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What’s happening?
The Digital Markets, Competition & Consumers Act 2024 received Royal Assent on 24 May 2024, introducing major reforms to UK consumer law. One key element is a new subscription regime, designed to protect consumers who enter automatic or recurring payment contracts.
Whilst the new subscription regime was due to come into effect in Spring 2026, implementation has now been delayed until Autumn 2026.
Why the delay?
The Department for Business and Trade (DBT) has confirmed that secondary legislation and detailed guidance are still being developed following consultation. The delay is intentional, it gives businesses more time to prepare and ensures that implementation is clear and consistent from day one.
Which contracts are caught?
The subscription rules apply widely and are intended to capture most consumer-facing arrangements that involve recurring payments. Under the Act, a “subscription contract” is any agreement where a trader supplies goods, services or digital content to a consumer in exchange for payment, and the contract includes some form of automatic renewal.
In practice, the following types of arrangements will fall within scope:
- Recurring or auto-renewing contracts – These include contracts that renew monthly, annually or on any rolling basis, whether for an indefinite period or for a fixed initial term. The key feature is that the consumer automatically incurs ongoing charges unless they actively cancel.
- Free or discounted trials that roll into paid subscriptions – If a consumer benefits from a promotional period (for example, “30 days free” or “50% off for the first three months”) and will be charged the full price afterwards unless they cancel, the contract is caught. This applies even where the consumer pays nothing during the trial period but will pay if they do not cancel in time.
- Subscriptions covering a wide range of sectors – The regime is intentionally broad. It applies to subscription boxes, online services, apps, streaming services, digital memberships, fitness platforms, software as a service, gaming services, and many others.
However, the Act contains a list of excluded contracts, set out in Schedule 22. These fall outside the subscription regime and include:
- Insurance policies
- Medical prescriptions
- Financial services and regulated financial products
- Utility contracts, such as energy and water
- Childcare services
These exclusions reflect areas already regulated by specialist regimes, so the DMCCA subscription rules do not apply.
The Act also has extraterritorial effect. This means:
- UK‑based businesses are caught even if their customers are outside the UK; and
- Non‑UK providers are caught if they offer subscriptions to UK consumers.
As a result, any trader with UK consumers, or operating from the UK, will need to review their subscription practices carefully.
What will change?
Although the final details are still being drafted, the core requirements of the new subscription regime will include:
- Requirements for provision of key and full pre-contract information;
- Mandatory renewal and reminder notices;
- New and extended cooling-off rights;
- Easy cancellation mechanisms; and
- Stronger enforcement powers and remedies.
What does this mean for your business?
Compliance will go beyond updating contract wording. Many businesses will need to make operational changes, such as:
- Updating billing platforms;
- Implementing automated reminder systems;
- Revising customer journeys and cancellation workflows;
- Training staff across legal, commercial, and customer service teams.
Action points now
Even with the delay, early preparation is wise. Here’s what you can do:
- Audit your current subscription terms
Review how your auto-renewals and cancellations work in practice. - Map out system changes
Identify what updates will be needed for billing, reminders, and cancellations. - Monitor developments closely
The exact requirements—such as timing of reminders and cooling-off rights—will only be clear once secondary legislation and guidance are published.
Need help?
If you’d like tailored advice on preparing for the new subscription regime, or support with reviewing your contracts and systems, please get in touch.