Posted: Wednesday, 11 February 2026 @ 09:14
Updated CMA Guidance for Will Writers
What's changed, when, and what you need to know
The Competition and Markets Authority (CMA) has updated its guidance for unregulated legal services, including will-writing. While the core legal duties remain unchanged, the enforcement landscape has shifted significantly. Here's what every will-writing professional needs to know to ensure compliance and protect their practice.
📅 Timeline: How We Got Here
Early 2024
Draft Guidance
CMA shared draft guidance and asked stakeholders for feedback.
Oct 2024
Final Guidance
Clarified scope, structure, and examples. Legal duties unchanged.
Apr 2025
New Law in Force
Digital Markets, Competition and Consumers Act 2024 introduced rules on pricing, subscriptions, and enforcement.
Jan 2026
Guidance Updated
Updated to reflect new law and stronger CMA enforcement powers.
Who This Applies To
This guidance applies to all unregulated will-writing services, including:
- DIY kits
- Online platforms
- Face-to-face providers
Important: Being unregulated doesn't mean you're exempt from consumer law. All providers must comply with these requirements.
Key Points for Will Writers
✅
Transparent Pricing
All mandatory fees must be displayed upfront; optional extras should be clearly marked as such.
✅
Subscriptions & Updates
Recurring charges must be clear, optional, and easy to cancel. No hidden auto-enrolment.
✅
Accurate Marketing
Avoid guaranteed probate outcomes or legal claims you can't deliver. Be honest about what your service includes.
✅
Fair Contract Terms
Terms must be clear, fair, and not restrict clients' legal rights. Use plain language.
✅
Service Standards
Deliver service with the care and skill promised. Quality matters.
⚠️ Enforcement Update: New Powers for the CMA
Under the new law, the CMA can take direct action for breaches without needing to go through the courts first. This includes:
- Fines 💰 - Significant financial penalties for non-compliance
- Refund orders 💸 - Mandating refunds to affected consumers
- Public enforcement notices 📢 - Naming and shaming non-compliant businesses
The stakes for compliance are higher than ever.
Quick Do's & Don'ts
✅ Do:
- Provide clear, upfront pricing
- Explain inclusions & exclusions
- Offer easy cancellation for subscriptions
- Use plain, simple language
❌ Don't:
- Mislead about legal outcomes
- Hide fees or auto-enrol clients
- Use unfair or unclear contract terms
- Make claims you can't substantiate
Summary: What's Changed?
• Updated guidance reflects Digital Markets, Competition and Consumers Act 2024
• Focus: transparency, fairness, clear communication, compliance
• Key change: Obligations are largely the same, but enforcement is now stronger and more direct
Read the full guidance here:
CMA Guidance on Unregulated Legal Services
Disclaimer: This article provides a summary of CMA guidance for informational purposes. It does not constitute legal advice. For specific compliance questions, consult with a legal professional familiar with consumer protection law.