The new UK subscription rules: a plain-English guide for small businesses

The short version

The government intends the rules to apply to consumer subscriptions that start on or after 1 January 2027, if Parliament approves the detailed regulations in time. For each new subscription you will need to:

• Show key information before sign-up, as close as practicable to the moment they subscribe, and get the customer to acknowledge that they will have to pay.
• Send a copy of the contract information by email (or another lasting form) soon after sign-up and before supply begins, if you did not already give it in a lasting form.
• Send reminders before certain payments: before a free trial or introductory price ends, then before the last payment in each six-month period (about twice a year on a monthly plan), and twice before each annual renewal.
• Send a separate cooling-off notice when a trial or introductory offer turns into a full-price payment, and when an annual plan renews. The customer then has 14 days to cancel.
• Make leaving easy, online if they signed up online, and confirm the end date in writing (within 24 hours if they told you online).
• Refund within 14 days (under the draft regulations) when someone cancels in a cooling-off period.

Business customers are not covered, and some sectors are excluded. The rest of this guide takes each point in turn and links to the law it comes from.

Where the law stands, and what is still draft

The rules are in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act, sometimes written DMCCA). The Act is law, but legislation.gov.uk still marks this chapter as "prospective": it is not in force yet.

Much of the detail is in the Consumer Subscription Contracts (Cancellation and Information) Regulations 2026. These are a draft. They were laid before Parliament on 19 October 2026 and need the approval of both Houses before they can be made. Regulation 1 of the draft says they come into force on 1 January 2027.

On the same day the government published draft guidance on the subscription contracts rules on GOV.UK. Guidance is not law, but it shows how the government reads the rules. Final guidance is expected once the regulations are made.

One more step is needed: regulations that switch on the Act's subscription chapter (commencement regulations). legislation.gov.uk showed none for this chapter as of 3 November 2026. So 1 January 2027 is the government's stated intention, not yet a certainty.

In these guides, anything that comes from the draft regulations or the draft guidance is labelled "draft".

Does it apply to my business?

Under section 254, a contract is a subscription contract if it is between a business and a consumer, for goods, services or digital content, and either:

• it renews or continues automatically, with the customer paying automatically until they end it (for example a rolling monthly plan, or an annual plan that renews itself); or
• it starts free, or at a lower price, for a set period and then moves automatically to paid, or to a higher price, unless the customer ends it first (free trials and introductory offers).

Points that often come up:

• Consumers only. A consumer is an individual acting wholly or mainly outside their business. Subscriptions sold to businesses are not covered.
• Every sales channel. The draft government guidance says the rules apply whether people sign up online, by phone or in person.
• New contracts only. The chapter does not apply to contracts entered into before it comes into force (section 275). The draft guidance says existing contracts are not caught even when they renew after the start date, but calls extending the protections to existing customers best practice.
• Selling from abroad. The draft guidance says businesses outside the UK that sell to UK consumers must comply.
• App stores and platforms. The draft guidance says the duties stay with the business the customer contracted with, even if someone else, such as an app store, handles billing.

Contracts that are excluded

Schedule 22 to the Act lists contracts the rules do not cover, and the draft regulations change the list. In short:

• utilities: electricity, gas, heat networks, water and sewerage;
• financial services, such as banking, credit, insurance, pensions, investments and payment services;
• goods, services and digital content for health purposes supplied under a prescription or by a prescriber (the draft regulations take glasses and contact lenses out of this exclusion, and add dentists as prescribers);
• NHS-type health services;
• phone, broadband and other electronic communications services regulated by Ofcom;
• premium rate services;
• renting a home;
• food, drink and other everyday household consumables supplied by a micro-entity (as defined in company law) through frequent or regular delivery made by the business itself (not mainly by a courier), or collected from its premises;
• package travel, and timeshares and similar holiday products;
• childcare provided by registered or approved providers or schools;
• gambling and lotteries;
• draft addition: charity memberships that give access to property the charity preserves or creates (such as buildings, land, gardens, animals, works of art or scientific collections), or to performances or films.

A contract is excluded only "to the extent" that it falls in the list (section 255), so a bundle can be partly covered.

What you will need to do

1. Give key information before sign-up

Before the customer subscribes, you must give them "key pre-contract information" (section 256, with the list in Schedule 23 Part 1). It includes:

• that the subscription continues, and they keep paying, until they end it, plus any minimum period;
• for a free trial or introductory price, that they will be charged (or charged more) unless they end it first, and the date that happens;
• how often they pay and the least amount of each payment, plus the monthly equivalent if payments are not monthly;
• the least they will have to pay in total;
• whether the price or how often they pay can change, and how;
• how to end the contract, and any notice needed;
• the period in which you will send reminders;
• a summary of their cooling-off rights.

This must be given together, apart from everything else, as close to the moment of sign-up as practicable. Online, the customer must not have to take any extra step to read it (section 256). The draft guidance says it cannot be given by a link, and that it "could be provided on the same screen as the purchase button". One law firm reads the rule as ruling out drop-downs too.

You must also make the full contract information available (online, a clear and prominent link will do). If you did not give it in a lasting form before sign-up, you must send it in a lasting form, such as email, as soon as reasonably practicable afterwards and before supply begins (section 257).

2. Get a clear acknowledgement

For online sign-ups, the final step must involve the customer expressly acknowledging that the contract means they have to make payments. If you do not do this, the customer is not bound by the contract (section 257). The Act does not set button wording; the draft guidance gives the example of a clearly labelled order, buy or subscribe button.

3. Send reminders before certain payments

Reminders are due before the first payment after a free trial or introductory price, before the last payment in each six-month period, and twice before each annual renewal (section 258 and section 259). Each one must contain a set list of facts and arrive within the period you stated at sign-up. Our reminder guide has the detail and example wording.

4. Send a separate cooling-off notice

Customers get a 14-day cooling-off period when they first sign up, and a new one at a "relevant renewal": the first payment after a free trial or introductory price ends, and each annual renewal (section 265). At each relevant renewal you must send a cooling-off notice on its own, not combined with anything else (section 266). See cooling-off periods for renewals explained.

5. Make leaving easy, and confirm it

Ending a subscription must be straightforward, with no steps that are not reasonably necessary. If the customer signed up online, they must be able to end it online (section 260). They can also end it by sending you a clear statement, for example by email. You must then confirm the end date in writing: within 24 hours if they told you online, otherwise within 3 working days (section 261). See how to let customers cancel online.

6. Refund on time, and do not charge early

If someone cancels in a cooling-off period, the refund is due within 14 days, to the payment method they used unless they agree otherwise (draft regulation 21). You may be able to keep a proportionate amount for a service already provided, but only if you gave the right information first. Separately, under draft regulation 37 a rolling subscription renews on the first day of each new period, and section 273 makes a term that charges for the renewal before that day of no effect. If you invoice for the next period early, check this.

What happens if you get it wrong

• Customers can cancel and claim money back. Under the draft regulations (Part 3), a customer can cancel within 12 months of a listed failure, such as a missed or incomplete reminder, missing key information or an unreasonable reminder period (the 12 months run from the day after the payment concerned, not from when the customer finds out). A route to cancel that is not straightforward also gives this right. For listed failures, payments from that point onwards are cancelled and refunded within 14 days, although the amount can be reduced if the customer delayed unreasonably.
• Cooling-off periods get longer. If you do not give the cooling-off information, the period runs until 14 days after you do, for up to 12 months (draft regulations 5 and 6).
• Regulator action. Once the chapter is in force, the Competition and Markets Authority (CMA) can enforce it directly and impose penalties of up to £300,000 or 10% of turnover, whichever is higher (section 182 and Schedule 16; the draft guidance describes this as global turnover). The draft guidance says Trading Standards can also enforce through the courts. In a blog post on 14 October 2026, the CMA said that in the early months it will focus on supporting businesses and on more egregious conduct, and will consider genuine efforts to comply. It also said businesses "should not assume that our support for compliance means enforcement of the rules is being delayed".
• A criminal offence in one case. For off-premises contracts (for example, signed in the customer's home), failing to give the initial cooling-off information is an offence (section 268).

You also carry the burden of proof. If there is a dispute, it is for you to show that you gave the information and sent the notices (section 272). Keep a record of what you sent, and when.

What is still uncertain

• The start date depends on Parliament approving the draft regulations and on commencement regulations being made.
• No law says how many days before a payment a reminder must arrive. It has to be reasonable (see reminder timing).
• The draft guidance says asking for account details to find the subscription is likely to be reasonable when someone cancels. It does not say whether making them log in first is.
• Retention offers when someone cancels are allowed in principle, but there are no worked limits.
• Final guidance may change the detail.

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)
• DMCC Act 2024, Schedule 22 (contracts that are excluded) Law, not yet in force (a few provisions only so regulations can be made)
• DMCC Act 2024, Schedule 23 (pre-contract information and reminder content) 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")
• UK Parliament: progress of the draft regulations
• DMCC Act 2024, section 182 and Schedule 16 (CMA direct enforcement and penalties) In force since 6 April 2025 (applies to the subscription rules once they are in force)
• Competition and Markets Authority blog: direct consumer enforcement 18 months on (14 October 2026)