If your business offers subscriptions to consumers, whether that's software, memberships, digital content, subscription boxes or other recurring services, there are significant legal changes on the horizon.
In January 2027, the new subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024, or DMCCA, is expected to come into force.
The purpose of the new regime is to tackle “subscription traps” where consumers sign up without fully understanding the ongoing commitment, forget about automatic renewals, or find it difficult to cancel.
These reforms are designed to improve transparency and give consumers greater control over recurring payments.
The new rules will apply to many consumer subscription contracts for goods, services and digital content that automatically renew or convert from a free or discounted trial into a paid subscription.
However, certain sectors, including insurance and financial services, are excluded from the regime.
Our Commercial Solicitors explore the new rules and explain how businesses can prepare for the new changes.
What Are the Key Changes Under the New Subscription Rules?
Clearer Pre-Contract Information
The first key change concerns the information provided to consumers before they sign up.
Businesses will be required to provide both key pre-contract information and full pre-contract information.
While much of the full information mirrors the existing requirements under the Consumer Contracts Regulations, the key information must be presented separately and more prominently. Consumers must be clearly informed about matters such as pricing, renewal arrangements, future payments and cancellation rights before they commit to a subscription.
For many businesses, this is likely to require changes to website checkout pages, app subscription journeys and customer onboarding processes.
Under the new regime, businesses will need to clearly explain when a trial will end, when charges will begin, what the customer will pay and how they can cancel before those charges are taken.
Therefore, businesses that rely on introductory offers should review their trial communications and renewal processes before January 2027.
Mandatory Subscription Reminder Notices
One of the most significant operational changes is the introduction of mandatory reminder notices. Currently, there is generally no obligation to remind consumers that a subscription is continuing or about to renew.
Under the DMCCA, businesses will be required to send reminder notices at prescribed points throughout the life of a subscription.
These notices must inform consumers about upcoming payments, renewal arrangements and their right to cancel.
For businesses, this is likely to require updates to CRM systems, billing platforms and customer communication processes. Reminder notices will also need to be provided on a durable medium, such as email, SMS or WhatsApp.
New Cooling-Off Rights
The DMCCA also introduces new cooling-off rights.
The existing 14-day cooling-off period at the start of a contract will remain.
However, consumers will also benefit from a new 14-day renewal cooling-off period following certain renewals, including where a free or discounted trial converts into a paid subscription.
Businesses must review their cancellation and refund processes to ensure they are capable of dealing with these enhanced rights.
Simpler Subscription Cancellation Rules
The final major change concerns cancellation. If a consumer enters into a subscription online, they now must be able to cancel online.
Businesses must also avoid contractual provisions or processes that make cancellation unnecessarily difficult.
For businesses, this may require updates to website functionality, subscription management tools and customer service processes.
How Can Businesses Prepare for the New Subscription Rules?
Businesses offering subscription products should use the time before January 2027 to review their subscription terms, customer journeys, trial offers, reminder notice processes, cancellation mechanisms and the systems that support them.
The new regime is likely to require operational changes across legal, marketing, customer service, product and technology teams.
The key takeaway is that the new regime regulates the entire subscription lifecycle, from sign-up and trial periods through to renewal and cancellation.
Businesses that start preparing now will be best positioned to minimise compliance risk, avoid disruption, and ensure a smooth transition when the new rules come into force in January 2027.
If you are looking to operate a consumer-facing platform, we explore these issues and a range of other key legal considerations in more detail in our Five Key Legal Themes for Online Businesses 2026 webinar below.
Contact Our Commercial Lawyers
If you would like to discuss how the new subscription rules could affect your business, please contact the Myerson Commercial Team.
0161 941 4000
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Mia Caruana
Solicitor Apprentice
Mia joined Myerson as a Level 7 Solicitor Apprentice after completing her A Levels in Biology, Psychology, Law and Core Maths at Wilmslow High School Sixth Form. During her final year of study, she began exploring alternative routes into the legal profession and was drawn to the solicitor apprenticeship pathway because it offered the opportunity to gain practical experience while studying towards a law degree.
After researching leading apprenticeship opportunities, Mia was impressed by Myerson's reputation, culture and commitment to developing aspiring lawyers. Following a successful application and assessment centre process, she accepted an offer to join the firm as a Solicitor Apprentice. Although she also received an offer to study Law at a Russell Group university, she chose the apprenticeship route to begin her legal career in practice from day one.
As part of her apprenticeship, Mia is studying towards an LLB (Hons) in Law and Legal Practice at BPP University Law School while gaining hands-on experience across different areas of the business. During her first year, she worked within Business Services, providing her with valuable insight into the firm's operations and the wider functions that support the delivery of legal services.
Mia is now undertaking a year-long seat within the Corporate and Commercial teams, with a particular focus on commercial law. She has a keen interest in understanding how legal advice supports business objectives and enjoys developing her knowledge of the legal and commercial issues faced by clients.
Through her apprenticeship, Mia is developing both her legal expertise and commercial awareness, and she values the opportunity to learn from experienced colleagues while contributing to the delivery of practical, client-focused legal solutions.
About Mia Caruana