The Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) introduces wide‑ranging reforms designed to strengthen consumer protection and promote fair competition in the UK. One of the most significant areas of change for businesses is subscription contracts, with the Act directly targeting so‑called “subscription traps”.
The subscription provisions are expected to come into force in Spring 2027. While this may seem some way off, many businesses – particularly those with digital platforms or recurring revenue models – will need to make practical operational changes that take time to implement.
Clearer information before customers sign up
Under the new regime, businesses will be required to provide clear, prominent and easy‑to‑understand information before a customer enters into a subscription contract. This includes:
- Pricing and billing frequency
- Minimum commitment periods
- Automatic renewal terms
- How and when a customer can cancel
The aim is to move away from complex or hidden terms that can lead to unintended long‑term commitments.
Mandatory reminder notices
The DMCCA also introduces new reminder notice requirements. Businesses will need to notify customers:
- Before a free trial ends
- Before a subscription automatically renews
- Particularly where renewal results in a longer or more expensive commitment
These reminders must be clear and timely, enabling customers to decide whether to continue.
Simpler cancellations
Cancelling a subscription must be at least as easy as signing up. This is likely to require changes to online journeys, ensuring customers can exit without friction or unnecessary barriers.
Enhanced cooling‑off rights
The Act strengthens cooling‑off rights, including renewal cooling‑off periods in certain circumstances. Businesses will need processes in place to manage cancellations and refunds efficiently and in line with statutory timeframes.
What businesses should be doing now
Although implementation is expected in Spring 2027, early preparation will reduce risk and avoid last‑minute disruption.
Key actions include:
- Providing clear, prominent pre‑contract information on pricing, renewals and cancellation rights
- Planning for compliant reminder notices before trials end and subscriptions renew
- Designing a simple, accessible cancellation process
- Updating systems to support cooling‑off periods, including renewals where applicable
- Reviewing and amending terms and conditions
- Aligning customer journeys and communications with fairness requirements
- Training relevant teams on the forthcoming obligations
Why this matters
Once in force, non‑compliance will expose businesses to regulatory enforcement, financial penalties and reputational damage. For SMEs relying on recurring revenue, these changes go beyond legal compliance – they directly affect customer experience and retention.
How we can help
Clarke Willmott’s commercial contracts team supports UK businesses in preparing for regulatory change, combining legal advice with practical, implementation‑focused guidance.
We can help you:
- Audit your current subscription model to identify compliance risks
- Review and update terms and conditions
- Assess customer journeys and digital interfaces for transparency and fairness
- Design compliant cancellation and renewal processes
- Advise on customer communications, including pre‑contract disclosures and reminder notices
- Support internal training for commercial, marketing and customer service teams
Our focus is on practical, proportionate solutions that minimise disruption while protecting your business and your customer relationships.
Speak with an expert
If you require further details or advice on your commercial contracts and policies, please contact us.
