What Are The New UK Online Subscription Rules?
If your website or app offers subscriptions – think virtually any kind of online service (also goods if being delivered regularly) – big changes are coming in the form of new UK online subscription rules. The Digital Markets, Competition and Consumers Act 2024 (DMCCA) tackles “subscription traps” that apparently cost UK consumers £1.6 billion annually. New regulations, expected by spring 2026, will change the rules around subscription sign-ups, reminders, and cancellations.
This blog explains what’s changing, compared with what you are (or should be!) doing now. And how to get ready. We’ll try to keep it clear, user-friendly, and practical.
What’s Changing? A Quick Overview
The DMCCA aims to make subscriptions fair and transparent. It introduces stricter rules to protect consumers. Here’s what’s coming:
- Clear Information: You must share detailed subscription info upfront.
- Reminders: Send notices before free trials end and at set intervals.
- Easy Cancellation: Allow one-click or single-email exits.
- Cooling-Off Periods: Offer 14-day refund periods at the start, after trials, and even after certain renewals.
- Big Fines: Up to 10% of global turnover for violations.
To comply with the online subscription regulations, you’ll need to update your website/app, terms and conditions, and communication processes. Some details, like refund rules, are still being finalised, but we recommend that you start preparing well ahead.
Current Regulations: What You Are or Should Be Doing Now
Hopefully your website/app already follows the “Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013” and other UK consumer laws. These already set some standards for online subscriptions. As a reminder, here’s what you should be doing:
Providing Subscription Information Before Sign-Up
You must give customers key details before they subscribe:
- What the subscription offers, like services or products.
- Total cost, including recurring fees.
- Subscription length and renewal terms.
- How to cancel and any related fees.
This info should be clear, not hidden in fine print. For example, if your app charges £10 monthly after a free trial, highlight this before the “buy” button.
Cooling-Off Period
Consumers generally have 14 days to cancel and get a refund, starting when they sign up. You can charge for services used during this period, like streamed content, but only if you explained this upfront. Refunds must be processed within 14 days.
Cancellation
The existing rules don’t focus on the ease of cancelling subscriptions. Many businesses require email, phone calls, or account logins for cancellations. Some add extra steps, like requiring multiple confirmations. The new rules crack down on this kind of thing.
Avoiding Misleading Practices
Under the “Consumer Protection from Unfair Trading Regulations 2008”, you can’t hide fees or make false claims, like “limited time offers” that never end. Your website must be honest about subscription terms.
Sending Renewal Notices
There’s no requirement to send renewal reminders, but some businesses do this as best practice. For example, you might email customers 30 days before an annual renewal to minimise the risk of an unwanted subscription renewal. Which might lead to an unhappy customer/ negative review.
If you’re following these rules, you’re doing pretty well! But the DMCCA will soon demand more. Let’s consider the changes…
What’s Different Under the New Online Subscription Regulations?
The DMCCA builds on current rules with stricter requirements. Some details are still being worked out through government consultations. Here’s what you need to know at this stage:
Pre-Contract Information
You’ll need to provide more details before customers sign up, presented clearly. This includes:
- Exactly what the subscription covers.
- Duration/minimum commitment periods.
- How renewal works.
- Total costs, including any post-trial price increases.
- Clear cancellation instructions.
- Cooling off rights/refunds (including the new post-renewal cooling rights where applicable).
- Any other key terms.
Reminder Notices
You must send reminders at key points:
- Before a free trial or discount ends, including details of the upcoming payment change and how to cancel.
- Regularly during the subscription period. This will likely be once a year for annual plans. The Government hasn’t yet decided on the frequency of reminders for monthly subscriptions. The Government is also still considering how far in advance of the relevant renewal date you have to give the notice. But this is likely to be around 14-30 days for annual subscriptions and less for monthly subscriptions.
Notices must include a reminders about the amount of the upcoming payment and clear steps to cancel.
Cooling-Off Periods
You will have to give consumers additional 14-day cooling-off rights including reminder notices at each point. Customers can cancel and get refunds:
- At the start of the subscription, as now.
- After free trials or discounts end.
- After renewal of contracts with annual or longer subscription payments..
The Government is still working out how refunds will work. For example, can a streaming-service customer get a full refund if they binge-watch a whole series and then cancel.
Easy Cancellation
Cancelling must be simple, like one click or email. You must tell customers about your “easy” cancellation step right at the start: “Click here to cancel.” “Email [email protected] to cancel”.
This easy cancellation requirement applies whether customers are cancelling the contract under the cooling off rules or simply ending the subscription. Complex processes, like navigating menus or answering surveys, won’t be allowed. Tactics that slow cancellations, like repeated “are you sure?” prompts, are unlikely to comply either.
Exclusions from the New UK Online Subscription Rules
Some subscriptions are exempt, including utilities, financial services, healthcare, rentals, and charity subscriptions that qualify for Gift Aid.
What’s Still Unclear
As mentioned above, some parts of the subscription rules still in progress including:
- Refund Rules: How refunds work for used services during cooling-off periods isn’t set.
- Reminder Timing: Exact intervals for reminders are undefined, only that they will be tied to subscription length.
Stay updated via gov.uk or CMA guidance for the latest details.
Implementation Timeline
The CMA has concluded its consultation on the new subscription rules. They anticipate that the official guidance and secondary legislation (i.e., regulations) will be finalised in late 2025/early 2026. The subscription rules will start in spring 2026.
There is likely to be an tight timescale between finalisation of the official guidance/secondary legislation and the new rules coming into effect. Sot it’s best not to wait to the last minute! We suggest that you review/update your processes sooner rather than later. That way you can move quickly to implement the changes and update your website/terms when the new rules are finalised. We can of course help you prepare for the new subscription landscape!
Final Thoughts
The DMCCA’s rules will change how you manage subscriptions, but they’re also a chance to build trust. Clear terms, easy cancellations, and timely reminders can help keep customers happy and reduce complaints.
Need Legal Help With the New UK Online Subscription Rules?
Please contact Adam Taylor now for an initial chat.
