As of Spring 2026, businesses offering subscription services to UK consumers will need to comply with new regulations designed to protect consumers from "subscription traps." The UK government is consulting on these regulations, which are part of the broader Digital Markets, Competition, and Consumers Act 2024. This blog provides an overview of the proposed changes and how businesses can prepare.
The issue with subscription contracts
Subscription services, including those for digital content, beauty products, streaming services, and insurance, have become increasingly popular in recent years. While subscriptions are convenient for consumers, they can also give rise to concerns, particularly in relation to auto-renewal clauses and free trials. These concerns have led to what are commonly referred to as "subscription traps," where consumers inadvertently find themselves locked into contracts they intended to cancel.
The new legislation, set to come into effect in Spring 2026, aims to address these issues. It introduces protections for consumers and provides clear guidelines for businesses offering subscription-based contracts.
Key aspects of the new rules
The new regulations target two main subscription models:
- Auto renewals – Subscription contracts that automatically renew after a fixed period unless cancelled by the consumer.
- Free trials – Subscription contracts that begin with a free trial period, but the consumer is automatically charged if they do not actively cancel the subscription before the trial ends.
Although these types of subscriptions are not banned, the government has set out certain protections to prevent businesses from taking advantage of consumers. These protections include:
- Cooling off periods
- Clear pre contract information
- Timely renewal reminders
- Ease of exit for consumers
The new rules do not apply to regulated sectors such as energy, water, telecommunications, and financial services, as these sectors are already covered by separate regulations.
Cooling off periods
Existing consumer protection laws already provide for a 14-day cooling-off period, allowing consumers to cancel contracts for goods and services and receive a full or partial refund. The new rules extend this cooling-off period to subscription contracts with auto-renewal provisions. For these contracts, consumers will have an additional 14-day cooling-off period starting from each renewal date.
Additionally, the government proposes new regulations to limit the ability of digital content providers to bypass cancellation rights. Specifically, digital content providers who deliver content during the cooling-off period may not be able to claim that consumers waived their rights simply by consenting to access the content.
Information and reminder requirements
Businesses will be required to provide clear information to consumers before they enter into a subscription agreement. This includes details about the renewal schedule, payment terms, and how to cancel. Importantly, businesses must also send reminders to consumers before a subscription renews, giving them the chance to cancel or adjust their terms.
Non-compliance with these requirements will lead to serious consequences, including the possibility of extended cancellation rights for consumers and stronger refund obligations for businesses.
Easy exit for consumers
The new rules emphasise that consumers should be able to exit a subscription contract as easily as they entered it. Businesses will be required to ensure that it is simple for consumers to cancel their subscriptions, especially for online contracts. This means providing an easy-to-find cancellation option online, and allowing consumers to give notice of cancellation up until a few days before the renewal date.
Non-compliance with this "easy exit" requirement will lead to penalties, similar to the consequences for failure to provide proper information and reminders.
Penalties for non-compliance
Businesses that fail to comply with the new subscription contract rules could face significant penalties. The Competition and Markets Authority (CMA) will have direct enforcement powers, including the ability to impose fines of up to 10% of a company’s global turnover.
How we can help
As businesses prepare for the upcoming changes, it is essential to review your existing contracts to ensure compliance with the new rules. We can assist in:
- Reviewing and updating terms and conditions to include clear information about renewal schedules and cancellation policies.
- Ensuring that proper cooling-off periods and cancellation processes are incorporated into subscription contracts.
- Advising on how to manage and comply with new reminder and notification requirements.
- Navigating the potential penalties for non-compliance and helping to implement strategies for minimising risks.
Contact our commercial and corporate team on 0161 696 6170 for further advice and guidance.
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