On 2 April 2026, the Department for Business and Trade published its response to the Consultation on the implementation of the new subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The Consultation had been closed for well over a year and the outcome much anticipated.

The regime is expected to come into force in Spring 2027.

The DMCCA introduces significant new requirements designed to ensure consumers have clarity and control over their subscriptions.

Businesses offering subscription contracts to consumers will be required to provide clear pre-contract information, send regular reminders (particularly before trials or contracts of 12 months or longer auto-renew), make it straightforward for consumers to exit contracts, allow online cancellation where the consumer signed up online, and provide two 14-day cooling-off periods: one when consumers first enter a subscription contract, and another after a trial or contract of 12 months or longer auto-renews.

More information about the DMCCA can be found on our tracker page here.

Cooling-off periods and refunds

The Government has confirmed that consumers will benefit from two 14-day cooling-off periods:

• an initial period when entering a contract (mirroring existing rights under the Consumer Contracts Regulations 2013 (CCRs)); and
• a renewal cooling-off period after a trial or 12-month+ contract auto-renews.

Where consumers cancel during these periods, they will be entitled to a full or proportionate refund depending on whether goods, services or digital content have been supplied.

Refunds for goods, services and digital content

• For digital content: the Government has adopted a middle-ground approach (Option 2 from the Consultation – see paras 55-57). The initial cooling-off waiver — whereby consumers can consent to immediate supply and waive their cancellation right — will be retained in line with the current process under the CCRs. However, for renewal cooling-off periods, consumers will be entitled to a proportionate refund if they cancel. Despite considerable industry concerns, the Government was not persuaded that there was a substantial risk of ‘binge and cancel’ behaviour after auto-renewal, and considered that consumer protection should take precedence.
• For goods: the Government has moved away from its original proposal to use a ‘dispatch date’ concept, instead relying on the existing concept of ‘supply’ in consumer law. Where goods are returnable, consumers will receive a refund upon return; where goods are perishable, bespoke, or sealed for health or hygiene reasons and subsequently opened, businesses may reduce the refund accordingly.
• For services, the Government has retained its proposal that refunds should be proportionate — calculated on the basis of the total subscription price for the service supplied. Despite industry concerns about ‘binge and cancel’ behaviour (for example, consumers using a gym extensively before cancelling for a near-full refund), the Government did not consider there was sufficient justification to depart from the existing approach under the CCRs.

Easy exit and online cancellation

Under the new regime, consumers must be able to exit contracts in a straightforward way, without unnecessary hurdles. Where a consumer can sign up online, they must be able to cancel online. While businesses may make retention offers or seek feedback, these must not frustrate or unreasonably elongate the cancellation process.

Further clarity on terms such as ‘online’, ‘straightforward’, and what constitutes reasonable practice will be provided in guidance.

Contractual terms restricting cancellation

The Government will legislate to prevent the use of contractual terms which have the purpose or effect of making it disproportionately difficult for consumers to cancel auto-renewal — for example, terms that only permit cancellation within a narrow window (such as 30 to 60 days before renewal). Businesses will also be prohibited from making consumers liable for payment before a rolling contract actually renews.

Information notices

Requirements for reminder notices, cooling-off notices and end-of-contract notices have been confirmed.

Key points include that notices must be provided in writing on a durable medium, the purpose of the notice must be immediately apparent to the consumer, and prescribed information must be given in a way that is more prominent than any other information provided at the same time.

Notably, the Government has stepped back from its original proposal that prescribed information must appear ‘upfront’ as the first information a consumer sees — the prominence requirement is considered sufficient.

Breach remedies

Where businesses breach certain implied terms (such as failing to send reminder notices), consumers will have the right to cancel and claim a refund. The Government will include a specific list of breaches for which consumers will not need to prove financial loss in order to access a refund — addressing concerns from consumer groups that the original proposal placed too heavy a burden on consumers.

The message from the Government is clear: the new regime will proceed broadly as proposed, with limited concessions to industry concerns.

For businesses operating subscription models, the practical implications are significant and, whilst implementation is still a year away, early preparation is recommended and should include:

• Review cancellation processes – consumers must be able to exit online if they signed up online, and the process must be straightforward without unnecessary friction.
• Prepare systems for the multiple information notices that will be required – reminder notices, cooling-off notices, and end-of-contract notices must meet the new requirements as to timing, format and content, with the purpose immediately apparent and prescribed information given prominently.
• Prepare for proportionate refund calculations – particularly for providers of digital content. Businesses will need systems in place to calculate and process refunds based on the proportion of the contract supplied.
• Audit contractual terms to remove any provisions that restrict when consumers can cancel auto-renewal or that make consumers liable for payments before renewal actually occurs.

The Government has indicated that guidance will be published to support business implementation, covering areas such as mixed contracts, easy exit requirements, and sector-specific considerations. However, with the CMA already demonstrating its appetite for enforcement under the DMCCA – having launched 14 investigations since April 2025 (see our summaries here and here) – businesses should prepare.

Early movers will be best placed to avoid regulatory scrutiny and the regime’s significant penalties, which include fines of up to 10% of annual global turnover. Our tracker page will be kept up to date as further detail emerges.

If you would like to discuss any of the above issues with our consumer team, please contact Claire Livingstone.