TRW & Co · Consumer law
New Subscription Contract Rules under the DMCC Act
The new subscription contract rules under the Digital Markets, Competition and Consumers Act 2024 will require clear key information before sign-up, reminders before renewals, easy online exit and two 14-day cooling-off rights. Draft guidance says they apply to contracts made from 1 January 2027, subject to Parliament approving the Regulations laid in October 2026.
Key pointUnder the Consumer Rights Act 2015, most key and full pre-contract information becomes a contract term, so the renewal price and reminder window shown at sign-up bind the trader and cannot be changed without the consumer's agreement.
At a glance
Start date
Draft guidance says the rules apply to subscription contracts entered into on or after 1 January 2027, once Parliament approves the draft Regulations laid in October 2026.
Reminder notices
Written reminders on a durable medium are needed about every six months for rolling plans, twice before annual renewals and before a trial converts to paid.
Easy online exit
If consumers can join online they must be able to leave online, without unnecessary steps; an email address alone is not a straightforward online exit.
Two cooling-off rights
Consumers get a 14-day initial cooling-off period and a 14-day renewal cooling-off period after trials end and after renewals onto 12 months or more.
CMA fines
The CMA can enforce directly and impose penalties of up to £300,000 or 10% of global turnover, whichever is higher, for infringements.
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The short answer: what the new subscription contract rules require
The new subscription contract rules in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) require businesses that sell auto-renewing subscriptions to consumers to give clear key information before sign-up, send reminder notices before certain renewals, let consumers leave easily (online if they joined online), confirm exits in writing and honour two 14-day cooling-off rights. Breaching the core duties gives consumers a statutory right to cancel and can lead to refunds and enforcement by the Competition and Markets Authority (CMA).
As of October 2026, the regime is not yet in force. The government laid the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 in Parliament in October 2026 and published draft guidance alongside them. According to that guidance, the rules will apply to subscription contracts entered into on or after 1 January 2027, subject to Parliament approving the Regulations.
That leaves subscription businesses roughly ten weeks to rebuild sign-up flows, reminder systems and cancellation journeys. This guide explains what changes, who is affected and what to do now.
What changed and when it takes effect
The Digital Markets, Competition and Consumers Act 2024 received Royal Assent in 2024. Its subscription chapter needed secondary legislation before it could start. The Department for Business and Trade consulted on implementation and, in its April 2026 government response, said the regime would commence in spring 2027.
The timetable then moved forward. On 19 October 2026 the government published draft guidance on subscription contracts with the draft Regulations. The draft guidance states that the subscription contract rules apply to contracts entered into on or after 1 January 2027 and that final guidance will follow once the Regulations are made. Contracts entered into before that date stay under the existing rules, principally the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013.
For subscription contracts within scope, the new rules replace the 2013 Regulations' requirements on pre-contract information and cooling-off cancellation. The Consumer Rights Act 2015 and the DMCCA's unfair commercial practices provisions continue to apply alongside them.
Who is affected: scope and exclusions
A subscription contract is a contract between a trader and a consumer for goods, services or digital content, paid for in money or money's worth, which auto-renews or continues, with the consumer charged automatically, unless the consumer acts to stop it. Free or reduced-price trials that roll onto a paid or higher price are expressly included. The rules apply whether the contract is made online, by phone, on business premises or off-premises, for example on the doorstep.
Streaming services, software, gyms, meal kits, beauty boxes, news and media, membership clubs, car and product subscriptions, and app-based services are all likely to be caught. The draft guidance lists exclusions, including:
- utilities, including energy, heat networks, water and sewerage;
- financial products such as banking, credit, insurance, pensions and investments;
- telecoms contracts regulated by Ofcom;
- certain prescription and NHS-related healthcare supplies;
- residential accommodation, package travel, timeshares, childcare and gambling; and
- cultural and heritage memberships of charities, and very small local grocery delivery businesses.
Business-to-business subscriptions are outside the regime, but sole traders and individuals acting mainly for personal purposes are consumers, so platforms with mixed customer bases need to identify which users are protected.
The traders' duties in practice
The subscription contract rules impose a sequence of duties across the customer lifecycle.
- Key pre-contract information. Give the key information listed in the DMCCA, such as the price, how often payments are taken and when reminders will be sent, all together, prominently and separately from other information, as close as possible to the point of commitment. Online, it must be readable in the purchase journey without clicking a link.
- Full pre-contract information. Give or make available the full information, such as the product description and trader identity. Online it can sit behind a prominent, clearly labelled link, but it must then be sent on a durable medium, such as email, before supply starts.
- Express acknowledgement. For online contracts, the final step must expressly acknowledge the obligation to pay, for example a clearly labelled subscribe button. Otherwise the consumer is not bound.
- Reminder notices. Send written reminders on a durable medium before relevant renewal payments, within the reasonable period stated in the key information. Push notifications that cannot be retrieved are not enough.
- Easy exit. Let consumers end the contract at any time in a straightforward way, without steps that are not reasonably necessary. If they can sign up online, they must be able to leave online.
- End-of-contract notice. Confirm the end date in writing within 24 hours if the consumer leaves online, or within three working days if by other means.
- Timing of renewal payments. Do not make the consumer liable for a renewal payment before the new contract period starts; a term that does so has no effect.
How often reminders are needed
For rolling contracts that renew more often than yearly, such as monthly plans, a reminder is needed roughly every six months, tied to the last renewal payment in each "relevant six-month period". For contracts that renew onto a period of 12 months or more, an additional, earlier reminder is required before each renewal. Where there is a free or discounted introductory period, a reminder is needed before the first renewal payment at the higher price.
Reminders must make their purpose readily apparent, for example through a clear email subject line, and the required content must be more prominent than any marketing sent at the same time.
What an acceptable exit journey looks like
The draft guidance says the policy intention is that leaving should be as easy as signing up. A clearly labelled cancel button in an account page or app, or a simple web form, is likely to comply. An email address alone is not considered a straightforward online exit route. Retention offers and feedback requests are allowed only if they do not prolong the process or discourage the consumer from finishing, and feedback must not be compulsory.
Under the Consumer Rights Act 2015, most of the key and full pre-contract information becomes a term of the contract. If your sign-up page states a price, renewal frequency or reminder window, you are bound by it and cannot change it without the consumer's agreement. Treat the pre-contract screen as contract drafting, not marketing copy.
Cooling-off, cancellation rights and refunds
Consumers get two separate 14-day cooling-off rights. The initial cooling-off period runs from the day the contract is made or, if goods are supplied, from receipt of the first full supply of goods. A renewal cooling-off period starts when a free or discounted period ends and the consumer becomes liable to pay the higher price, and when a contract renews onto a period of 12 months or longer. Traders must send a cooling-off notice explaining the right and when the period ends.
If the trader fails to give the required information about the initial cooling-off right, the period is extended until 14 days after the information is given, up to a maximum of 12 months. Special rules apply to perishable, bespoke and hired goods and to digital content, where the consumer can in some cases waive the right.
| Right | When it applies | Effect |
|---|---|---|
| Initial cooling-off | 14 days from contract, or from receipt of the first full supply of goods | Cancel without reason or penalty; refund rules depend on goods, services or digital content |
| Renewal cooling-off | 14 days after a trial or discount ends, or after renewal onto 12 months or more | Cancel without reason or penalty; cooling-off notice required |
| Cancellation for breach | Breach of key information, reminder, reasonable reminder period or easy exit duties | Cancel within 12 months of the relevant date; payments from that date may become refundable |
| Contractual exit | At any time | Stops auto-renewal; supply continues to the end of the current period |
Refunds due after cancellation for breach must be paid without undue delay and in any event within 14 days from the day after cancellation. Where goods for sale were supplied, the consumer may not have to return them if they are no longer liable to pay.
Enforcement and penalties
Breaches of the subscription contract rules can be enforced by the CMA, Trading Standards and sector regulators through the courts, and by the CMA directly under its new consumer powers. Under direct enforcement the CMA can investigate, accept undertakings, issue infringement notices and impose penalties of up to £300,000 or 10% of global turnover, whichever is higher. The CMA explains its approach in its direct consumer enforcement guidance (CMA200), and our guide to DMCC Act consumer enforcement covers how the CMA has used the regime since April 2025.
There is also a criminal offence for failing to give consumers information about their initial cooling-off rights in off-premises contracts, such as doorstep sales. And consumers have private remedies: the statutory right to cancel for breach, refunds, and their ordinary contractual remedies, provided they do not recover twice for the same loss.
Illustrative scenario: a streaming app with a free trial
This example is illustrative only and uses generic parties.
A UK fitness streaming app offers a 30-day free trial that rolls onto a monthly plan, and an annual plan at a discount. Today, customers can cancel only by emailing support, and the app sends a push notification three days before the trial ends.
From 1 January 2027 the app will need a key information panel next to the subscribe button, a durable-medium reminder before the first paid month, a further reminder roughly every six months for monthly subscribers, and two reminders before each annual renewal. It must add an in-app cancel button and send an end-of-contract email within 24 hours of an online exit.
It must also handle renewal cooling-off cancellations after the trial ends and after each annual renewal, with refunds calculated for the digital service already used. Its current email-only cancellation route and push-only reminder would both fall short.
Common mistakes and risks
Relying on push notifications or in-app messages for reminders
Reminder notices must be given in writing on a durable medium, such as email, SMS or paper, so that the consumer can refer back to them. The draft guidance says pop-up or push notifications that are not retrievable would not meet the requirement. Failing to send a required reminder is a breach of a relevant implied term, giving the consumer a right to cancel and potentially recover payments made from the date the reminder should have been sent.
Building friction into the cancellation journey
Multiple screens of retention offers, compulsory exit surveys, phone-only cancellation and email-only routes for online customers are the practices the subscription contract rules target. The trader must not require steps that are not reasonably necessary to end the contract. A non-compliant exit route also triggers the consumer's statutory right to cancel for breach. Test the exit journey from a customer's perspective and keep records of how long it takes.
Burying key information in terms and conditions
Key pre-contract information must be given all together, prominently and separately from other information, close to the point of commitment. For online sign-ups, consumers must not have to click a link to read it. Putting the renewal price or reminder timing only in the terms and conditions is likely to breach the duty and, because the information also becomes a contract term, can create mismatches between the sign-up page and the contract.
Forgetting legacy customers and third-party channels
The rules apply to contracts entered into from 1 January 2027, so businesses will run two regimes in parallel for existing and new subscribers. Contracts sold through app stores, resellers or telephone agents still need to comply, and the trader remains responsible. Map every sales channel and agree with platform partners who sends reminders and handles exits. Our commercial contracts team reviews reseller and platform agreements.
Cross-border subscription businesses
The regime protects UK consumers, so overseas businesses selling subscriptions into the UK need to comply, and the CMA's direct enforcement powers extend to conduct with a sufficient UK connection. Businesses already complying with EU or other national rules on online cancellation will find some overlap, but the requirements are not identical. UK-specific reminder timing, cooling-off notices and end-of-contract notices need separate configuration.
Groups based in Bangladesh, the Gulf or Singapore offering apps or digital content to UK users should check whether their billing provider or app store supports the required notices and exits. Pricing presentation must also comply with the separate rules on drip pricing; see our guide to fake reviews and drip pricing.
What to do now: a checklist for the subscription contract rules
- Map every auto-renewing consumer product, trial and sales channel, and confirm which are excluded.
- Redesign sign-up flows with a separate key information panel and an express payment acknowledgement.
- Set and publish a reasonable reminder window, and build durable-medium reminders for six-monthly, annual and post-trial renewals.
- Add an online exit route for online customers and remove unnecessary steps.
- Automate end-of-contract notices within 24 hours or three working days.
- Build cooling-off notices, cancellation handling and refund calculations for goods, services and digital content.
- Align terms and conditions with the pre-contract information, and train customer service teams.
- Monitor the parliamentary approval of the draft Regulations and the final guidance.
TRW & Co's London office is authorised and regulated by the Solicitors Regulation Authority. Our consumer protection lawyers review subscription journeys, terms and reminder templates against the subscription contract rules, and our advertising and marketing team advises on pricing and promotions. To discuss your readiness, contact us at info@trw.co or on +880 1779 127165, or visit us at Holborn Gate, 330 High Holborn, London WC1V 7QH.
Frequently asked questions
01When do the new subscription contract rules come into force?
As of October 2026, they are not yet in force. The government laid the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 in Parliament in October 2026 and published draft guidance stating that the rules apply to subscription contracts entered into on or after 1 January 2027. The Regulations must be approved by Parliament before they can come into force. The government's April 2026 consultation response had pointed to spring 2027, so the date was brought forward.
02Do the rules apply to existing subscribers?
According to the draft guidance, the rules apply to subscription contracts entered into on or after 1 January 2027. Contracts entered into before that date continue under the existing law, mainly the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 and the Consumer Rights Act 2015. In practice many businesses will apply the new journeys to all customers to avoid running two systems, but they should take advice on how renewals of older contracts are treated.
03How many reminder notices must a subscription business send?
It depends on the renewal period. For rolling contracts that renew more often than yearly, such as monthly plans, a reminder is needed roughly every six months. For contracts that renew onto 12 months or more, an additional earlier reminder is required before each renewal. Where there is a free or discounted introductory period, a reminder is needed before the first payment at the higher price. Reminders must be in writing on a durable medium.
04Can businesses still make retention offers when customers cancel?
Yes, but carefully. The draft guidance says offers and feedback requests must not prolong the exit process or discourage the consumer from completing it, and feedback must not be compulsory. The overall test is that consumers can end the contract in a straightforward way without steps that are not reasonably necessary. A single, optional offer on the way out is more likely to comply than several screens of offers before the cancel button appears.
05Which subscriptions are excluded from the new rules?
The draft guidance lists exclusions including utilities, financial products such as banking, credit, insurance, pensions and investments, Ofcom-regulated telecoms contracts, certain prescription and health service supplies, residential accommodation, package travel, timeshares, childcare, gambling, cultural and heritage memberships of charities, and some very small local grocery delivery businesses. Business-to-business subscriptions are outside the regime because it protects consumers only. Check each exclusion's precise wording before relying on it.
06What happens if a business breaches the subscription contract rules?
Consumers can cancel the contract if the trader breaches the duties on key information, reminder notices, the reasonable reminder period or easy exit, generally within 12 months of the relevant date, and may recover payments made from that date. The CMA can investigate and impose fines of up to £300,000 or 10% of global turnover, whichever is higher, and courts can make enforcement orders. Failing to give cooling-off information in off-premises sales is also a criminal offence.
Sources and official materials
- Subscription contracts (GOV.UK) — Draft guidance published October 2026 with the draft Regulations
- Draft Guidance on Consumer Subscription Contracts — Traders' duties, cooling-off, refunds and enforcement
- Consultation on the implementation of the new subscription contracts regime — April 2026 government response
- Digital Markets, Competition and Consumers Act 2024 — Part 4, Chapter 2 subscription contracts
- Direct consumer enforcement guidance (CMA200) — CMA investigation and penalty powers
General information only, current as at 21 October 2026. It is not legal advice and does not create a solicitor–client relationship. It reflects the law of England and Wales unless stated otherwise; Scotland and Northern Ireland have separate legal systems, and the law changes frequently. Check current official sources and take advice on the facts of your matter.