Cooling-off periods for subscription renewals explained

Two kinds of cooling-off period

Under section 264 and section 265, a customer can cancel a subscription without penalty during a cooling-off period. There are two kinds:

• The initial period starts when the contract is made. For services and digital content it ends at the end of the 14th day after the day of sign-up. For goods it ends at the end of the 14th day after the customer receives the first complete delivery.
• A renewal period starts on the day of a "relevant renewal" and ends at the end of the 14th day after it.

Cancelling in a cooling-off period is not the same as ending a subscription. Ending stops future renewals, and the customer keeps what they paid for until the end of the current period. Cancelling brings the contract to an end and can mean a refund.

Which renewals count

A renewal is "relevant" (section 265) when the customer becomes liable for:

• the first payment after a free trial or introductory price ends; or
• a renewal payment where the next payment is due 12 months or more later (the Act counts the 12 months from the day before the payment), or where there is no further payment but the contract runs on beyond 12 months. In practice, each annual renewal.

Ordinary monthly renewals on a plan that never had a trial or offer do not start a new cooling-off period. The draft government guidance reads the rules the same way.

Counting the 14 days

The Act says the period ends "at the end of the period of 14 days beginning with the day after" the renewal (or sign-up). The day after is day 1, so the last day to cancel is 14 days after the renewal day:

A customer's cancellation counts if they send it before the period ends, even if you receive it later (section 272).

The cooling-off notice

At each relevant renewal you must send a cooling-off notice (section 266 and draft regulation 36). It must be:

• sent on the first day of the renewal cooling-off period, or as soon as reasonably practicable after;
• in writing in a lasting form, such as email;
• sent separately from any other information: not inside a receipt, a reminder or a newsletter;
• clearly about the right to cancel and what happens if the customer uses it.

It must tell the customer:

1. that the subscription is continuing;
2. that they can cancel during the cooling-off period without penalty;
3. when the period begins and ends;
4. how to cancel;
5. any circumstances in which they could lose the right;
6. what happens if they cancel: any refund, any reason it may be reduced and, for goods, whether they must send them back;
7. for goods that must be returned and cannot normally go by post, the likely cost of returning them (draft regulation 36).

There is no separate notice for the initial period. The initial cooling-off information goes in the key information before sign-up and in the full contract information.

Example cooling-off notice

Here is an example for an annual online class membership (a service) that renewed on 1 March 2028.

Subject: Your right to cancel: your Riverside Yoga Online subscription has renewed

Hi Sam,

Your Riverside Yoga Online subscription with Riverside Yoga has renewed and is continuing.

You have a right to cancel it during a cooling-off period, without penalty and without giving a reason. The cooling-off period began on 1 March 2028 and ends at the end of the day on 15 March 2028.

How to cancel: use this page https://riverside-yoga.example/cancel or send a clear statement that you want to cancel to hello@riverside-yoga.example.

You will not lose this right to cancel during the cooling-off period.

If you cancel during the cooling-off period, we will refund the renewal payment within 14 days of your cancellation, to the payment method you used. We may keep an amount in proportion to the service you received from 1 March 2028 until you cancelled, and will refund the rest.

Riverside Yoga, 1 High Street, Anytown. Contact: hello@riverside-yoga.example.

Refunds after a cooling-off cancellation

• Timing and method. Refund without undue delay and within 14 days, starting the day after cancellation (for returned goods, from when you get them back or the customer shows they sent them, if earlier), to the same payment method unless the customer expressly agrees otherwise (draft regulation 21).
• Services. You may keep a proportionate amount for the service provided up to cancellation, but only if you met the conditions: for a renewal period, that you sent a compliant cooling-off notice; for the initial period, that you gave the initial cooling-off information and the customer gave express consent to the service starting during it, in writing on a durable medium if the contract was made off-premises (draft regulation 19). The draft guidance's example is a £365 annual service cancelled on day 4, where the business may keep £4.
• Digital content. In a renewal period you may keep a proportionate amount only if you sent a compliant cooling-off notice (draft regulation 20). In the initial period, a customer loses the right to cancel once supply begins only if they expressly consented to it starting, acknowledged they would lose the right, and you confirmed both in a lasting form (draft regulation 7).
• Goods. Separate rules cover returns, perishable or personalised goods, sealed goods and hired goods (draft regulations 12 to 18).
• Full refunds are always allowed. The proportionate amount is the most you may keep. The draft guidance says you can refund in full if working it out is a burden.

If you do not send it

If you do not give a compliant cooling-off notice, the renewal cooling-off period does not end on day 14. Under draft regulation 6 it runs until 14 days after you do give the information, or for up to 12 months after the original end date if you never do. You also lose the right to keep a proportionate amount for services or digital content.

Sources

We link to the law itself wherever we can. Section and regulation links in the text go to legislation.gov.uk.

• Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 2 (subscription contracts) Law, not yet in force (a few provisions only so regulations can be made)
• The Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 Draft, awaiting approval by Parliament
• Guidance on the subscription contracts rules (GOV.UK, 19 October 2026) Draft (the PDF cover says "Draft Guidance")