The Association of Scotland’s Self-Caterers (ASSC) welcomed the opportunity to respond to the Competition and Markets Authority (CMA) consultation on draft guidance on the protection from unfair trading provisions in the Digital Markets, Competition and Consumers (DMCC) Act 2024.
The ASSC broadly welcomes the overarching aims of the Digital Markets, Competition and Consumers (DMCC) Act 2024 to enhance fairness and transparency in commercial practices. As a key stakeholder representing Scotland’s self-catering industry, we are committed to ensuring consumer protection while safeguarding the viability of self-catering businesses and the intermediaries that support them.
However, aspects of the draft guidance could disrupt established industry practices and have unintended consequences. We have provided detailed responses to the consultation questions, with recommendations to clarify and adapt the guidance to suit the unique characteristics of our sector.
The Draft Guidance outlines essential practices to ensure fairness, transparency, and compliance for businesses operating within the furnished holiday let sector. Below are the key points:
Key Information for Consumers
Businesses must provide clear, material details about the accommodation being sold, including:
Prohibition of Drip Pricing
Businesses cannot advertise a headline price that excludes mandatory costs.
Prohibited Practices
Businesses must avoid practices that mislead or harm consumers:
Consumer Protection Standards
Businesses must act with professional diligence, ensuring that:
ASSC supports measures to improve transparency and fairness while seeking clarification on issues including owner privacy, damage deposit policies, and agency practices. Businesses are encouraged to review the guidance to ensure compliance and maintain consumer trust.
You can download the ASSC’s submission to the consultation below.
We will report back on results of the consultation.