The government has moved the start date for the UK’s new consumer subscription rules. The regime in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) will now take effect in January 2027 rather than the spring 2027 date announced earlier this year. The reasoning is seasonal: January is when consumers sign up to most new subscriptions.
The policy is aimed at tackling the “subscription trap”: easy sign-ups, inconspicuous renewals and cancellation processes that are often anything but straightforward. The government estimates that the UK has around 155 million active subscriptions, with consumers spending approximately £1.6 billion each year on subscriptions they no longer want.
For businesses, the practical consequence is narrower than the policy debate: 3 months of implementation time have disappeared, and the secondary legislation that supplies the operative detail has not been published yet.
Who is caught
The rules apply where a consumer pays for goods, services or digital content on a recurring basis under a contract that automatically renews and creates a new payment obligation at each renewal. Free trials and discounted introductory offers that automatically convert into paid subscriptions are also within scope. This includes, for example, streaming and digital media services, software and online services, gym and fitness memberships, subscription boxes and other recurring-delivery services.
“Consumer” means an individual acting wholly or mainly outside their trade, business, craft or profession, so business-to-business subscriptions sit outside the regime. Schedule 22 to the Act carves out sectors regulated elsewhere, including specified financial services, insurance, utilities, healthcare, residential tenancies, education and gambling.
The rules to follow the consumer rather than the trader, meaning that a business established outside the UK that markets subscriptions to UK consumers, accepts UK orders or takes UK payments should assume it is in scope, whatever the governing law of its terms.
On timing, the regime is expected to apply principally to contracts entered into from January 2027. Contracts signed before then are likely to be caught when they renew after that date, but the transitional provisions have not been published yet, so the safe assumption is that an existing subscription book rolling past January 2027 will need to comply, and that reminder notices and cancellation routes have to be ready for those customers too, not only new ones.
What changes, stage by stage
At sign-up: traders must give “key” pre-contract information separately from the full terms: that payments recur, how often the consumer will be charged, the amount, the minimum total payable, and when reminders will arrive. It has to be visible without the consumer clicking through to find it, and the final step must include an express acknowledgement that placing the order creates an obligation to pay.
Before renewal: reminder notices become mandatory. Broadly, a notice is due at least once in every six-month period before a renewal payment, or before each renewal where payments are less frequent, and it must arrive a reasonable period ahead (a period the trader sets and has to disclose). The notice needs to say when the renewal takes effect, what will be charged and how to cancel.
After renewal: there are now two cooling-off windows, not one. The first is the standard 14 days at sign-up. The second is new: 14 days to cancel after a renewal that triggers it – the first payment when a free or discounted trial converts, and any renewal that commits the consumer for 12 months or more. You must inform the consumer about both rights when they sign up, then send a separate notice each time the second window opens. If that notice is missing or wrong, the window runs for longer.
On exit: cancellation must be straightforward, without steps that exist only to slow the consumer down. Where the subscription was taken out online, the consumer must be able to end it online, and to switch off auto-renewal before the next renewal date.
Fail to give the required information, send the reminders or allow a clean exit, and the consumer may be entitled to cancel and claim a refund.
Who enforces it, and what is expected
This is Competition and Markets Authority territory, and the CMA’s toolkit changed in April 2025. It can now decide for itself that consumer law has been breached and impose penalties of up to 10% of worldwide turnover, without first going to court.
What to do between now and January
- Map every subscription product against scope, trials included, and identify anything relying on a Schedule 22 exclusion.
- Take the sign-up flow apart screen by screen: what is disclosed, where it sits, and whether the payment obligation is actually acknowledged.
- Establish whether reminder notices can be generated at all. This is usually a billing-systems point rather than a drafting one.
- Test the cancellation path end to end, including the online route and the auto-renewal switch.
- Decide how refunds for partial periods will be calculated.
Regulations and CMA guidance will fill the remaining gaps, particularly on durable medium, prohibited terms and proportionate refunds for digital content. If you need help assessing how this might affect your business, get in touch with us.
Image by Freepik.
