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Summary. The UK's subscription contracts regime in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA) is due to cover consumer subscriptions entered into on or after 1 January 2027. The detail sits in the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, laid before Parliament on 19 October 2026 with 77 pages of draft guidance. Both Houses must approve the draft before it is made, and by 12 November 2026 we found no record of either doing so, so 1 January is the planned date, not yet law. For subscription apps selling to UK consumers the build list is concrete: key terms on the checkout screen, written reminders about every six months on rolling plans and before any trial or discount ends, two reminders before a renewal onto 12 months or more, online exit without compulsory surveys, an end-of-contract notice within 24 hours of an online exit, and two 14-day cooling-off periods with pro-rata refunds. A missed cooling-off notice can keep the window open for up to 12 more months. The Competition and Markets Authority (CMA) can fine up to £300,000 or 10% of global turnover, whichever is higher. Build to the draft now and treat any change Parliament makes as a patch.
About this article. For product, engineering and billing teams at subscription businesses that sell to UK consumers. On 12 November 2026 we checked the draft Regulations and their Explanatory Memorandum, the DMCCA subscription chapter, the government's draft guidance, consultation papers and announcements, CMA case pages and Hansard. Readings of how the rules apply to specific product flows are ours. This is general information, not legal advice; the Regulations and guidance are drafts, so re-check both before you ship. Researched with AI assistance and reviewed by our editorial team.
What is confirmed and what is still draft
The DMCCA received Royal Assent in 2024, but its subscription chapter is not yet in force. The draft Regulations fill in what the Act left to secondary legislation: cooling-off extensions, refund rules, notice formats, renewal charge timing and extra exclusions. A third moving part is easy to miss: draft regulation 2(2) applies the Regulations only to contracts made once section 254 of the Act is in force, so the chapter also needs its own commencement step.
| Item | Status on 12 November 2026 | Where to check |
|---|---|---|
| DMCCA Part 4, Chapter 2 (sections 253 to 281, Schedules 22 and 23) | Enacted in 2024, not yet in force | legislation.gov.uk |
| Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 | Draft laid on 19 October 2026; needs approval by both Houses; not yet made | Draft SI, ISBN 978-0-348-28791-2 |
| Coming-into-force date | 1 January 2027, in draft regulation 1(2) | Draft SI, regulation 1 |
| Commencement of the Act's chapter | Still needed; the Regulations bite only once section 254 is in force | Draft SI, regulation 2(2) |
| Business guidance | Draft, 77 pages, published 19 October 2026; final version once the Regulations are made | GOV.UK, Subscription contracts |
| Contracts covered | Entered into on or after 1 January 2027; not retrospective | Draft guidance, section 2 and FAQ 1 |
| CMA powers | Direct consumer enforcement in use; the chapter is listed in Schedule 16 | Draft guidance, section 10.2 |
The government consulted from 18 November 2024 to 10 February 2025, received 75 responses and published its response on 2 April 2026, then expecting the rules in spring 2027. It estimates that nearly 10 million of the UK's 155 million active subscriptions are unwanted, costing £1.6 billion a year. On 9 August 2026 the Prime Minister's Office brought the start forward to January 2027.
The latest copy of the draft instrument we could read, captured on 31 October 2026, still describes it as not yet made, and Hansard showed no debate on it by 12 November. If approval slips, the date in regulation 1 would have to change. For other UK and US dates in the same window, see our 2027 compliance calendar for software teams.
Does the regime cover your SaaS or app?
Under section 254 of the DMCCA, a subscription contract is a trader-to-consumer contract for goods, services or digital content, paid for, that recurs or continues automatically and keeps charging unless the consumer ends it. Free or discounted periods that roll onto a paid or higher price are expressly covered.
- B2C only. FAQ 3 of the draft guidance excludes business-to-business contracts, including a company buying subscriptions for staff. A consumer is an individual acting wholly or mainly outside their business, so self-serve SaaS with card sign-ups will usually have some regulated customers.
- Every channel. Online, phone, in-person and doorstep sign-ups are all covered.
- Non-UK traders. FAQ 9 says traders outside the UK selling to UK consumers must comply, and FAQ 10 notes that choosing a non-UK law does not switch the rules off where the contract has a close connection with the UK (section 275).
- Exclusions. Schedule 22, as amended by draft regulations 39 and 40, excludes utilities, financial services, prescription-linked health products, Ofcom-regulated telecoms, residential lettings, micro-grocery businesses, package travel, timeshares, childcare, gambling and cultural and heritage charity memberships. Contact lens and spectacle subscriptions stay in scope.
- App stores and billing partners. FAQ 11 puts the duties on the trader the consumer contracts with. If you sell through the App Store, Google Play or a merchant-of-record reseller, agree with counsel who that trader is. Android teams moving to Play Billing Library 9 can fold the UK notice work into the same release.
Existing subscribers are not covered, even when their plans renew after 1 January 2027, though the guidance calls consistent treatment best practice.
The build map: five duties, five workstreams
This table maps sections 256 to 266 of the Act and the draft Regulations, as summarised in section 4 of the draft guidance.
| Duty (legal source) | What to build | Timing rule |
|---|---|---|
| Key pre-contract information (s.256, Sch 23 Part 1) | A grouped summary on the final checkout step, readable without clicking a link | As close as practicable before the consumer commits |
| Full pre-contract information (s.256, s.257(9), Sch 23 Part 2) | Prominent direct link at checkout plus a copy on a durable medium such as email | Copy sent after sign-up, before supply starts |
| Reminder notices (s.258, s.259, regs 33 and 34) | A scheduler that emails or texts the prescribed notice | Within the window stated at sign-up; an extra earlier notice before 12-month renewals |
| Easy exit and end-of-contract notice (s.260, s.261, regs 32 and 35) | Online cancel button or webform, then a confirmation | Confirmation within 24 hours online, 3 working days otherwise |
| Cooling-off rights and refunds (s.264 to s.266, regs 5 to 22 and 36) | Cancellation handling, waiver capture, pro-rata refunds, cooling-off notice | 14 days from sign-up and from qualifying renewals; refunds within 14 days |
1. Key pre-contract information on the checkout screen
Part 1 of Schedule 23 lists the key information, summarised in Annex A of the draft guidance. In product copy, the summary must tell the user:
- That the contract renews or continues automatically, that charges run until they end it, and any minimum term.
- For trials or introductory prices: that they will be charged, or charged more, unless they end it first, with the date and amount of that first charge.
- How often they pay and the minimum amount each time.
- The monthly equivalent, if billing is not monthly.
- The minimum total they will pay under the contract.
- Any terms letting you change the price or payment frequency.
- How to end the contract, with the web address or contact details needed.
- Any notice period required to end it.
- The period in which reminder notices will be sent.
- A summary of both cooling-off rights, and that full details are in the full information.
Online, the user must be able to read this during the purchase journey without clicking a link; FAQ 17 rules out linking out. It can share a screen with the buy button but must be grouped, set apart and not crowded out by upsells. Delivery restrictions and accepted payment methods must also be visible without a link, and the final step must include an express acknowledgement that the consumer will have to pay, or the consumer is not bound. A button reading Start free trial alone is risky; Start trial, then pay £9.99 a month from 8 January is closer to the intent.
The full pre-contract information (trader identity and addresses, complaint handling, full cooling-off rules, digital content compatibility) can sit behind a clearly labelled direct link, but you must also send it on a durable medium after sign-up and before supply begins. Most of it becomes a contract term under the Consumer Rights Act 2015.
2. A reminder-notice engine
This is the largest engineering change for most apps. The rules depend on plan shape, per section 4.4 of the draft guidance and draft regulation 33.
| Plan shape | When a reminder is required | Notes |
|---|---|---|
| Rolling weekly, monthly or quarterly, no trial | Before the last renewal payment in each relevant six-month period | Guidance example: sign up 1 June, monthly on the 1st, reminders for 1 December and the next 1 June |
| Renewal periods of 9 or 12 months | Before every renewal payment | No payment falls inside a six-month window |
| Renewal onto 12 months or longer | The normal notice plus an additional earlier one (s.259(6)) | Also triggers a renewal cooling-off period |
| Free trial converting to paid | Before the first paid renewal | The six-month clock then restarts from that payment |
| Stepped discount, such as 50%, then 25%, then 10% off | Before the first renewal payment | Guidance scenario 3 |
| One discount held across several payments (draft reg 33) | Before the first payment at the higher rate | Guidance example: £30 plan at £15 for 3 months needs a reminder before month 4 only |
Draft regulation 34 requires reminders in writing on a durable medium, with their purpose obvious, for example from the subject line. Email, SMS, letter and, per FAQ 8, WhatsApp can qualify if the user can keep and retrieve the message; a disappearing push or in-app notification cannot. Section 259 requires the prescribed information to be more prominent than anything sent with it, so a newsletter with a billing line at the bottom fails.
Part 3 of Schedule 23 sets the content, including the charge date and amount, any increase on the previous payment, the minimum total, and how and by when to end the contract. You choose the timing window, but you must state it at sign-up and it must leave time to decide and act before the last day to cancel. An unreasonable window is itself a breach that lets the consumer cancel.
3. Online exit and retention offers
Draft regulation 32 lets a consumer end a subscription at any time, which the guidance says includes straight after signing up, with supply continuing to the end of the paid period. Section 260 requires exit arrangements that are straightforward, with no steps beyond those reasonably necessary. The stated policy aim is that leaving should be as easy as signing up.
If users can subscribe online, they must be able to leave online. The guidance accepts a clearly labelled button in the site, app or account page, or a simple web form; an email address alone is not an online exit route. Asking for account details is likely fine; a compulsory exit survey is unlikely to be. FAQ 29 does not rule out a chatbot, but it must meet the same test, and offers must not prolong the exit or discourage the user. Our reading: one optional offer screen with an obvious control to continue cancelling, not a multi-step save funnel.
4. The end-of-contract notice
Once the user ends or cancels, send a written confirmation on a durable medium stating the date the contract ended or will end: within 24 hours of an online exit, or within 3 working days beginning the day after notification for other routes. Draft regulation 35 requires that date to be more prominent than anything else in the message and the purpose to be obvious. FAQ 36 allows marketing alongside it, but a win-back offer that outshines the end date breaks the rule.
5. Cooling-off, waivers and refunds
There are two 14-day cooling-off periods:
- Initial cooling-off starts on the day the contract is made. With no goods, a contract made on 1 January has a last cooling-off day of 15 January, per the guidance's example. With goods, it ends 14 days after the first complete delivery arrives.
- Renewal cooling-off starts on the day a free or discounted period first converts to the higher price, or a contract renews onto 12 months or more, and ends 14 days after that day. Send a cooling-off notice on its first day or as soon as reasonably practicable, on a durable medium and separately from any other information.
For digital-content-only subscriptions, draft regulation 7 lets the consumer waive initial cooling-off if, before supply starts, they expressly consent to immediate supply and acknowledge losing the right, and you confirm both on a durable medium. A pre-ticked box or blanket acceptance of terms is not express consent. Skip a step and a consumer who cancels in the first 14 days owes nothing for content already streamed. Where digital content and services share one contract, FAQ 40 says no waiver is possible.
Refunds after a cooling-off cancellation are pro rata to what was supplied: in the guidance example, a £365 annual film-library plan cancelled on day 4 of a renewal cooling-off period leaves the consumer liable for £4. Refunds are due without undue delay and within 14 days beginning with the day after cancellation, by the original payment method unless the consumer agrees otherwise. A full refund is always allowed if pro-rating is too fiddly.
The penalty for getting notices wrong is time. Under draft regulations 5 and 6, a missing initial cooling-off information or renewal cooling-off notice keeps the window open until 14 days after you put it right, or for 12 months after the original end date if you never do.
One more rule that breaks common billing code
Section 273(2) voids any term making the consumer liable for a renewal payment before the day the contract renews, for contracts described in draft regulation 37, which treats each contract period's first day as the renewal day. The guidance example is a monthly plan taken out on the 15th: a term charging before the 15th has no effect. Billing that charges three days early to allow card retries needs review; users can still choose a later payment date.
Worked example: a UK fitness app at £9.99 a month or £59.99 a year
Assume a streaming-only fitness app, treated as digital content, sells two plans from 1 January 2027: a 7-day free trial converting to £9.99 a month, and an annual plan at £59.99. If live coaching is included under the same contract, it becomes a mixed contract and the waiver is unavailable. Dates follow the draft guidance's counting examples.
| Date | Event | What your system must do |
|---|---|---|
| 1 January 2027 | User starts monthly trial | Show key information at checkout; capture waiver consent if wanted; send full information before streaming starts |
| 3 to 5 January 2027 | Trial about to convert | Send the reminder within your stated window, for example 2 to 4 days before the last day to cancel |
| 8 January 2027 | First £9.99 payment | Renewal cooling-off starts; send the cooling-off notice |
| 15 January 2027 | Initial cooling-off ends | Log the date |
| 22 January 2027 | Renewal cooling-off ends | Pro-rata cooling-off refunds stop applying |
| Before 8 July 2027 | Last payment in the six-month period that began on 9 January | Send the six-monthly reminder |
Now the user cancels on 11 January, day 4 of the first paid month, 8 January to 7 February (31 days).
- With a valid waiver and an on-time cooling-off notice, the initial right ended when streaming began, so renewal cooling-off rules apply. Liability is £9.99 × 4 ÷ 31 = £1.29, so the refund is £8.70, due by 25 January.
- Without a valid waiver, initial cooling-off still runs to 15 January, and a consumer cancelling under it owes nothing for digital content supplied, so the refund is £9.99. The draft does not say how overlapping cooling-off periods interact; our reading is to expect the consumer to rely on whichever leaves them owing less. A missing cooling-off notice also removes the pro-rata deduction.
For the annual plan, key information must show the monthly equivalent: £59.99 ÷ 12 = £5.00. The 1 January 2028 renewal triggers two reminders, a cooling-off notice and a renewal cooling-off period ending on 15 January 2028. As 2028 is a leap year, a cancellation on day 4 leaves liability of £59.99 × 4 ÷ 366 = £0.66 and a refund of £59.33. The refund maths is cheap; a broken notice template that keeps cooling-off open for a year is not.
What to change in the data model
In a dispute the trader must prove that information and notices were given correctly, and electronic notices count as given when sent. A sketch of the extra fields:
uk_consumer_subscription:
contract_entered_at: "2027-01-01T09:00:00Z"
renewal_period: "P1M" # P1M, P3M, P1Y
concessionary_end: "2027-01-08"
key_info_snapshot_id: "kpi_8f2c" # exact text shown at checkout
reminder_window_days: [2, 4] # as stated in key info
waiver: {consent_at: "2027-01-01T09:00:12Z", confirmation_id: "msg_1a9"}
cooling_off:
initial_ends: "2027-01-15"
renewal: [{start: "2027-01-08", end: "2027-01-22", notice_id: "msg_2b3"}]
notices_log: [] # id, type, channel, sent_at, template_version, content_hash
exit: {requested_at: null, channel: null, end_notice_id: null}
Store the rendered text or a hash of every notice, and version templates like releases: a copy edit to a reminder is now a compliance change.
Enforcement and risk
- Private cancellation rights. Four duties are relevant implied terms: giving key information, sending reminders, stating a reasonable reminder window and keeping exit straightforward. After a breach the consumer can cancel within 12 months beginning the day after the relevant date the Regulations set, and may stop owing, or recover, payments from that date.
- CMA direct enforcement. The CMA can investigate, accept undertakings, issue infringement notices and fine up to £300,000 or 10% of global turnover, whichever is higher. It already acts on subscriptions under existing law: on 19 March 2026 it opened its ninth direct enforcement case, into Adobe's early cancellation fees, still open on 12 November 2026, and on 29 July 2026 it opened another into how Microsoft told Microsoft 365 Personal and Family customers about plan changes before renewal. It has reached no conclusions in either.
- A criminal offence for failing to give initial cooling-off information on off-premises, doorstep-style sign-ups.
Freshfields reports that the CMA has said it will focus first on helping businesses comply, will not defer enforcement, and will weigh genuine compliance efforts. We could not find that statement on a CMA page, so treat it as reported comment, not a grace period.
Implementation checklist
- Now to late November 2026: tag UK consumer sign-ups, inventory plan shapes (rolling, annual, trial, held and stepped discounts, bundles) and get legal review of checkout, reminder and exit copy.
- Build the key information block for web, iOS, Android and TV with no links for the key items, and make the final button state the payment obligation.
- Send full pre-contract information on a durable medium before supply starts.
- Build the reminder scheduler: six-month logic, trial conversion, held and stepped discounts, and the extra notice before 12-month renewals.
- Send statutory notices only through durable channels; drop push-only reminders.
- Put online cancel on the surface used to subscribe, with optional feedback and at most one skippable offer.
- Send end-of-contract notices within 24 hours of online exit.
- Capture waiver consent with an unticked box and a confirmation email.
- Build pro-rata refunds with a full-refund fallback and a 14-day deadline.
- Remove charge-before-renewal patterns for UK consumer plans.
- Log every notice with template version and content hash, and agree with any store or merchant of record who sends what.
- Test in staging by mid-December 2026, and before 1 January 2027 check legislation.gov.uk for the made instrument and any date change.
How eCorpIT can help
eCorpIT is a Gurugram-based technology organisation, founded in 2021, assessed at CMMI Level 5 and MSME certified, with senior-led engineering teams working across AWS, Microsoft and Google platforms. Our subscription billing and monetisation team builds checkout disclosures, reminder schedulers, durable-channel notices, online cancel journeys and pro-rata refund logic for web and mobile apps, with your legal advisers signing off the wording. Talk to us at /contact-us/.
Last updated: 12 November 2026.
