The Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026
Extended the transitional period for Alternative Dispute Resolution providers from 5 October 2026 to 7 January 2027.
These Regulations amend the transitional provisions of the Digital Markets, Competition and Consumers Act 2024 to extend the deadline for Alternative Dispute Resolution (ADR) providers and special ADR arrangements to comply with new requirements.
The document changes the end date of the transitional period from 5 October 2026 to 7 January 2027.
This extension applies to ADR providers, particularly those in the aviation sector, and enables the Civil Aviation Authority to be integrated as a competent authority within the new regulatory framework.
Arguments For
The explanatory note states that the extension allows Alternative Dispute Resolution (ADR) providers in the aviation sector sufficient time to submit applications to the Civil Aviation Authority (CAA).
The document indicates the extension is necessary to facilitate a proposed amendment to separate regulations (S.I. 2026/259) which would permit the CAA to be appointed as a competent authority for ADR purposes.
Proponents may argue that the revision ensures regulatory continuity for ADR providers and special ADR arrangements by preventing the premature expiration of transitional protections before the CAA's new functions are finalized.
Arguments Against
Legal scholars might note that the instrument depends on the subsequent passage of amendments to other regulations, creating a period of regulatory dependency.
Affected ADR providers outside the aviation sector may face prolonged uncertainty regarding their final status due to the blanket extension of the transitional period.
Critics may question why the original transitional period ending in October 2026 was insufficient, suggesting potential delays in the administrative implementation of the 2024 Act.
Citation and commencement
- —(1) These Regulations may be cited as the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) (Amendment) Regulations 2026.
(2) These Regulations come into force on the day after the day on which they are made.
This section establishes the official name of the regulations and the date they take legal effect.
The rules become active on 17 September 2026, which is the day following their signing by the Secretary of State.
Amendment of the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026
- In regulations 3(3)(b)(i) and (ii) (transitional provisions relating to ADR providers) and 4(3)(b)(i) and (ii) (transitional provisions relating to special ADR arrangements) of the Digital Markets, Competition and Consumers Act 2024 (Commencement No. 3 and Transitional Provisions) Regulations 2026, for ‘5th October 2026’, in each place where it occurs, substitute ‘7th January 2027’.
This section modifies the existing timeline for businesses and organizations that provide out-of-court dispute resolution services.
It replaces the previous deadline of 5 October 2026 with a new date of 7 January 2027 for transitional arrangements.
This affects both standard Alternative Dispute Resolution (ADR) providers and those operating under special ADR arrangements.
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