Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
Practical CRA 2015 Compliance Steps For Small Businesses (A Simple Checklist)
- 1) Audit What You Sell And How You Sell It
- 2) Tighten Up Your Descriptions And Pre-Contract Information
- 3) Put A Clear Complaints, Refunds And Returns Process In Place
- 4) Use Properly Drafted Consumer Terms (Not DIY Templates)
- 5) Don’t Forget Distance-Selling Cancellation Rights (They’re Separate)
- 6) Don’t Forget Data And Marketing Compliance
- Key Takeaways
If you sell to consumers in the UK, the Consumer Rights Act 2015 (often shortened to the Consumer Rights Act, or CRA 2015) isn’t optional reading - it’s a key part of your day-to-day risk management.
And even if you’re a small business, side hustle, or startup, the rules still apply. In fact, small businesses often feel the impact more because one dispute, chargeback, or bad review can take a real chunk out of your time and cashflow.
The good news is that compliance with the Consumer Rights Act 2015 isn’t about having “perfect” legal documents - it’s about having clear processes, fair contract terms, and a customer journey that matches what the law expects.
This guide breaks down what the CRA 2015 covers, what your customers can demand, and how you can set up contracts and policies that protect your business from day one.
What Is The Consumer Rights Act 2015 And When Does It Apply To Your Business?
The Consumer Rights Act 2015 is the UK’s main piece of consumer law covering the sale of:
- Goods (eg products you sell in-store or online)
- Digital content (eg apps, downloadable templates, software, digital subscriptions)
- Services (eg trades, creative services, coaching, repairs, hospitality)
It applies where you’re selling as a trader to a consumer:
- A trader is someone acting for business purposes (including sole traders and companies).
- A consumer is an individual acting mainly outside their trade, business, craft, or profession.
So if you’re selling to members of the public (B2C), the CRA 2015 will usually be front and centre. If you only sell B2B, the CRA 2015 generally won’t apply - but you’ll still have contract law obligations and other rules that can be just as important.
Common Small Business Examples Where CRA 2015 Applies
- An eCommerce store selling products to customers in the UK
- A hair, beauty, wellness or fitness business providing services to clients
- A trades business doing home repairs and renovations for homeowners
- A SaaS or digital product business selling subscriptions to individuals
- A hospitality business offering accommodation, food or events to consumers
Once you know the CRA 2015 applies, the key question becomes: what does it require you to do?
What Rights Do Consumers Have Under The Consumer Rights Act 2015?
The CRA 2015 sets out automatic rights consumers get when they buy from you. These rights sit in the background even if your terms and conditions don’t mention them.
That’s why a “no refunds” line in your policy can create more risk than protection - because if it conflicts with the CRA 2015, it likely won’t be enforceable (and it can damage trust with customers).
Goods Must Be Of Satisfactory Quality, Fit For Purpose And As Described
When you sell goods, the CRA 2015 says they must be:
- Of satisfactory quality (what a reasonable person would consider acceptable, taking price and description into account)
- Fit for purpose (including any specific purpose the consumer made known to you)
- As described (matching your website listing, labels, photos, and any statements made to the customer)
This is where small businesses can get caught out by marketing. If your product descriptions are vague, exaggerated, or inconsistent, you can end up with disputes even when you acted in good faith.
It also links closely to your broader obligations when dealing with faulty goods under UK consumer law - which is why many businesses choose to formalise this in their policies and Online Goods And Services Terms.
Services Must Be Provided With Reasonable Care And Skill
If you provide services, the CRA 2015 includes an implied term that you’ll carry out the service with reasonable care and skill.
That’s not saying you need to be perfect - it’s saying you need to meet the standard of a reasonably competent professional in your industry.
For service-based businesses, disputes often come down to expectations. This is why your scope, deliverables, timelines, and what’s “included” should be crystal clear in a Service Agreement.
Digital Content Also Has Protected Standards
Digital content (downloads, software, streaming, in-app purchases) must be:
- Of satisfactory quality
- Fit for purpose
- As described
If digital content damages a consumer’s device or other digital content, the consumer may have rights to repair the damage or claim compensation, depending on the situation.
If you run a SaaS product or online platform, it’s worth getting your legal foundations aligned across contracts and user-facing documentation such as SaaS Terms and your Website Terms And Conditions.
Refunds, Repairs And Replacements: What The CRA 2015 Means In Practice
The CRA 2015 doesn’t just say “be fair” - it sets out specific remedies (solutions) a customer can ask for when something goes wrong.
Understanding these remedies helps you do two important things:
- Respond to complaints quickly and lawfully
- Design your refunds and returns process so it’s consistent and defensible
For Goods: The 30-Day Short-Term Right To Reject
Where goods are faulty, not as described, or not fit for purpose, consumers usually have a short-term right to reject within the first 30 days and claim a refund.
That said, there are a few important timing nuances for small businesses to understand. The 30-day period can be affected by when the goods are delivered (and, for some goods, when installation is completed). If you agree to repair or replace during the short-term right-to-reject period, the “clock” may effectively pause while you carry out that remedy, and the consumer then gets further time to decide whether to reject if the fix doesn’t work.
For small businesses, the operational takeaway is simple: if a product is genuinely faulty, delaying or refusing a refund can escalate the issue quickly (chargebacks, negative reviews, or even formal complaints).
Also, how you handle timelines matters. A common question is “how long should a refund take?” and while the answer depends on the payment method and context, you should have an internal process so your team isn’t improvising each time.
After 30 Days: Repair Or Replacement First (Usually)
If the issue arises after the first 30 days, the consumer will usually be entitled to a repair or replacement first, as long as it’s possible and reasonable.
If repair or replacement isn’t possible, doesn’t work, or takes too long, the consumer can often move to a refund. This is sometimes described as the final right to reject (or, alternatively, a price reduction). In some cases, a deduction for use may be allowed, depending on the product type and timing.
Another key point: if a fault appears within the first 6 months, it’s generally presumed to have been present at delivery unless you can prove otherwise. After 6 months, the burden of proof is more likely to fall on the consumer.
For Services: Repeat Performance Or Price Reduction
If your service wasn’t performed with reasonable care and skill (or other CRA 2015 standards are not met), consumers may be entitled to:
- Repeat performance (redoing the service, where possible), or
- A price reduction (which can be up to 100% in serious cases)
This is why it’s worth documenting your work, scope changes, approvals, and client communications. A well-drafted contract helps, but your records often matter just as much when a dispute arises.
How To Make Your Contracts CRA 2015-Compliant (Without Overcomplicating Things)
If you sell to consumers, your contracts don’t just need to “look professional” - they need to be fair, clear, and consistent with the Consumer Rights Act 2015.
In practice, that means two big things:
- You can’t remove or reduce consumers’ core legal rights
- Your written terms must not create an unfair imbalance in your favour
Make Sure Your Terms Are “Fair” And Transparent
The CRA 2015 gives consumers protection against unfair contract terms. A term can be unfair if it creates a significant imbalance between the parties, to the consumer’s detriment, and contrary to good faith.
For small businesses, common examples of terms that can create trouble include:
- Very broad “we can change anything at any time” clauses
- “No refunds under any circumstances” statements
- Hidden fees or unclear pricing structures
- Harsh cancellation charges that don’t reflect real costs
- Overly one-sided limitation of liability clauses (especially if not clearly explained)
You can still protect your business - you just need to do it in a way that’s proportionate and understandable to an everyday customer.
If you use liability caps, the drafting needs to be careful (and context matters). Many businesses start with properly structured Limitation Of Liability Clauses and build from there.
Match Your Marketing And Sales Process To Your Terms
This is an underrated CRA 2015 compliance point: your “contract” isn’t only your written T&Cs. It includes what you tell the customer before they buy - including:
- Product descriptions
- Photos and videos
- Delivery promises
- Reviews you publish or promote
- “Guarantees” and claims
If your ad says “next day delivery” but your terms say “delivery times are estimates only,” you’ve created confusion. And confusion is where complaints and disputes grow.
Be Careful With Auto-Renewals And Subscriptions
If your business uses rolling subscriptions, membership renewals, or automatic billing, the legal risk isn’t just about charging customers - it’s about transparency and cancellation rights.
Even where auto-renewals are lawful, you should make sure your subscription journey is clear, fair, and not misleading, particularly around renewal dates, minimum terms, and how to cancel. This often sits alongside your CRA 2015 obligations and your broader subscription documentation.
It may also be worth aligning this with your Online Subscription Terms so your customer experience and contract terms are working together.
Practical CRA 2015 Compliance Steps For Small Businesses (A Simple Checklist)
Legal compliance can feel overwhelming if you treat it like a one-off project.
A better approach is to build small, repeatable processes that your team can follow (even if your “team” is just you right now).
1) Audit What You Sell And How You Sell It
Start by listing your core offerings and sales channels:
- Goods, services, digital content (or a mix)
- Online store, social selling, in-person, marketplaces, subscriptions
- Delivery methods and lead times
This matters because your obligations (and the most common customer complaints) often vary depending on what you’re selling.
2) Tighten Up Your Descriptions And Pre-Contract Information
Under the CRA 2015, what you say about the product or service becomes a big part of what the customer is entitled to receive.
Practical fixes include:
- Use accurate photos (avoid filters that change colour or size perception)
- Be specific about what’s included (and what isn’t)
- Clarify lead times, booking windows, and delivery limitations
- Avoid absolute claims unless you can back them up
3) Put A Clear Complaints, Refunds And Returns Process In Place
You don’t need a 30-page policy, but you do need consistency.
At a minimum, you should know:
- Who handles complaints and what information they collect
- How you confirm a fault or service issue
- When you offer refund vs repair/replacement vs repeat performance
- Your refund timelines and payment method process
This also helps you identify when a “goodwill refund” is a smart commercial decision versus when you’re dealing with a genuine legal entitlement.
4) Use Properly Drafted Consumer Terms (Not DIY Templates)
Templates can be tempting, especially when you’re watching every pound.
But with the CRA 2015, the risk isn’t just missing a clause - it’s having clauses that are unenforceable, unfair, or inconsistent with how you actually operate.
For many small businesses, it makes sense to formalise things with tailored Business Terms (or consumer-facing website terms) that reflect your real process.
5) Don’t Forget Distance-Selling Cancellation Rights (They’re Separate)
One common pitfall is mixing up CRA 2015 rights (faulty goods/services/digital content) with distance-selling cancellation rights for online, phone, and mail-order sales, which sit under separate rules (the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013).
In practice, this means a customer might have the right to change their mind and cancel within a cooling-off period for an online purchase even if nothing is “wrong” with the goods or service, and you’ll need your policies to deal with both regimes clearly.
6) Don’t Forget Data And Marketing Compliance
While the CRA 2015 is the focus here, many customer disputes sit alongside data issues (emails, delivery addresses, complaint handling, customer records).
If you collect personal data through your website or sales process, you’ll also want a compliant Privacy Policy and sensible internal practices for handling customer information.
Key Takeaways
- The Consumer Rights Act 2015 applies to most UK small businesses selling goods, services, or digital content to consumers, regardless of your size.
- Under the CRA 2015, goods must be of satisfactory quality, fit for purpose, and as described, and services must be delivered with reasonable care and skill.
- Customers can have specific remedies under the CRA 2015, including the 30-day short-term right to reject faulty goods (subject to timing nuances), repair or replacement rights, and the final right to reject (plus the 6-month presumption about faults).
- Your terms and conditions can’t remove consumers’ key statutory rights, and contract terms must be fair and transparent to be enforceable.
- Practical compliance is about aligning your marketing, customer journey, and written contracts - plus having a consistent refunds/complaints process that your business can follow every time.
- If your business sells online or by phone, remember that cooling-off cancellation rights come from separate distance-selling rules, not the CRA 2015.
- If your business uses subscriptions or auto-renewals, clarity around pricing, renewals, and cancellation is essential to reduce disputes and keep your contracts robust.
If you’d like help making sure your contracts and customer processes comply with the Consumer Rights Act 2015, you can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.


