FairRenew

Guides › UK subscription rules: a compliance checklist

A compliance checklist for the new UK subscription rules

Last updated

Work through this list before the rules start. Each item links to the guide or the law behind it. It is a practical list, not a full statement of the law.

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".

1. Check whether you are covered

  • Do you sell to consumers (not businesses) on a rolling, auto-renewing, free trial or introductory-price basis? (section 254)
  • Does anything you sell fall in the excluded list? (Schedule 22)
  • Can you tell which subscriptions started on or after the start date? The rules apply to new contracts only. (section 275)
  • Decide whether to extend reminders to existing customers. The draft guidance calls it best practice.

2. Your sign-up page

  • Key information shown together, apart from everything else, as close as practicable to the point of sign-up, with no click needed to read it. (section 256) The draft guidance suggests the same screen as the subscribe button.
  • It includes the payment amount and frequency, the minimum total, how to cancel, any notice period, the period in which you send reminders, and a cooling-off summary. (Schedule 23 Part 1)
  • For trials and offers: the date the first charge or higher charge happens.
  • A clear link to the full contract information.
  • The final step makes the customer expressly acknowledge they will have to pay. (section 257)
  • Delivery restrictions and accepted payment methods visible during checkout. (section 257)

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

3. Straight after sign-up

  • Email a copy of the full contract information as soon as reasonably practicable, before supply begins, if you did not give it in a lasting form before. (section 257)
  • Digital content that starts straight away: record the customer's express consent and acknowledgement, and confirm both in a lasting form. (draft regulation 7)

4. Reminders

  • Before the first payment after a trial or introductory price. (section 258)
  • Before the last payment in each six-month block. (section 258)
  • Two reminders before each annual renewal. (section 259)
  • Sent within the period you stated at sign-up, and before the last day to cancel. (section 259)
  • Every required fact included (Schedule 23 Part 3), all together and more prominent than anything else in the message (section 259). The draft guidance suggests putting them first.
  • Sent by email or another durable medium, clearly a reminder. (draft regulation 34)

Details: subscription reminder notices.

5. Cooling-off

  • A separate cooling-off notice on the day of each relevant renewal (or as soon as reasonably practicable after): the first payment after a trial or offer, and each annual renewal. (section 266)
  • It states the dates, how to cancel, when the right can be lost and the refund position. (draft regulation 36)
  • Your refund wording matches what you sell: services, digital content or goods.

Details: cooling-off periods explained.

6. Cancelling

  • An online way to leave, if customers join online, that is easy to find and has no unnecessary steps. (section 260)
  • No compulsory survey; any retention offer quick to skip.
  • A way to record cancellations that arrive by email, phone or post.
  • A confirmation of the end date within 24 hours (online) or 3 working days (otherwise). (section 261)

Details: how to let customers cancel online.

7. Refunds and charging

8. Records

  • Keep the key information you showed, the acknowledgement, and a copy of every notice with when and to whom it was sent. You carry the burden of proof. (section 272)
  • Keep records for at least as long as customers can bring claims: under the draft regulations, up to 12 months after a missed notice (Part 3), and cooling-off periods can be extended by up to 12 months (Part 2, Chapter 2).

9. Keep an eye on

Common questions

What do UK subscription businesses need to do before 1 January 2027?

Update the sign-up page with the key information and an acknowledgement step, set up reminder, cooling-off and cancellation confirmation emails, provide a straightforward online way to cancel, plan for 14-day refunds (under the draft regulations), and keep records. The start date is still subject to Parliament.

Do I need a solicitor to comply with the subscription rules?

The rules are detailed and parts are still draft. Checklists and tools help, but if you are unsure how they apply to your business, a qualified adviser can check your position.

How long should I keep records of subscription notices?

There is no express record-keeping duty, but you must be able to prove you sent the notices. Under the draft regulations, customers can claim up to 12 months after a missed notice, and cooling-off periods can be extended by up to 12 months.

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.

More guides