New Requirements Accelerated for UK Consumer Subscription Contracts

Multinational consumer-facing businesses are subject to a global patchwork of consumer protection laws and regulations, all of which create a complex regulatory landscape. Requirements around consumer subscription contracts are rapidly evolving and increasingly divergent across national regimes. Businesses offering subscriptions to UK consumers must prepare for new requirements related to transparency, reminders, cooling-off periods, and cancellation rights from January 2027.

New UK Consumer Subscription Contract Regime

The UK government has announced that the new consumer subscription contract regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) will come into force in January 2027, bringing forward the previously anticipated spring 2027 implementation date. 

The regime is intended to address “subscription traps” by requiring businesses to provide clearer information when consumers subscribe, issue regular renewal reminders, introduce additional cancellation rights, and make subscriptions easier to terminate. The regime is regulated by the Competition and Markets Authority (CMA) which, as of April 2025, gained enhanced enforcement powers under consumer protection legislation, including the ability to impose significant financial penalties which may reach up to 10% of global annual turnover.

Which Contracts Are in Scope?

Broadly, the new rules will apply to contracts under which a consumer pays for goods, services, or digital content that renew on an ongoing basis and automatically create further payment obligations. This includes subscriptions that begin with a free or discounted trial before converting into a paid arrangement. A “consumer” in this context means an individual acting wholly or mainly outside their business, with “business” defined to include a trade, craft, profession, or any other undertaking carried on for gain or reward. The subscription rules therefore do not extend to business-to-business arrangements, such as subscriptions offered to corporate entities.

From a territoriality perspective, the regime is expected to apply to businesses contracting with UK consumers, irrespective of where the business is established or the contract’s governing law. Businesses outside the UK may be subject to the regime if their contracts have a sufficiently close connection with the UK — for example, if they market subscriptions to UK consumers or accept UK orders or payments. Certain sectors and contract types will be excluded, including specified financial services, insurance, utilities, healthcare, residential rental, education, and gambling arrangements.

From a timing perspective, the regime is currently expected to apply primarily to contracts entered into as of January 2027, although the treatment of contracts concluded before then (particularly on renewal) will need to be considered based on a fact-specific assessment against the final transitional provisions and implementation guidance.

New Requirements

• Businesses will need to provide prescribed subscription-specific information immediately before the consumer enters into the contract. This information must be presented separately from the full pre-contract information, including the general terms and conditions. In addition, this information must be presented prominently and must explain matters such as the subscription’s auto-renewal mechanics, payment frequency, minimum commitment, price changes, renewal reminders, and cancellation rights. Consumers will have to acknowledge the fact that placing the order creates an obligation to pay.
• Consumers must receive reminders before subscriptions renew. The timing and frequency will depend on the nature of the subscription, with particular requirements applying when a trial converts into a paid subscription or a renewal commits the consumer for 12 months or more. Reminders must provide sufficient time to cancel and explain the renewal date, payment amount, and cancellation process.
• In addition to the initial 14-day cooling-off period upon entering into the contract (aligned with existing requirements), consumers will receive a new 14-day renewal cooling-off period in which they can cancel without penalty following the end of a free or discounted trial and on renewals for 12 months or more. Businesses must notify consumers of these rights upon entering into the contract and must also give the consumer a separate cooling-off notice on the first day of each renewal cooling-off period, or as soon as reasonably practicable afterwards. A failure to provide the required information may extend the relevant cooling-off period.
• Businesses must provide a straightforward termination process. In particular, for subscriptions concluded online, consumers must be given the ability to terminate online and must generally be able to switch off auto-renewals at any time before the next renewal.

If a business fails to provide the required subscription-specific information or renewal reminders to consumers, or to facilitate contract termination, the consumer may be entitled to cancel the contract and receive a refund. 

Next Steps

Businesses offering subscriptions to UK consumers should review their consumer journeys, pre-contract disclosures, reminder systems, cancellation processes, and refund arrangements ahead of January 2027. The detailed requirements will be supplemented by secondary legislation and CMA guidance, but early preparation is important given the operational changes involved and the potential consequences of non-compliance.