8 items
- Actionable27 September 2026
EmpCo green-claims rules now apply — UCPD blacklist expanded
Directive (EU) 2024/825 amending UCPD 2005/29/EC and CRD 2011/83/EU
Application date arrived · Binding · all Member States
Generic environmental claims, uncertified private sustainability labels, and future-performance claims without a verifiable plan are now restricted or blacklisted. The Commission Q&A is explicit: there is no legal transition, including stock already on shelf. The CPC Network Common Understanding allows phased enforcement of old stock, not a pause of the duty. Infringement files remain open against Member States that missed the 27 March 2026 transposition deadline.
So what. A live EU consumer-facing green claim is a UCPD problem today. Hungary: Fttv blacklist expansion (GVH, 8 September), no grace period.
- ActionableFlagged 29 September 2026
Digital Fairness Act tentatively listed for 11 November
Digital Fairness Act · Have Your Say 14622 · Fitness Check SWD(2024) 230
Tentative College agenda, paired with a consumer-enforcement initiative · Proposal · text not published
MLex reports the Commission's tentative November agenda names the Digital Fairness Act for 11 November, next to a consumer-enforcement initiative. That second item is almost certainly the CPC Regulation revision, also a Q4 2026 Work Programme item. The official DG JUST page still says the file is under preparation. Consultation closed 24 October 2025. Legal form — new regulation, directive, or a conversion of the UCPD — is still open. Agendas slip.
So what. Diary 11 November as a slip-prone date. The next document that matters is the proposal and staff working document, not another explainer.
- Material movement17 September 2026
KIDS Act redraws the DFA lane on minors and addictive design
Proposal COM(2026) 681 · Communication COM(2026) 680
Commission proposal adopted · Proposal · ordinary procedure
Minimum autonomous social-media age of 15, safety-by-design, age assurance, and rules for AI companions, enforced through DSA and AI Act scaffolding. The accompanying communication now describes the DFA as the horizontal consumer-law update for manipulative business-to-consumer practices, unfair pricing, influencer marketing, and digital contracts. It no longer lists addictive design as a DFA headline the way the May 2026 communication did.
So what. When the DFA text lands, check whether addictive design is still an operative DFA provision or has been parked in the KIDS Act for minors.
- Material movementQ4 2026
CPC Regulation revision is travelling with the DFA
Review of Regulation (EU) 2017/2394
Same Q4 2026 package as the College agenda item · Expected proposal
The 2030 Consumer Agenda (19 November 2025) committed to assessing centralised Commission investigation and sanctioning powers for certain EU-wide infringements. Commissioner McGrath has described the aim as deterrence. EuroCommerce and ECC-Net both treat the fourth quarter of 2026 as the proposal window. This is the enforcement half of whatever dark-pattern and unfair-practice rules the DFA writes.
So what. A Digital Fairness Act without a harder CPC is a drafting exercise. Read the two texts together.
- Material movementThis week
Comparative enforcement outside the EU
India Dark Patterns Guidelines 2023 · ACCC priorities · New Mexico Unfair Practices Act
Cross-cited by EU commentators, not EU law · Comparative only
India’s CCPA has penalised Zepto, IndiGo, FirstCry, Physics Wallah, SpiceJet and others for drip pricing, basket sneaking, and pre-ticked add-ons. Australia’s ACCC named subscription traps and manipulative design as 2026–27 priorities, with recent Federal Court penalties on fake countdown timers and hidden recurring fees. On 25 September a New Mexico jury found 26 Meta statements to be willful deceptive trade practices — a consumer-law theory, not a dark-pattern interface case.
So what. Keep as comparative colour unless UK, US, or India are first-class beats.
- ContextIn force
DSA Article 25 is still the only EU-wide dark-pattern rule, and it only covers platforms
Regulation (EU) 2022/2065, Article 25(1)
Standing rule · guidelines power unused · Binding for online platforms
Article 25 bans online platforms from designing interfaces that deceive or manipulate recipients. The Commission has not used its power to issue guidelines. The December 2025 decision against X (€120 million, paid blue checkmark as a deceptive trust signal) is the first Article 25 holding. Traders who are not platforms stay on the Unfair Commercial Practices Directive — which is why the Digital Fairness Act file exists.
So what. Do not treat a platform fine as a rule for every trader’s checkout.
- Context19 June 2026
Distance financial services already have a dark-pattern ban
CRD Articles 16a–16e, inserted by Directive (EU) 2023/2673
Application date passed · Binding · sectoral
Chapter IIIa of the Consumer Rights Directive requires Member States to stop traders concluding distance financial-services contracts from using dark patterns. It is complementary to DSA Article 25, not a substitute, and Member States may go further in this sector.
So what. If the brief includes fintech or insurance interfaces, this is the live sectoral rule.
- ContextText dated 3 September · leak 21 September
The cookie-banner fight stays adjacent
Council Presidency text 12535/26
Leaked compromise on cookie consent · Out of scope unless the definition moves
The leaked text would move cookie consent back toward the ePrivacy Directive and add a measurement exemption. That is a consent-interface file. It enters this desk only if it changes how a manipulative interface is defined for the Digital Fairness Act.
So what. Do not brief Digital Omnibus high-risk AI deadlines here.
Who can enforce this
Taken from the Commission’s CPC competent-authorities list. A body is here only if that list gives it Directive 2005/29/EC, or, for Hungary, if it is the digital or financial consumer authority on the same list. Each link is a related release, not the general press room. County offices, rail, energy, pharma and gambling regulators are on the official list and are left off.
EU
European Commission, CPC Network
Coordinator of cross-border sweeps under Regulation (EU) 2017/2394. Not a national enforcer.
Competent-authorities listHungary
Gazdasági Versenyhivatal (GVH)
Unfair commercial practices under the Fttv (Directive 2005/29/EC) and misleading advertising.
gvh.huHungary
Nemzeti Kereskedelmi és Fogyasztóvédelmi Hatóság (NKFH)
Horizontal consumer authority since 1 January 2025, including the UCPD, the Consumer Rights Directive, and digital-content rules. County offices inspect under its direction.
nkfh.gov.huHungary
Magyar Nemzeti Bank (MNB)
Unfair practices in distance contracts for financial services, including the dark-pattern ban in CRD Articles 16a–16e.
mnb.huNo related release verified in this pass. The site is the authority, not a news item.
Hungary
Nemzeti Média- és Hírközlési Hatóság (NMHH)
Listed for the UCPD together with ePrivacy and audiovisual media. Recent public items are media-law commercial communications, not an Fttv interface case.
nmhh.huNetherlands
Authority for Consumers and Markets (ACM)
Single liaison office. Horizontal enforcer of the UCPD, including deceptive design.
acm.nlBelgium
FPS Economy, Economic Inspection
Single liaison office for unfair commercial practices.
economie.fgov.beFrance
DGCCRF
Single liaison office. Misleading commercial practices and environmental claims.
economie.gouv.fr/dgccrfIreland
Competition and Consumer Protection Commission (CCPC)
Single liaison office for the UCPD and price-indication rules.
ccpc.ieItaly
Autorità Garante della Concorrenza e del Mercato (AGCM)
Unfair commercial practices, including dark patterns in e-commerce.
agcm.itPoland
Office of Competition and Consumer Protection (UOKiK)
Single liaison office. Unfair market practices, including interface design.
uokik.gov.plFinland
Finnish Competition and Consumer Authority (KKV)
Single liaison office. Consumer Ombudsman enforces unfair practices.
kkv.fiDenmark
Forbrugerombudsmanden
Single liaison office. Marketing Act, including green claims and price promotions.
forbrugerombudsmanden.dkSweden
Konsumentverket / Konsumentombudsmannen
Single liaison office. The Consumer Ombudsman takes misleading-marketing cases to court.
konsumentverket.seSpain
Dirección General de Consumo
National inspection and sanctioning body for unfair practices. Regional consumer authorities also enforce Directive 2005/29/EC.
dsca.gob.esGermany
Bundesamt für Justiz, consumer-enforcement unit
CPC unit for cross-border unfair practices since 1 January 2026, moved from the Federal Environment Agency. Germany has no single domestic public enforcer; most UCPD cases are private actions.
bundesjustizamt.de
Seven-day watchlist
1–7 October
Any Commission drop ahead of the November College: draft proposal, staff working document, or CPC revision.
11 November
Tentative College date for the Digital Fairness Act and the consumer-enforcement initiative. Treat as slip-prone.
Ongoing
National EmpCo old-stock posture, including the GVH. No Hungarian dark-pattern decision in this 15-day window. Baseline remains the Fttv and the 8 September blacklist expansion.
Left off this issue
- AI Act and Digital Omnibus high-risk deadline stories — no unfair-practice or interface hook.
- Generic “what are dark patterns” explainers and vendor webinars.
- DSA disinformation-code dialogues with platforms (29 September) — not Article 25, not the UCPD.
- Pay Transparency Directive transposition — a different file.
How this desk works
Adapted from the Detect lane of newsjack: a standing profile, a freshness gate, and three buckets. Pitch-ready became actionable. Big stories became material movement. Watch became context. This issue is the 30 September run, EU-first, with Hungary noted where the Fttv or the GVH moved. The authority list is the CPC directory filtered to the bodies that actually police these beats. It is a briefing, not legal advice.