UK Online Subscription Rules: What’s Changing?
If your website or app offers subscriptions, big changes are coming in the form of the UK online subscription rules introduced under the Digital Markets, Competition and Consumers Act 2024 (the “DMCC Act”). The aim is to tackle so-called “subscription traps” and make sign-up, reminders and cancellation clearer for consumers.
This guide explains what is changing, what you should already be doing under existing consumer laws, and practical steps you can take now to prepare. It is written for website/app operators and online businesses, whether you offer services, digital content, or goods supplied on a recurring basis.
Update (January 2026): the Government confirmed in November 2025 that implementation of the new subscription contracts regime has been delayed. Current commentary indicates the regime will not start until Autumn 2026 at the earliest, pending secondary legislation and guidance. See “Implementation timeline” below.
A Quick Overview of the New UK Online Subscription Rules
The DMCC Act introduces a subscription contracts regime that will require more structured information, reminders and easier cancellation journeys. In broad terms, businesses should expect requirements covering:
- Clear upfront information about the subscription, price, renewal and cancellation.
- Reminder notices before a free trial ends and at set intervals during the subscription.
- Easy cancellation, designed to remove unnecessary friction.
- Additional cooling-off rights at certain key points (including after some renewals), with refund mechanics to be confirmed in more detail.
- Potentially significant enforcement risk for non-compliance.
Although the overall direction is clear, key details depend on secondary legislation and guidance. Therefore, the sensible approach is to prepare your subscription journey, terms and customer communications now, so you can move quickly when the final rules are confirmed.
What You Should Be Doing Now Under Existing UK Consumer Law
Even before the DMCC Act subscription regime starts, many subscription services are already regulated under UK consumer law. In particular, you should be complying with the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (“CCR 2013”) and the Consumer Protection from Unfair Trading Regulations 2008 (“CPRs 2008”).
1) Pre-contract information
Before a consumer subscribes, you should clearly provide key information such as:
- what the subscription includes (services, digital content and/or goods)
- the total price and how/when payment is taken
- the renewal cycle and any minimum commitment period
- how to cancel, and any consequences of cancellation
This information should be prominent and understandable. For example, if your service becomes paid after a free trial, the paid price and when charging starts should be clear before the consumer commits.
2) Cooling-off rights
Consumers usually have a 14-day cancellation period for remote contracts, subject to exceptions and specific rules. If you do not provide the required cancellation information, the cancellation period can be extended. Digital content has special rules (including consent/acknowledgement requirements), and services may allow proportionate charging where properly disclosed.
3) Avoiding misleading practices
Under CPRs 2008, you should not mislead consumers about price, renewal, cancellation or key terms. For example, fee disclosures should not be hidden, and “limited time” claims should not be used in a way that is misleading.
How the DMCC Act Subscription Regime Is Expected to Raise the Bar
The new regime builds on existing law and is intended to make subscription journeys more transparent and easier to exit. Based on published materials so far, the main practical areas to plan for are:
1) More structured pre-contract information
You should expect requirements to present subscription information clearly and in a standardised way, including price, renewal mechanics, cancellation process and key rights.
2) Reminder notices
You should plan systems to send reminders:
- before a free trial or introductory price ends (including how to cancel)
- at intervals during the subscription term (the exact timings will depend on the final rules)
In practice, this means reviewing your CRM/email automation flows as well as your customer service processes.
3) Easier cancellation
The regime is intended to prevent unnecessarily complex cancellation journeys. Therefore, review your cancellation pathway now: how many steps, how much friction, and whether the process could be criticised as a “dark pattern”.
4) Additional cooling-off rights at key points
The DMCC Act regime is expected to create further cancellation/refund rights in certain situations (for example, after a free trial ends and after certain renewals). However, detailed refund mechanics are expected to be clarified by secondary legislation and guidance.
Implementation Timeline (Updated)
The Government consulted on implementation of the new subscription contracts regime (including operational detail and refund mechanics). The regime requires secondary legislation and supporting guidance.
Following the consultation (which closed in February 2025), the Government confirmed in November 2025 that implementation will be delayed. Current legal updates indicate the subscription contracts regime will not take effect until Autumn 2026 at the earliest.
- DBT consultation page: Consultation on implementation of the new subscription contracts regime (GOV.UK)
- Background web-accessible consultation: Web-accessible consultation document (GOV.UK)
Because there may be a relatively short lead-in between final guidance/regulations and commencement, it is sensible to prepare early rather than rushing changes at the last minute.
Practical Compliance Steps for Website/App Operators
- Map your subscription journey: sign-up screens, checkout, confirmation emails, account area, cancellation journey.
- Audit disclosures: price, renewal, minimum term, cancellation steps, and any post-trial price changes.
- Review your terms: ensure your subscription clauses reflect the actual customer journey and the current law.
- Build reminder capability: define trigger points, content, timing and audit trails.
- Stress-test cancellation: remove friction that could be criticised as unfair or misleading.
If you are updating terms as part of this work, you may find our service page helpful: Website and app terms and conditions.
Need Legal Help With UK Online Subscription Rules?
If you would like advice on how the UK online subscription rules affect your website/app, or you need help reviewing and updating subscription terms and cancellation journeys, please contact Adam Taylor for an initial chat.
Originally published May 2025. Updated January 2026.
