Leaked EU Digital Fairness Act draft points to consumer-law overhaul
Hogan Lovells reports a leaked draft of a proposed Digital Fairness Act regulation that the European Commission is expected to formally present on 11 November 2026, signalling significant EU consumer-protection reform.
What is reported: Hogan Lovells has circulated analysis of a leaked draft of the proposed EU Digital Fairness Act (DFA), a Regulation the European Commission is expected to present formally on 11 November 2026. On the firm's account, the leaked text indicates the initiative could substantially reshape the EU framework governing consumer protection. The operative provisions are unverified: the leak is unofficial, and the Commission's own proposal, recitals and implementation timetable are still pending.
Why counsel should care: the framework at issue governs how terms, offers and commercial practices are assessed against consumer-protection standards, and a Regulation of this kind would reach consumer-facing businesses operating in, or into, the EU. Because the text is not public, firms cannot rely on the leaked specifics.
Next steps: monitor the Commission's 11 November 2026 presentation and the subsequent legislative timetable; map current consumer-facing practices, terms and pricing against the existing framework meanwhile; and treat any summary of the leak as provisional until the official proposal appears.