Posted Monday 1st June 2026
If you sell D2C with a subscription offering, you will likely need to change your current cancellation policy, and checkout flows as consumers will have more cancellation rights starting from Spring 2027.
The UK is introducing a new legal regime for consumer subscription contracts designed to tackle so-called ‘subscription traps’, the new regime will increase the regulatory burden on businesses offering auto-renewing subscriptions for products or services.
Although the core consumer enforcement provisions of the DMCC Act came into force in April 2025, the new subscription-specific rules are now expected to apply from Spring 2027. Businesses therefore have a window to prepare – but early action is essential, particularly given the Competition and Markets Authority (CMA) now has the power to impose fines of up to 10% of global turnover for breaches of consumer law.
Businesses will need to provide key information about subscriptions, auto-renewals and rights to cancel in a way that is prominent, easy to understand and presented at the right time in the customer journey. This includes clearly explaining pricing (including any future price increases), billing frequency, whether the contract auto-renews, the length of any minimum term, and how the customer can cancel. The emphasis is on ensuring consumers actively understand what they are signing up to, rather than relying on dense terms and conditions.
In addition to the existing 14-day cooling-off period at the start of a subscription, consumers will gain new cancellation rights following certain renewals – for example where:
During this window, consumers will be entitled to cancel and receive a refund (on a pro-rata basis depending on the services or goods provided).
Businesses will be required to send timely reminders at key stages, such as before a free or discounted trial ends, before an annual subscription renews, and periodically for rolling subscriptions. These reminders must clearly explain that payment will be taken unless the customer cancels, helping to avoid passive rollovers into paid terms.
Businesses must ensure that cancellation processes are simple and do not involve unnecessary barriers. If the consumer signed up online, then they must be able to cancel online too without having additional offers or feedback requests which unduly elongate the cancellation process.
These changes will likely require operational and technical adjustments, including updates to sign-up flows, customer communications, and refund processes. Businesses should also review their T&Cs and user journeys now to ensure they are aligned with the direction of travel.
The new regime reflects a clear shift towards greater consumer protection and also more active enforcement from the CMA.
With potentially significant financial penalties for non-compliance, businesses offering subscription models should begin preparing well in advance of implementation.
If you would like support preparing for these changes, please get in touch with Phil Hails-Smith or Harry Davies.
This article is for reference purposes only. It does not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking or deciding not to take any action.
For founders and startups, raising capital is one of the most critical steps for any growing business. There are several funding options available to businesses, Convertible Loan Notes (“CLNs”) are one favoured option for their flexibility and ease.
Joelson are delighted to announce our charity partnerships for 2026: continuing our relationship with City Harvest and welcoming Rebel Restoration as a new charity partner.
Senior Associate RIchard Showan reflects on why close collaboration between conveyancing solicitors and estate agents is essential to achieving successful property transactions.
Sustainability and ESG have moved beyond aspirational values to become essential foundations for trust, credibility and long‑term growth in an environment where businesses are increasingly expected to prove what they stand for.
We are pledging to donate at least 1% of our annual fee revenue to support environmental organisations worldwide.
