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Subscription reminder notices: what they must say and when (with example wording)

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Reminder notices are the part of the new rules most likely to need a change to your emails. This guide covers which payments need one, when to send it, what it must say, and gives an example you can adapt.

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".

Which payments need a reminder

Section 258 of the Act decides which payments need a reminder. It talks about "renewal payments": any payment the customer could avoid by ending the subscription.

Rolling subscriptions with no trial or offer

Think in six-month blocks. The first block starts the day after the customer signs up. You must send a reminder before the last renewal payment in each block (or, if no payment falls in a block, before the first one after it). The next block starts the day after that reminded payment.

Free trials and introductory prices

You must send a reminder before the first renewal payment. For a free trial, that is the first paid payment. Under draft regulation 33, where a fixed lower price runs over several payments, the reminder goes before the first payment at the higher price instead. After that, the six-month blocks start from the day after that payment. See free trials and introductory offers.

Examples from the draft guidance

SubscriptionReminder needed before
Monthly, started 1 JuneThe 1 December payment, then the 1 June payment the year after, and so on
Billed every 9 or 12 monthsEvery renewal payment
First week free, then weeklyThe first paid week
First month half price, then monthlyThe first full-price payment
50%, 25% and 10% off in months 1 to 3, then full priceThe month 2 payment (25% off), because it is the first renewal payment
£30 a month, with the first 3 months at £15The month 4 payment of £30, with none before months 2 and 3 (draft regulation 33)

Annual plans need two reminders

If the next payment is due 12 months or more after this one, or there is no further payment but the contract runs on beyond 12 months, you must also send an additional, earlier reminder before the standard one, at a time that is reasonable for that extra notice (section 259). In practice, customers on annual plans get two reminders before each renewal. The Act counts the 12 months from the day before the payment, so an annual plan billed on the same date each year qualifies. No number of days is set for either reminder.

How far ahead to send it

The Act, the draft regulations and the draft guidance set no fixed number of days. Instead, under section 259:

  • at sign-up, you tell the customer the period in which you will send reminders (it is part of the key information);
  • each reminder must be sent within that period;
  • the period must end before the "last cancellation date", the last day the customer can end the subscription and avoid the payment;
  • the period must be reasonable for letting the customer know the payment is coming, and for letting them decide and act before they have to pay.

If your terms need notice to cancel (say, 7 days), the reminder has to arrive early enough to leave room for that too. A period that is not reasonable is itself a breach, which can let the customer cancel and claim a refund.

As a starting point, FairRenew sends reminders between 14 and 7 days before the payment, and the early annual reminder between 45 and 30 days before. These are our defaults, not numbers from the law, and sellers can change them. Whether a period is reasonable depends on your product and your notice terms, and no one can yet say for certain what a court or the CMA will accept.

What a reminder must say

Schedule 23 Part 3 to the Act lists what goes in a reminder. In plain English:

The reminder must sayWhen
That the customer will have to make the payment unless they take steps to end the subscriptionAlways
The date they become liable for the payment, and the amountAlways
The amount of the previous renewal paymentIf there was one
That this payment is higher than the previous one, and by how muchIf it is higher
How often further automatic payments will be made, and the least amount of each (or how it is worked out)If more payments follow automatically
The amount of the equivalent payments the customer has been liable for since the previous renewal paymentIf more payments follow automatically
That those further payments are, or may be, higher than those equivalent payments, and by how muchIf so
The least the customer will have to pay in total if they do not end it before the payment date (or how it is worked out)Always
The date of the next renewal payment after this one, or the date the contract ends if there is noneAlways
How to end the subscription to avoid further payments, including contact details and the deadline for doing soAlways

Where an amount cannot be known in advance, for example with usage-based pricing, the Schedule lets you explain how it is worked out instead.

The three rows about further payments come from paragraphs 34 to 36. Paragraph 34 talks about further payments "ignoring any subsequent renewal payment", and the draft guidance does not explain how these items apply to a plain rolling plan, or exactly which payment counts as the "previous renewal payment". To be safe, FairRenew includes them whenever more payments follow automatically, counting from the previous reminder (or from sign-up). This is a point worth checking with an adviser.

How to send it

  • In writing, in a lasting form. Draft regulation 34 requires a "durable medium". Email counts. The draft guidance says push notifications and in-app pop-ups that cannot be kept and found again do not.
  • All together, and most prominent. The required facts must be given all together and be more prominent than anything else in the message (section 259). The draft guidance suggests that putting them first is one way to do this.
  • Obviously a reminder. It must be readily apparent that the message is telling the customer a payment is coming, so they can decide whether to end the subscription (draft regulation 34). The draft guidance says the email subject line could make this clear.
  • Never combined with a cooling-off notice. Cooling-off notices must be sent separately from any other information (section 266), so keep the two apart.

The rules do not require a reminder to be sent on its own: other content may go in the same message if the required information is more prominent. A plain, dedicated email is the simplest way to meet the prominence and "readily apparent" tests.

Example reminder email

Here is an example for a monthly subscription that started on 1 January 2027 and costs £12 a month. The first six-month block runs to 1 July 2027, so the 1 July payment needs a reminder. In this example the business takes payment early on the renewal day, so its terms say customers must cancel by the end of the day before.

Example only. Change the details to match your product and your terms.

Subject: Important: your Coffee Club subscription will renew on 1 July 2027 (£12.00)

Hi Sam,

This is a reminder that your Coffee Club subscription with Hilltop Coffee Club will renew soon.

Unless you take steps to end your subscription, you will have to pay £12.00 on 1 July 2027.

Your previous payment, on 1 June 2027, was £12.00.

After that, unless you end your subscription, you will pay £12.00 every month.

Since 1 January 2027 you have paid £72.00 in 6 payments.

If you do not end your subscription before 1 July 2027, the least you will have to pay is £12.00.

Your next payment after that is due on 1 August 2027.

To avoid this payment, end your subscription by 11:59pm on 30 June 2027.
You can end it online in a few steps here: https://hilltop.example/cancel
You can also email hello@hilltop.example saying you want to end your subscription.

If you want to keep your subscription, you do not need to do anything.

This is a service message about your contract with Hilltop Coffee Club. It is not marketing.

For a trial or introductory offer, the opening line changes (for example, "your free trial is ending, and paid billing will start"). If the payment, or the payments after it, are higher than before, the reminder must also say so and by how much. You can read every notice FairRenew sends, in full, in our demo.

Common mistakes to avoid

  • Relying on a generic "your payment is coming up" email that leaves out required facts, such as the cancellation deadline or the least the customer will pay.
  • Forgetting the end of a discount. A coupon such as "50% off for 3 months" is an introductory offer, so the first full-price payment needs a reminder.
  • Sending only one reminder before an annual renewal.
  • Sending outside the period you promised at sign-up, for example because a scheduled job stopped running.
  • Putting the reminder below promotions, or sending it only as a push notification.
  • Not keeping a copy. If a customer disputes it, you must be able to show you sent it (section 272).

Common questions

How many days before a renewal must a subscription reminder be sent?

No fixed number of days is set in the Act, the draft regulations or the draft guidance. You state the period at sign-up, each reminder must be sent within it, and the period must be reasonable and end before the last day the customer can cancel to avoid the payment.

Do I have to send a reminder before every monthly payment?

No. For a rolling monthly plan without a trial or offer, a reminder is needed before the last payment in each six-month block, so roughly twice a year. Plans billed every 9 or 12 months need one before every renewal.

Can a subscription reminder be a push notification or in-app message?

The draft regulations require a durable medium. The draft guidance says non-retrievable push notifications and pop-ups do not qualify. Email does.

Can I include marketing in a reminder email?

The rules do not forbid it, but the required information must be given all together and be more prominent than anything else. A reminder must never be combined with a cooling-off notice, which has to be sent separately.

What happens if I miss a reminder?

Under the draft regulations, the customer can cancel within 12 months of the payment that should have had a reminder. Payments from that one onwards are then cancelled and refunded within 14 days, although the amount can be reduced if the customer delayed unreasonably.

Do annual subscriptions need two reminders?

Yes. Where the next payment is due 12 months or more after this one (the Act counts from the day before the payment), it requires an additional, earlier reminder before the standard one.

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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