UK government confirms new subscription contracts rules for Spring 2027

On 2 April 2026, the UK government published its long-awaited response on the new subscription contracts regime. The announcement outlines plans for secondary legislation under the DMCCA and is expected to take effect in Spring 2027.

There are currently almost 10 million unwanted subscriptions active in the UK, costing consumers around £1.6 billion yearly. New rules under the DMCCA seek to address these unwanted expenses by empowering consumers and providing greater transparency over their subscriptions.

What has been announced?

The UK government has confirmed that the following regulations will be brought forward:

• Renewal cooling-off periods: Consumers will be able to cancel and receive a proportionate refund within 14 days of the end of a trial, or auto-renewal of a 12-month+ contract.
• Initial cooling-off periods: Mirroring existing rights under the Consumer Contracts Regulations 2013, allowing for cancellation within 14 days of entering into a contract.
• Terms restricting cancellation: Terms making it disproportionately difficult to cancel auto-renewal are not allowed. Consumers cannot be liable for payment before a contract renews.
• Information notices: Requirements have been confirmed for information notices (e.g. reminder, cooling-off and end-of-contract notices). Their purpose must be immediately apparent to consumers and provided “in writing on a durable medium”. The relevant notice must also be more prominent than other information given at the same time.
• Breach remedies: Consumers will be able to cancel and receive a refund where a business breaches certain duties. The UK government has confirmed that a list of specific acts and omissions will be published, under which consumers will not need to prove financial loss to receive a refund.
• Exclusions for charities: Contracts between charities and consumers related to their charitable purpose will be excluded from the rules.

The UK government has also confirmed further guidance will be published to support business implementation (e.g. what constitutes reasonable practice for exiting subscriptions and guidance for mixed contracts).

Takeaways for businesses

While formal commencement of the rules is awaited, businesses should note the CMA remains willing to act under its existing powers. For example, the CMA previously launched an investigation into Adobe’s subscription cancellation fees (see our analysis here). Consumer protection remains a “key priority” for the CMA (see our analysis of the CMA’s 2026-27 annual plan here).

To remain compliant, businesses should:

• Review current subscription contracts against existing rules.
• Plan for upcoming regulation and guidance by setting up compliance timelines.
• Implement clear policies and training for appropriate subscription contract practices.

Early assessment of business practices can help mitigate risk before they give rise to enforcement concerns (including fines of up to 10% of annual global turnover). At Bristows, our consumer protection team is well-experienced in providing practical solutions to businesses to comply with consumer law requirements.