The UK Government has confirmed significant reforms to the rules governing consumer subscription contracts. These changes are expected to be introduced in spring 2027, through secondary legislation under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), following the conclusion of the Department for Business and Trade’s consultation.
Unlike the current rules, which were never designed with modern subscription models in mind, the new rules will introduce a dedicated framework covering all consumer subscription contracts. This includes subscriptions for goods, services, digital content, or any combination of the three. Importantly, free trials and discounted introductory offers will also fall squarely within the new regime.
Two Statutory Cooling-Off Periods
The new framework introduces two distinct cancellation windows:
- Initial 14-day cooling-off period
This mirrors the current position under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, allowing consumers to cancel shortly after signing up. - New 14-day cooling-off period at key renewal points
Consumers will gain a new, second statutory right to cancel:
• When a free or discounted trial ends, and
• When a subscription lasting 12 months or more renews.
This is a significant departure from the current rules. It gives consumers a clear opportunity to reconsider before payments begin and before a long-term commitment rolls over automatically.
Clearer and More Prominent Pre-Contract Information
Businesses will be required to provide a concise, pre-contract summary of key terms before a customer signs up. This must be clearly set out:
- pricing;
- renewal arrangements;
- trial terms;
- cancellation rights;
- minimum commitment periods; and
- any key limitations or conditions.
This information must be easy to find and easy to understand, rather than buried in lengthy terms and conditions or hidden behind multiple links.
Mandatory Renewal Reminders
To reduce the risk of customers being charged unexpectedly, businesses will be required to send reminders:
- before a free trial converts into a paid subscription;
- before an annual or other long-term subscription renews; and
- at appropriate intervals for ongoing subscriptions.
Reminders must be sent via a durable medium (such as email or SMS) and must clearly explain how the consumer can cancel.
‘Easy Exit’ Cancellation Requirements
The DMCCA introduces strict standards for subscription cancellations. Where a customer signs up online, they must be able to cancel online, without unnecessary friction or delay.
Businesses must ensure that:
- cancellation routes are simple and clearly signposted;
- customers can cancel in just a few steps;
- no ‘Dark Patterns’ are used to discourage cancellation; and
- cancellations are confirmed promptly.
Updated Refund Rules for Services, Digital Content and Goods
The new regime introduces clearer, subscription-specific refund rules.
Services
Consumers should only pay for what they have genuinely used. Refunds must reflect the real value of the service provided, with specific rules applying to mixed subscriptions and one-off onboarding benefits. Refund rights apply during all cooling-off periods.
Digital Content
Once a consumer starts using digital content, the right to a refund is generally lost. However, businesses must explain this clearly up front. Where digital content forms part of a wider subscription, each element must be assessed separately.
Goods
Full refunds remain the default position unless the goods fall within recognised exemptions, such as bespoke or perishable items.
Stronger Enforcement and Consequences for Non-Compliance
The Competition and Markets Authority (CMA) will have enhanced powers, including the ability to:
- issue binding directions;
- impose significant financial penalties; and
- intervene proactively where subscription practices appear unfair.
Where businesses fail to comply with information, reminder or cancellation, consumers may also benefit from extended cancellation and refund rights.
As a result, the regulatory risk profile for subscription businesses will increase significantly.
What Businesses Should Do Now
Although the new rules are not expected to take effect until Spring 2027, early preparations will be key. Businesses should start by:
- reviewing sign-up flows and customer journeys;
- implementing automated reminder systems;
- updating cancellation processes to meet “easy exit” standards;
- revising terms and conditions and pre-contract disclosures;
- assessing refund processes for mixed subscriptions; and
- training customer service and compliance teams
Businesses that rely heavily on free trials, discounted introductory offers or annual renewals are likely to see the most significant impact.
How We Can Help
The Commercial Law team at Swinburne Maddison are about to support businesses which will be affected by the incoming law effecting consumer Subscription Contracts by:
- assess your existing subscription models and identifying where changes will be required under the new rules, including sign up flows, trial structures, renewal practices and cancellation routes;
- reviewing and redesigning customer journeys to ensure compliance with pre contract information, reminder and “easy exit” obligations;
- updating contractual documentation, including terms and conditions, pre‑contract summaries and renewal notices;
- evaluating refund processes, particularly for subscriptions involving services, digital content and goods; and
- advising on regulatory risk, including the impact of the CMA’s enhanced enforcement powers and steps to mitigate exposure.
Whether you operate a digital platform, a subscription box service, a membership model or a hybrid offering, we can help you navigate the new regime and prepare for a smooth transition ahead of implementation in 2027. For more information, please contact Jenny Wade, Partner and Head of Commercial Law at Jenny.Wade@swinburnemaddison.co.uk or call our team on 0191 384 2441.
