Businesses offering subscription contracts to consumers should take note: the UK Government has brought forward the implementation of the new subscription contract regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).

The new rules are now due to come into force on 1 January 2027. Having originally been expected to take effect in 2026, implementation was subsequently pushed back to spring 2027. It has now been bought forward again following an intervention by Andy Burnham.

This revised timetable therefore leaves businesses with less time to prepare for a new compliance regime governing how consumer subscriptions are offered, renewed and cancelled.

Draft Regulations and CMA guidance now published

On 19 October 2026, the Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 (Regulations) were laid before the House of Commons and the House of Lords.

The Regulations are subject to the affirmative procedure, meaning that they must be approved by both Houses of Parliament before they can be made.

This means that we now have sight of the draft Regulations, together with the accompanying Explanatory Memorandum. The CMA has also published draft guidance on consumer subscription contracts, providing businesses with further detail on how the new regime is expected to operate in practice.

With implementation now approaching, businesses should be reviewing the draft Regulations, the Explanatory Memorandum and the CMA's draft guidance to understand what the new requirements will mean for their subscription models and identify any changes needed before the rules take effect.

What are the key changes under the DMCCA subscription contract regime?

The new regime introduces a range of requirements for businesses offering subscription contracts to consumers. These subscription rules are said to apply to subscription contracts entered into on or after 1 January 2027.

Under these new rules, businesses will need to:

  1. give consumers clear information upfront about the subscription they are signing up to;
  2. issue timely reminders at key points during the contract, including when a free or discounted trial is coming to an end and before certain longer-term automatic renewals; and
  3. provide an easy way for consumers to cancel their subscription.

The rules also strengthen consumers' cancellation rights. Consumers may be able to cancel without penalty, and may be entitled to a refund, during the initial 14-day cooling-off period, during a new 14-day cooling-off period following certain trials and renewals, and in certain circumstances where a trader has failed to comply with the new rules.

For many businesses, compliance will require more than simply updating their terms and conditions. Customer journeys, sign-up processes, renewal arrangements, reminder communications and cancellation mechanisms may all need to be reviewed and, where necessary, updated.

Which businesses will be affected?

The new rules will have a broad reach, applying to business-to-consumer subscription contracts unless they are specifically excluded.

Importantly, they are not limited to businesses that operate primarily on a subscription model, such as digital and media platforms, software providers or membership schemes. They will also catch businesses that offer subscriptions as an add-on to their core products or services, for example recurring delivery or servicing arrangements.

Businesses should therefore assess whether they are offering subscription arrangements and, if so, whether these arrangements fall within the scope of the new regime. If they do, businesses will need to think about what operational and contractual changes will be required.

What are the enforcement priorities?

In its "Direct Consumer Enforcement: 18 months on" blog, the CMA said in relation to subscription contracts that "In the early months of the regime, the CMA's focus will be on supporting businesses to get this right to help drive the best outcomes for consumers. However, businesses should not assume that our support for compliance means enforcement of the rules is being delayed. Conduct during this period may still be considered as part of enforcement action."

In line with its broader consumer protection approach, it will focus its enforcement on more egregious conduct, particularly in areas where businesses should already be clear about their obligations under the existing law.

How we can help

With the new subscription rules due to take effect on 1 January 2027, and the draft Regulations and CMA guidance now available, businesses operating subscription models should be moving quickly to assess their readiness for the new regime. This should include reviewing customer journeys, contractual terms, renewal and reminder processes, customer communications and cancellation mechanisms to identify where changes may be required.

If you would like to discuss how the new rules could affect your business, please get in touch with Dan Smith or Zoe Pearman.