in April. These include clearer pre‑contract information obligations, renewal reminders, simplified cancellation mechanisms, and strengthened protections against “subscription traps.” Businesses offering subscription services in the UK should expect increased scrutiny from the Competition and Markets Authority (CMA), which has already identified problematic subscription practices as a priority enforcement area.
  • CMA investigations into online pricing practices (progress expected throughout 2026): The CMA is expected to advance several ongoing investigations into online pricing practices in 2026, including cases involving drip pricing, misleading urgency claims, hidden fees, and other digital‑interface design issues that may amount to unfair commercial practices. These investigations align with the CMA’s broader strategic focus on digital markets and consumer fairness, and may lead to formal enforcement action or updated guidance later in the year.
  • Potential developments under the Media Act 2024 (implementation steps expected in 2026): The UK government and Ofcom will continue working towards full implementation of the Media Act 2024 throughout 2026. The Media Act aims to modernize the regulatory framework for public service broadcasters, on-demand programme services and other media services. A number of the changes are designed to improve audience experience and set audience expectations. For example, with respect to the largest international on-demand programme services available to UK audiences, the Media Act will introduce more robust content standards and set targets to increase accessibility of programming. The Media Act will also introduce new rules to ensure prominence of public services broadcast content on digital platforms.

III. Middle East and North Africa

As governments across the Middle East and North Africa continue strengthening their consumer protection, advertising, and market transparency regimes, 2026 is expected to bring further consolidation of enforcement powers together with new digital compliance requirements. Authorities in the UAE, Qatar, and other jurisdictions are expanding oversight of online advertising, commercial practices, and price transparency, and are expected to increase supervision of digital platforms, influencer activity, and cross‑border commerce throughout the year. Key developments include:

  • UAE Advertiser Permit comes into effect (in effect since January 31, 2026): Under the UAE’s Advertiser Permit scheme, individuals and entities that post advertising and promotional content on social media must apply for and obtain a permit from the UAE Media Council. UAE citizens, residents, and visitors are required to have the Advertiser Permit. UAE citizens and residents are also required to hold a valid trade license and may apply for a one‑year renewable permit, whereas visitors only need to apply for a permit that is valid for three months. The requirement came into effect on January 31, 2026. Non‑compliance may result in content being removed from social media and a fine between AED 20,000 and AED 1 million (approximately between USD 5,450 and USD 272,000). This reflects the UAE’s increased efforts to more tightly regulate social media advertising and influencer culture.
  • Abu Dhabi Global Market’s Consumer Protection Regulations (in effect since December 2025): The Abu Dhabi Global Market (ADGM) issued its Consumer Protection Regulations, which came into effect in December 2025. The Regulations apply to entities providing goods and services within the ADGM. The rights awarded to consumers include providing a safe environment, obtaining true information about goods and services, educating consumers about their rights, protecting consumers against discrimination, providing quick and fair processing of complaints, and providing a way to obtain fair compensation. The Regulations also set out provider obligations related to labelling, price advertisement, addressing contingencies, obligations upon discovering a defect, promotions, price controls, and conformity to standard specifications, and prohibit including contract terms that may be harmful to consumers. The applicable penalties for non‑compliance may be a fine ranging from USD 1,000 to USD 54,000,000.
  • Qatar Issues Price Registration Requirements (in effect since October 2025): Qatar’s Ministry of Commerce and Industry (MOCI) released new requirements for commercial and industrial entities to register the prices of their goods and services on a designated portal on the MOCI’s website. Qatar aims to improve price transparency and market monitoring through a centralized government database and fair market practices.

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Covington & Burling is closely monitoring the initiatives outlined above and is available to advise on how they may affect your products, commercial practices and compliance strategies.

Photo of Jane Pinho Jane Pinho

Jane Pinho co-chairs Covington’s Entertainment and Media Industry Group and is a partner in the Technology and Communications practice and the International Business Reorganization practice. She has advised international streaming services on their content acquisition strategies, on new product launches and global expansions…

Jane Pinho co-chairs Covington’s Entertainment and Media Industry Group and is a partner in the Technology and Communications practice and the International Business Reorganization practice. She has advised international streaming services on their content acquisition strategies, on new product launches and global expansions, and on media regulation and licensing for the past decade.

Jane works with media industry leaders with global operations, including streaming services, video games and interactive entertainment companies, and social media platforms. She has particular experience advising in relation to the creation, acquisition, and distribution of digital content in the UK and Europe, in relation to the multi-territory launch, expansion, monetization and marketing of digital media products and services and in relation to compliance with the UK’s broadcasting, on-demand, video-sharing platform and online safety regimes, representing clients facing regulatory scrutiny. She also has experience advising media and technology companies on UK and EU consumer protection law, including on an investigation by the EU Commission and the Consumer Protection Co-operation Network.

Jane is also a key figure in Covington’s International Business Reorganization practice. She has managed global post-acquisition business reorganizations, pre-sale and pre-spin business separations and tax reorganizations for companies with substantial global footprints for more than a decade.

Photo of Dan Cooper Dan Cooper

Daniel Cooper is co-chair of Covington’s Data Privacy and Cyber Security Practice, and advises clients on information technology regulatory and policy issues, particularly data protection, consumer protection, AI, and data security matters. He has over 20 years of experience in the field, representing…

Daniel Cooper is co-chair of Covington’s Data Privacy and Cyber Security Practice, and advises clients on information technology regulatory and policy issues, particularly data protection, consumer protection, AI, and data security matters. He has over 20 years of experience in the field, representing clients in regulatory proceedings before privacy authorities in Europe and counseling them on their global compliance and government affairs strategies. Dan regularly lectures on the topic, and was instrumental in drafting the privacy standards applied in professional sport.

According to Chambers UK, his “level of expertise is second to none, but it’s also equally paired with a keen understanding of our business and direction.” It was noted that “he is very good at calibrating and helping to gauge risk.”

Dan is qualified to practice law in the United States, the United Kingdom, Ireland and Belgium. He has also been appointed to the advisory and expert boards of privacy NGOs and agencies, such as the IAPP’s European Advisory Board, Privacy International and the European security agency, ENISA.

Photo of Cándido García Molyneux Cándido García Molyneux

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido…

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido co-chairs the firm’s Environmental Practice Group.

Cándido has a deep knowledge of EU requirements on chemicals, circular economy and waste management, climate change, energy efficiency, renewable energies as well as their interrelationship with specific product categories and industries, such as electronics, cosmetics, healthcare products, and more general consumer products. He has worked on energy consumption and energy efficiency requirements of AI models under the EU AI Act.

In addition, Cándido has particular expertise on EU institutional and trade law, and the import of food products into the EU. Cándido also regularly advises clients on Spanish food and drug law.

Cándido is described by Chambers Europe as being “creative and frighteningly smart.” His clients note that “he has a very measured, considered, deliberative manner,” and that “he has superb analytical and writing skills.”

Photo of Anna Sophia Oberschelp de Meneses Anna Sophia Oberschelp de Meneses

Anna Sophia Oberschelp de Meneses is special counsel in the Data Privacy and Cybersecurity Practice Group.

Anna is a qualified Portuguese lawyer, but is both a native Portuguese and German speaker.

Anna advises companies on European data protection law and helps clients coordinate…

Anna Sophia Oberschelp de Meneses is special counsel in the Data Privacy and Cybersecurity Practice Group.

Anna is a qualified Portuguese lawyer, but is both a native Portuguese and German speaker.

Anna advises companies on European data protection law and helps clients coordinate international data protection law projects.

She has obtained a certificate for “corporate data protection officer” by the German Association for Data Protection and Data Security (“Gesellschaft für Datenschutz und Datensicherheit e.V.”). She is also Certified Information Privacy Professional Europe (CIPPE/EU) by the International Association of Privacy Professionals (IAPP).

Anna also advises companies in the field of EU consumer law and has been closely tracking the developments in this area.

Her extensive language skills allow her to monitor developments and help clients tackle EU Data Privacy, Cybersecurity and Consumer Law issues in various EU and ROW jurisdictions.

Photo of Seán Finan Seán Finan

Seán Finan is an associate in the Life Sciences team. His practice covers environmental, food and beverage and pharmaceutical regulation.

Seán has specific experience in a number of key areas for EU and UK clients in the technology, food and beverage, pharmaceutical, cosmetic…

Seán Finan is an associate in the Life Sciences team. His practice covers environmental, food and beverage and pharmaceutical regulation.

Seán has specific experience in a number of key areas for EU and UK clients in the technology, food and beverage, pharmaceutical, cosmetic and consumer goods industries, including:

Environmental and ESG compliance issues, including CSRD, CSDDD and green taxonomy issues; green public procurement issues; extended producer responsibility obligations, etc.;
Advertising claims, particularly environmental claims and greenwashing;
General food regulation; novel food regulation; genetically modified and “precision bred” products; and
Chemicals legislation (REACH, CLP, biocides, etc.).

Seán has represented clients in judicial review actions involving novel foods against multiple national regulators.

Seán is qualified in both England & Wales, and the Republic of Ireland.

Seán is a co lead of the firm’s Disability and Mental Health affinity group.