Posted Friday 18th September 2026
The new subscription rules will come into force in January 2027. Businesses should review their arrangements now to ensure they are ready.
The DMCCA brings in a new regime for D2C subscriptions. We explained what you need to know about it in an article we published back in June (you can read it here).
The changes were originally expected to apply from spring 2027. However, as one of its “everyday fixes” to help UK consumers with the cost of living, the government has brought the implementation date forward to January 2027.
The new regime gives consumers statutory cooling-off rights following certain renewals, requires businesses to provide clearer information and reminder notices of subscription renewals, and requires businesses to ensure that cancellation is simple and without barriers. There are no changes to the rules themselves and the actions businesses will need to take to ensure compliance are therefore the same. What has changed is the timing: what was once a project for Q1 2027 has become a project for now.
Given the CMA’s enhanced enforcement powers under the DMCCA and the potentially significant penalties for non-compliance, D2C subscription businesses should ensure that preparations are well underway before the year-end period and the demands of Christmas trading.
If you would like help preparing for the 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.
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