Essential for consumer and retail businesses offering subscriptions, covering DMCC Act rules on sign-up, reminders, cancellation, refunds and CMA enforcement from 2027.

At a glance

Across the UK, there are approximately 155 million active subscriptions, representing consumer spend of around £26 billion per year, of which an estimated £1.6 billion is spent on subscriptions consumers do not want.

On 2 April 2026, the Department for Business and Trade (DBT) published its response to the consultation on the implementation of the new subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) and the government’s crackdown on 'subscription traps'. 

DBT’s response recognises that subscription-based models can benefit both retailers and consumers, but also acknowledges that consumers can drift into paying for contracts they did not mean to keep, particularly where free or discounted trials roll into paid terms and exit routes are unnecessarily difficult.

The regime is expected to commence in Spring 2027 and will, through secondary legislation and guidance, impose a set of consumer journey requirements across the subscription lifecycle. These are designed to give consumers clarity and control over their spending, and are anticipated to deliver £400 million of consumer benefit per year. 

Businesses should use this intervening period to prepare for the regime’s impact on their customer journey, refund rules and procedures, and contractual documentation updates (particularly where multiple systems are involved in the subscription lifecycle, e.g. ecommerce platform, CRM, etc.).

The CMA will be the relevant enforcement authority once the regime is live, and it has already published DMCC direct enforcement guidance for businesses.

What counts as a 'subscription contract' (and what’s out of scope)

The DMCC regime targets subscription-style arrangements for goods, services or digital content, typically involving auto-renewal and/or a free or discounted period that converts to full price unless the consumer acts. The Act also contains a list of excluded contracts (set out in Schedule 22), such as regulated utilities, financial services, and certain micro-entity traders supplying household consumables.

(a) The consultation response: the points that matter most for consumer and retail businesses

A central theme of DBT's response is its commitment to keeping the subscription regime coherent with the Consumer Contracts Regulations (CCRs) where possible. This underpins the positions taken on cooling-off rights, refund mechanics and related provisions throughout the response.

A. Cooling-off: two 14-day windows (initial + renewal)

DBT reiterates the two key 14-day 'no penalty' cancellation windows under the DMCC Act model: 

• an initial cooling-off period on entering the contract; and
• a renewal cooling-off period after a trial or 12 month+ term that auto-renews. 

Consumer-facing businesses and retailers are required to inform consumers of their cooling-off rights. DBT has confirmed it will legislate that a failure to do so should extend the cooling-off period to 14 days after the breach is corrected, up to a maximum of 12 months (consistent with the CCRs).

B. Refund mechanics by product type (goods vs services vs digital)

DBT’s response sets out how refund rules will operate across different product types, whilst maintaining consistency with the CCRs. The position differs by subscription category:

• Returnable goods (e.g. books, clothing, 'subscribe and save'): refund upon return, including standard delivery costs.
• Perishable and bespoke goods (e.g. meal kits, personalised items): full refund if cancelled before supply; if cancelled after supply, the trader may reduce the refund by the goods’ price, including delivery costs. Notably, the initial cooling-off period may be shorter, reflecting the operational risk of preparing perishable or made-to-order goods.
• Sealed and inseparably mixed goods (e.g. hygiene and beauty products): once unsealed or mixed, the trader may reduce any refund to reflect those now-unreturnable goods.
• Services (e.g. gyms, delivery passes): full refund if supply has not begun, and proportionate refund if it has, calculated on the basis of the total contract price. DBT considered 'heavy use then cancel' arguments but retained the proportionality approach.
• Digital content (e.g. streaming): DBT will adopt 'Option 2' – retaining the initial cooling-off waiver, but applying proportionate refunds in the renewal cooling-off window.
• Mixed contracts (subscriptions combining goods, services and digital content): guidance (rather than legislation) will set out how refund rules apply to bundled subscriptions.

Refunds must be made without undue delay and within 14 days of cancellation (or receipt of returnable goods), using the same payment method unless the consumer agrees otherwise. 

C. A notable carve-out: charitable cultural/heritage memberships

DBT has confirmed that it will exclude certain charitable memberships (specifically cultural and heritage-type access arrangements) from the subscription regime, citing concerns including consumer 'use then cancel' behaviour and Gift Aid implications.

D. Cancellation rights for breach (and why process failures suddenly get expensive)

DBT confirms it will legislate for a cancellation and remedy framework enabling consumers to cancel where the trader has breached specified duties (e.g. failing to send required notices). 

Recognising that requiring consumers to prove financial loss would in practice render the remedy ineffective, DBT will also set out a defined list of acts and omissions that will automatically entitle the consumer to a refund, removing the need to prove financial loss in straightforward cases.

E. 'Easy exit' and 'online exit' - what this is likely to mean in practice

Consumers must be able to exit their contracts in a straightforward way and without unnecessary hurdles. Where a consumer signed up online, they must be able to exit online. Traders may make offers or seek feedback during the cancellation process, but these must not frustrate or unreasonably elongate it. 

DBT will also legislate to prevent contractual terms that make it disproportionately difficult for consumers to cancel auto-renewal (e.g. narrow cancellation windows) or that create payment liability before the contract has actually renewed.

Annex B to the response provides a summary of DBT’s responses to each consultation question, including that: 

• 'online exit' generally means exit via the same medium used to sign up;
• providing only an email address is unlikely to satisfy the requirement; and
• cancelling a Direct Debit with the consumer's bank does not constitute an 'online exit' mechanism. 

Retail businesses should review account pages, subscription management hubs and cancellation flows to ensure that they provide a genuinely straightforward exit route that meets the regime’s requirements.

F. Notices, 'durable medium', and prominence

DBT confirms that reminder and cooling-off notices and prescribed information must be provided in writing on a durable medium (defined in the Act as including email), and the primary purpose of any notice must be immediately apparent to the consumer. 

(b) What should consumer-facing and retail businesses be doing now?

To start building a compliant programme in anticipation of secondary legislation and further guidance, consumer-facing businesses and retailers should now focus on the following workstreams:

1. Mapping the subscription journey end-to-end 
2. Fixing exit routes
3. Building out refund processes by category
4. Establishing notice governance
5. Aligning contractual terms and UX

(c) Enforcement: why this will land differently than 'yet another consumer law tweak'

The subscription regime will sit within a post-DMCC enforcement environment where the CMA has direct consumer enforcement powers, including the right to impose fines of up to £300,000 or 10% of global turnover for substantive consumer law breaches, and lower caps for procedural non-compliance.

The practical significance for businesses is that subscription compliance is no longer solely a matter of managing customer complaints – it carries material regulatory risk. 

Conclusion

DBT’s 2 April 2026 response provides welcome clarity on the shape and intended direction of the regime, and re-emphasises the government's objective of cracking down on 'subscription traps' and unfair consumer practices. With the CMA's enhanced direct enforcement powers, the regime represents a step change in how subscription practices will be scrutinised and, where necessary, penalised.

For consumer-facing businesses and retailers, the businesses best placed to meet these requirements will be those that treat compliance as an operational design exercise, mapping the subscription journey end-to-end, establishing effective governance policies, and aligning their contractual terms with the new framework.