The Competition and Markets Authority (CMA) recently launched an investigation into Microsoft, examining whether the tech giant misled customers about their subscription options.
From January 2025, Microsoft began providing existing Microsoft 365 Personal and Family subscribers free access to new features, including its AI assistant Copilot, for the remainder of their subscription period. At renewal, customers were automatically moved onto a more expensive plan including the new features, unless they actively selected an alternative or cancelled. For ‘Personal’ subscribers, this meant paying £84.99 per year rather than £59.99 under the Classic plan. ‘Family’ subscribers faced a similar uplift, from £79.99 to £104.99. Prior to the auto-renewal, Microsoft offered a time-limited option to switch to a Classic plan, which gave consumers access to the same features they had access to before the changes, at the same price.
The crux of the CMA’s concern is the potential lack of sufficiently clear, timely, and prominent information about these choices before renewal. The CMA’s investigation “will consider whether Microsoft customers were misled and ended up paying more as a result”.[1]
While no conclusions have been reached regarding whether Microsoft has breached the law, the launch of the investigation signals the regulator’s view that innovation and rollout of new services must not come at the expense of fairness and transparency. As the CMA stated, consumers must “understand when they have the opportunity to shop around and make choices about which products they want to use”.[2]
The CMA is the latest regulator to target Microsoft, following on from court proceedings in Australia alleging that Microsoft misled customers and in Italy, an investigation into whether Microsoft failed to provide consumers with adequate information and whether its conduct amounted to an aggressive commercial practice. This pattern reflects a common trend: regulatory scrutiny in one market could be an early warning sign of similar actions elsewhere.
This investigation also highlights the CMA’s expanded enforcement toolkit. Since April 2025, the regulator has held direct consumer enforcement powers under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), enabling it to find breaches and impose fines of up to 10% of global turnover without court proceedings. The toolkit is set to expand further with a new subscription contracts regime expected to commence in early 2027, which will introduce specific requirements around pre-contract information, renewal notices, and cancellation mechanisms.[3] The Law Commission is also considering a consumer class actions regime which could significantly broaden the avenues for private enforcement.[4]
Cleary Gottlieb regularly advises on consumer protection compliance and can help navigate this evolving landscape. For further information, please contact Ricardo Zimbron or Anjali Iyer.
[1] CMA, CMA investigates Microsoft over marketing of subscription plans (29 July 2026).
[2] ibid.
[3] See A New Age of Consumer Protection in the UK | Cleary Antitrust Watch.
[4] Law Commission, Consumer class actions (20 April 2026).