Subscription contract regime – is your business ready?
The new rules on consumer subscription contracts are due to come into force in January 2027 under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). For businesses impacted by the new regulations, it is imperative that steps are taken now to ensure compliance in time for the deadline.
We previously set out some of the key changes being introduced along with steps for business owners to take to reduce the risk of non-compliance. The rules were initially expected to come into force in Autumn 2026 but postponed to 2027. We now know this means from 1st January 2027.
The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 were laid out in Parliament on 19 October 2026, with draft guidance on consumer subscription contracts also published.
The new rules mean many businesses will need to provide clearer up-front information, regular reminders and an easier route to exit subscription contracts.
For businesses who have not yet reviewed their existing subscription arrangements, key areas to consider include:
- Review current contract terms and consider any necessary amendments for compliance including integrating any additional requirements in their pre-contract information;
- Review processes and the customer’s journey, particularly in relation to the entering into and cancelling of contracts, and consider whether any changes will be required to make the process to exit the contract more straightforward; and
- Consider how best to implement the new required reminder notices, cooling-off notices, and cancellation notices for customers.
For many businesses, compliance may require changes not only to contractual documentation, but also to internal processes, customer communications and digital platforms.
How Hamlins can help
Businesses which offer goods, services or digital content by way of a subscription should act now to ensure they are prepared and ready to comply with the new rules when then come into force to avoid any sanctions. If you would like to discuss the new rules for subscription contracts under the DMCCA and how your business might be affected, please get in touch.
With increasing regulatory scrutiny and evolving consumer protection laws, it is essential for businesses to have a trusted legal partner who can navigate these complexities and safeguard their best interests.