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Prepare your subscription service for the DMCC Act. Discover what the new rules entail and how they will affect your website.
If your business sells anything on a subscription basis, whether it’s a monthly coffee delivery, a software licence, a membership, or access to online content, the rules are about to change. The subscription contracts rules under the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act or DMCCA) now has a start date, and it’s sooner than some businesses will be prepared for.
Much of the conversation around the DMCC Act has focused on the legal site, and rightly so. But a lot of what the new rules require will land on your website, your account pages, automated emails. and you cancellation journey. So in this post, I’ll cover what the rules say, who they apply to, and the practical changes subscription websites will likely need to make.
A quick note before I get into it: I’m a Marketer, not a lawyer. I didn’t study law, I studied Archaeology (but that’s a story for another day). This post isn’t meant to replace legal advice. The detailed secondary legislation hasn’t been published yet, so please speak to a legal advisor about how the rules apply to your business.
The DMCC Act became law in May 2024. Most of its consumer protection changes came into force on the 6th April 2025, including a ban on fake reviews, rules against drip pricing (where fees are added late in the buying process), and new powers for the Competition and Markets Authority (CMA) to fine businesses directly for breaking consumer law, without going through the courts first.
Those fines are nothing to sniff at, as they can be up to 10% of global turnover, or £300,000 iff that’s higher. The CMA has already started using these powers.
“Breaches of all banned practices can attract civil action of all banned practices can attract civil action by enforcement authorities, which can result in the imposition of compliance directions and/or monetary penalties of up to the higher of £300,000 or 10% or worldwide turnover” – gov.uk
The subscription rules sit in a separate part of the Act, and they couldn’t start until the government filled in the detail through secondary legislation. That’s why they’re starting later than the rest.
The proposed start date has moved about quite a bit. The rules were originally expected in spring 2026, which then slippeed to autumn 2026, and then to spring 2027.
Then on the 9th August 2026, the Prime Minister announced that the rules would be brought forward to January 2027, timed for when many people take out new subscriptions for the year ahead.
The Department for Business and Trade has said that the requirements themselves haven’t changed from those set out in the Act and its April 2026 consultation response. Only the timing has.
At the time of writing, the secondary legislation and CMA guidance that will confirm the finer detail still haven’t been published. It also hasn’t been confirmed whether there will be any grace period after January. With roughly 3 months to go, waiting for the final guidance before starting work is a risky plan, especially if your changes need development time.
The rules apply to consumer subscription contracts for goods, services, or digital content, where the customer pays and the contract either:
Free subscriptions aren’t covered, and neither are a number of contract types that already have their own sector regulation, such as financial services and some utilities. The government is also adding an exemption for certain charitable memberships, such as those giving access to museums, heritage sites, and cultural venues.
2 other points worth knowing. The rules are about business to consumer (B2C) contracts, so subscriptions that are purely B2B fall outside of them. They will apply to any business selling subscriptions to UK consumers, regardless of where that business is based.
The requirements cover the full lifecycle of a subscription, from sign-up, through to cancellation. Here’s a summary of the main ones:
Businesses must give customers a set of key pre-contract information before they sign up. This includes that payments will recur, how often, the monthly cost, the minimum total payable, and when reminders will be sent.
This key information needs to be shown together, separately from the full terms, as close as possible to the point of sign-up. and without the customer having to click anything to see it. The final step of the sign-up journey must also include an express acknowledgement from the customer that they’re agreeing to pay.
Businesses will need to send reminders before renewal payments. For mostly monthly or weekly subscriptions, that’s at least once in every 6 month period. For subscriptions with less frequent payments, it’s before each renewal. Extra reminders are required before free or discounted trials are set to end, and before a contract renews onto a term of 12 months or more.
Each reminder must be sent a ‘reasonable period’ before payment is taken. You decide what that period is, but you have to state it upfront in the key pre-contract information.
The existing 14 day cooling-off period at the start of the contract stays. On top of that, there’s a new 14 day renewal cooling-off period after the first payment following a free or discounted trial, and after a renewal onto a term of 12 months or more.
Businesses must send a cooling-off notice on the first day of each cooling-off period, separate from any other communication.
This is the part people tend to call ‘click to cancel’. Businesses must make it straightforward to end a subscription without unnecessary steps. If someone signed up online, they must be able to cancel online, and the option can’t be buried. Customers must also be able to cancel by simply making a clear statement to the business that they want to.
From the government response, a compliant online exit is expected to mean something like a clearly labelled button on the website, app, or account page, or a web for. Giving customers an email address to write to is unlikely to be enough, and cancelling a Direct Debit through the bank doesn’t count as an exit route you can rely on. Retention offers and feedback requests are allowed, but they must not get in the way of a quick cancellation.
Once a subscription is cancelled, businesses must send an end of contract notice conforming it.
Reminder, cooling-off, and end of contract notices must be given in writing on a durable medium, and their purpose must be obvious straight away. Emails, letters, and SMS messages are expected to qualify. In-app notifications that appear briefly and cannot be revisited won’t.
Some of the less headline grabbing detail could have a big impact on how subscription sites are built.
If a customer pays because a business failed to follow certain rules, such as not giving the key pre-contract information, or not sending a required reminder, they’ll be presumed entitled to a refund of payments made since the breach. The government decided not to distinguish between minor and major breaches, so small process failures could prove costly.
If a customer cancels a digital content subscription during a renewal cooling-off period, they’ll be owed a proportionate refund. For unlimited access services, this is expected to be calculated on an average cost per day basis.
This one is important for food and drink businesses. Under current rules, perishable and personalised goods are usually exempt from cooling-off rights. Under the new rules, subscriptions for these goods will have cooling-off rights, Customers who cancel before the goods are supplied get a full refund. If they cancel after supply but within the 14 days, the business can deduct the value of the goods and delivery costs. So if you run a subscription box for fresh produce, baked goods. or made-to-order items, your refund logic may need to change.
Even before the new rules come into force, subscriptions are already covered by existing consumer laws, and the CMA is clearly paying attention.
In July 2026 it opened an investigation into Microsoft over whether Microsoft 365 Personal and Family customers were given enough information before being renewed onto more expensive plans that included Copilot. It also has an ongoing case looking at Adobe’s early termination fees. Neither investigation has reached a conclusion at the time of writing, but they’re a good signal of the practices the CMA is focussing on, which is unclear renewal information and barriers to cancellation.
If you’ve read our post on dark UX patterns, a lot of this will sound familiar. Hard to find cancellation buttons and confusing renewal terms are classic examples, and they’re now a regulatory risk as well as bad for customer trust.
Most of these requirements (if applicable to your business model) will need changes to your website, not just in your terms and conditions. If you run subscriptions on WooCommerce, you may be using a plugin like WooCommerce Subscriptions (we covered the main options in our post on selling subscriptions with WooCommerce). These plugins handle a lot of the mechanics, but none of them will make you compliant out of the box. How they’re configured, customised, and connected to your other systems is what matters.
Here are the main areas I’d look at:
Check where your key subscription information appears. Is the recurring price, payment frequency, minimum total cost, and reminder timing shown together, clearly, just before the customer commits? Does the final button or step make it obvious that they’re agreeing to recurring payments? Free trial journeys need particular attention, as the price after the trial ends has to be just as clear as the free offer.
Log in as a customer and try to cancel. Count the steps. If the cancel option is hidden in a sub-menu, requires contacting support, or sends people through several retention screens before they can confirm, it’s likely to need some reworking. Any ‘are you sure?’ offers need to be easy to skip.
Also think about customers who don’t have an account login, such as those who checked out as a guest. They need a route to cancel too.
Reminder, cooling-off, and end of contract notices all need to be send automatically, at the right time, with the right information. That means checking which emails your subscription plugin sends as standard, and any automations you have for subscription customers from your email automation platform. What needs to be built or customised, and whether the content meets the prescribed requirements once the guidance is published.
These are transactional emails, so deliverability matters. A reminder that lands in spam doesn’t help anyone, and the burden of proof sites with the business to show a cooling-off notice was sent. Good email logging worth setting up now, if you haven’t already. Our post on transactional email covers the basics.
It’s also worth keeping these notices completely separate from marketing emails, both so customers aren’t tempted to unsubscribe from them, and so their purpose is obvious at a glance.
The new renewal cooling-off period and proportionate refunds fro digital content means some sites will needs to calculate and issue partial refunds automatically. Check what your subscription plugin and payment gateway support, and whether any custom development is required.
Terms that make cancelling auto-renewal disproportionately difficult, such as long notice periods, are specifically targeted by the new rules. Your terms and conditions will need a legal review, and any website changes should line up with what your terms say.
If your subscriptions run through a CRM, a membership platform, an app, or a third-party billing system, the same requirements apply across all of them. The customer experience needs to be consistent wherever they signed up.
With the final guidance still to come, you won’t be able to finalise everything yet, but there is still plenty you can be getting on with now:
The good news is that for businesses already treating subscribers fairly, the changes may be fairly minor. Also remember that a straightforward cancellation process isn’t just about compliance. People who leave easily and have a good user experience, are far more likely to come back. We’ve built numerous sites with subscription functionality, so we know how much a smooth subscriber experience matters for retention.
If you run a WordPress or WooCommerce subscription site, or provide subscriptions as part of your offering, and you want help with any development work involved in updating your sign-up, renewal, and cancellation journeys ahead of 2027, get in touch. Our team can help you get your current setup up to scratch, alongside your legal advisors, making the changes your site needs. If you’re already a customer of ours, speak to you account manager, and we’ll get it scheduled in.
Disclaimer: This post is for general information only, and isn’t legal advice. It reflects our understanding of the DMCC Act subscription rules as of September 2026. Secondary legislation and guidance are still to be published and may change the details. Please seek professional legal advice about your specific circumstances.
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