Retail Snapshot Q3 – 2025
Wednesday 2nd July 2025
Welcome to our latest Retail Snapshot
A summary key legal and regulatory developments impacting affecting retail businesses in Q3 2025.
What’s happening in Q3:
- Data (Use and Access) Act becomes law
- Food labelling rules change for products from Great Britain to Northern Ireland
- Service charge changes for commercial property
- Economic Crime and Corporate Transparency Act 2023 introduces a new offence for failure to prevent fraud
- Phase 2 of the Online Safety Act 2023 will become enforceable
- UK businesses expected to undertake some form of carbon reporting in the near future
- New rules for contracts when purchasing milk
Scroll down for more detail…
Data (Use and Access) Act
The UK’s new Data (Use and Access) Act 2025 (DUAA) received Royal Assent on 19 June 2025 and introduces a phased package of reforms to the UK’s data protection framework, with implementation expected to roll out over the next few months. While not a wholesale overhaul, key changes include updates to rules on automated decision-making, legitimate interests, data subject access requests (DSARs), and direct marketing.
Food labelling – Northern Ireland
From 1 July, composite products, fruit, vegetables, fish and certain other products moving from Great Britain to Northern Ireland under the Northern Ireland Retail Movement Scheme (NIRMS) must be individually labelled with the words ‘Not for EU’, subject to exemptions.
Service charges in commercial property
The second edition of this standard is set to be released in summer 2025, and is designed to address key challenges in the management of service charges, namely the issuing of budgets and year-end certificates, and aims to reduce the causes of disputes between landlords and tenants.
Failure to prevent fraud
From 1 September 2025, the Economic Crime and Corporate Transparency Act 2023 introduces a new offence for failure to prevent fraud. Organisations must demonstrate that they have reasonable policies and procedures in place to prevent fraud, or risk liability.
Online Safety Act 2023 – Phase 2
The Online Safety Act 2023 is being implemented in phases. Phase 1 has been implemented.
Phase 2 focuses on child safety, pornography and the protection of women and girls. Ofcom’s guidance was published in January 2025, with a three-month window for service providers to complete children’s access assessments.
Services likely to be accessed by children must be subject to a children’s risk assessment within three months of Ofcom’s publication of its Protection of Children Codes and risk assessment guidance. It is expected that the child protection safety duties will become enforceable in July 2025.
Phase 3 will introduce categorisation of regulated services, with additional duties for those meeting certain thresholds. Ofcom’s register of categorised services is expected by summer 2025.
Sustainability disclosure requirements
The Government is expected to endorse new International Sustainability Standards Board (ISSB) standards by July 2025. This will likely require all UK businesses, regardless of size, to undertake some form of carbon reporting in the near future. Retailers should begin preparing for enhanced sustainability disclosures.
The Fair Dealing Obligations (Milk) Regulations 2024
Any new contract, and from 9 July, all existing contracts to purchase milk from a ‘producer’ must comply with The Fair Dealing Obligations (Milk) Regulations 2024.
Written agreements must cover duration, price, volumes, dispute resolution, and termination notice periods. An Agricultural Supply Chain Adjudicator will enforce compliance, with fines of up to 1% of turnover for breaches.
If you would like to discuss any of these changes in more detail, please get in touch with one of our retail specialists.
