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Free trials and introductory offers under the new UK subscription rules

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Free trials and "first month half price" offers get extra attention in the new rules. Here is what changes, with a worked timeline for a typical 30-day trial.

Where things stand (3 November 2026): the Digital Markets, Competition and Consumers Act 2024 is law, but its subscription chapter is not yet in force. The detailed regulations are a draft that Parliament has not yet approved, and the government's guidance is also a draft. The intended start date is 1 January 2027, for contracts entered into on or after that date. Anything taken from a draft is labelled "draft".

Are trials and offers covered?

Yes. Section 254 of the Act covers contracts where the customer gets something free, or at a lower price, for a set period and then becomes liable to pay (or pay more) automatically unless they end the contract first. That includes cases where the business can choose to start charging. The Act calls the free or cheaper part a "concessionary period". The draft government guidance describes it as "free or reduced-cost periods which auto-renew onto a full or higher price period".

Before sign-up

As well as the usual key information (see the overview), you must tell the customer that they will be charged, or charged more, unless they end the contract before that happens, and the date it happens (Schedule 23 Part 1). The draft guidance says the information must cover both the trial and how the contract runs after it.

Part of the key information only, for a trial starting on 1 March 2027.

Free for 30 days, then £10 a month.
Unless you cancel before 31 March 2027, you will be charged £10.00 on that date and then £10.00 every month until you cancel.

Our free sign-up wording generator drafts the full key information and the acknowledgement tick box.

The reminder before the first full payment

For a trial or introductory offer, a reminder is due before the first renewal payment (section 258). For a free trial, that is the first paid payment. If a fixed lower price runs over several payments and ends on a set day, the reminder goes before the first payment at the higher price instead (draft regulation 33). Examples from the draft guidance:

  • First week free, then weekly: a reminder before the first paid week.
  • First month half price, then monthly: a reminder before the first full-price payment.
  • £30 a month, with the first 3 months at £15: a reminder before the month 4 payment of £30, and none before months 2 and 3.

The reminder must contain the usual list of facts, including that the payment is higher than the last one and by how much, and be sent within the period you stated at sign-up (see reminder notices).

A new cooling-off period when the offer ends

The first payment after a trial or introductory price is a "relevant renewal" (section 265). On that day a renewal cooling-off period starts, lasting until the end of the 14th day after it, and you must send a separate cooling-off notice (section 266). See cooling-off periods for renewals.

Worked example: 30-day free trial, then £10 a month

WhenWhat you need to do
Sign-up, 1 March 2027Key information on the sign-up page, close to the button, including the 31 March first payment date. The customer acknowledges they will pay. Send a copy of the contract information by email. For a service or digital content, the initial cooling-off period runs to the end of 15 March.
Before 31 March, within your stated periodReminder before the first payment of £10.
31 March 2027First payment. Send the separate cooling-off notice that day, or as soon as reasonably practicable after. The renewal cooling-off period runs to the end of 14 April.
From then onA reminder before the last payment in each six-month block, starting the day after the first payment. Here, that is the 30 September 2027 payment (if you bill on the 30th in shorter months). How the six-month boundaries are counted is not yet settled.

Things that catch people out

  • Coupons are offers too. "50% off for your first 3 months" is a concessionary period, even though it is not called a trial.
  • Stripe's trial email is fixed at 7 days and does not cover coupons (see our Stripe guide).
  • The date matters. The key information must give the date the first charge (or higher charge) arises, not just "after your trial".
  • Two notices, not one. The reminder comes before the first full payment; the cooling-off notice comes on the day of it (or as soon as reasonably practicable after), separately.
  • Cancelling during the trial must be as straightforward as at any other time.

Common questions

Do free trials count as subscriptions under the new UK rules?

Yes, if the trial moves automatically to a paid subscription unless the customer ends it first. The Act calls the free or discounted part a concessionary period.

When must I remind customers that a free trial is ending?

Before the first paid payment, within the reminder period you stated at sign-up. No fixed number of days is set, but the period must be reasonable and end before the last day the customer can cancel.

Does a discount coupon count as an introductory offer?

If a lower price applies for a set period and then moves automatically to a higher price, yes. The first payment at the higher price needs a reminder, and starts a renewal cooling-off period.

Is there a cooling-off period after a free trial ends?

Yes. The first payment after a trial or introductory offer is a relevant renewal, so the customer gets a further 14 days to cancel and you must send a separate cooling-off notice.

What must I tell customers before they start a free trial?

Among other things, that they will be charged unless they end the contract before it happens, the date it happens, how often they will pay and how much, and how to cancel.

Sources

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

This is not legal advice. It is a plain-English summary of published rules, several of which are still in draft, written to help small businesses understand them. FairRenew sends notices; it does not give legal advice. Check your own position with a qualified adviser.

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