Hit Unsubscribe: Adobe’s exit fees subject to CMA investigation

The UK’s Competition and Markets Authority (CMA) has opened an investigation into Adobe’s subscription terms, reflecting a continued focus on consumer protection in digital markets.

The case involves a common feature of subscription services: they offer ongoing access for a recurring fee and include specific terms around cancellation. The CMA is now examining whether these terms comply with consumer protection law, which could reshape subscription pricing and cancellation practices.

Consumers pay to quit Adobe

The case focuses on Adobe’s ‘annual billed monthly’ plan under which customers commit to a 12-month contract but pay in monthly instalments. If customers cancel after a ‘cooling off’ period of 14 days, they must pay an early termination fee of 50% of the remaining annual cost but lose access to the service after the end of the current billing month.

The CMA is assessing whether:

• Adobe’s cancellation fees are unfair contract terms; and 
• The presentation of these terms is misleading or unclear.

The CMA is currently gathering evidence, and a further update is expected in Autumn 2026.

More broadly, the case highlights that the CMA is willing to act using its existing powers. It follows investigations launched in November 2025 into practices such as drip pricing and pressure selling (see our analysis here).

Notably, in this case the CMA is proceeding under current consumer protection laws, rather than waiting for the new rules on subscription contracts under the Digital Markets, Competition and Consumers Act 2024 (DMCC), which are expected to come into force from Autumn 2026 (pending secondary legislation).

Growing regulatory alignment

The CMA is not the only regulator interested in subscription contract practices. Just a week earlier, the US Department of Justice (DoJ) announced a $150 million settlement with Adobe similarly focused on Adobe’s ‘annual paid monthly’ plan. The DoJ found that Adobe hid important information about its subscription plans and made cancellation unnecessarily difficult. 

Parallel cases such as these signal growing alignment in regulator behaviour. Businesses should therefore keep an eye on developments across jurisdictions to anticipate future enforcement risks.

Key takeaways

• Review subscription contracts, considering how they are presented to consumers and if anything may be misleading or unclear.
• Pay attention to the CMA’s priorities and international developments to anticipate enforcement risks.
• Stay up to date on the upcoming DMCC rules on subscription contracts.