Subscription traps: the new UK rules, and what your business must do from January 2027

The short version

• Who: any business selling consumers a plan that renews and charges automatically: memberships, monthly plans, boxes, apps, and free or cheap trials that turn into full price. Not sales to other businesses, and some sectors are excluded.
• When: subscriptions taken out on or after 1 January 2027. Existing customers aren’t covered, though the guidance calls treating everyone the same "best practice".
• Before sign-up: the key terms, together and prominent, where people can read them without clicking away.
• Reminders: roughly every six months on a rolling plan, before a trial or discount ends, and twice before an annual renewal. Email, text or WhatsApp; not a pop-up that disappears.
• Leaving: "as easy as signing up". If people joined online, they must be able to leave online, and an email address isn’t enough. Confirm within 24 hours.
• Cooling-off: 14 days after sign-up, and another 14 days after a trial converts or an annual plan renews.
• Status: draft. Parliament still has to approve the regulations, and the final guidance comes after that.

Where things stand

The law behind this is Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024. Parliament passed it in 2024, but it isn’t in force yet. The detail sits in a set of regulations, and the date has moved twice this year:

• 2 April 2026: after a consultation, the government set out how the rules would work: "The measures are expected to come into force in spring 2027."
• 9 August 2026: it brought them forward: "New rules will now come into force in January 2027, in time for when customers often start new subscriptions for the year ahead."
• 19 October 2026: the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 were laid in Parliament, alongside draft guidance from the Department for Business and Trade. The draft regulations say: "These Regulations come into force on 1st January 2027."

Two things about that last step. First, both are drafts. The guidance’s front cover says the regulations are "subject to parliamentary approval", and inside: "These Draft Regulations must be approved by Parliament before they can come into force." Second, the guidance is written "as though the subscriptions regime is in force", so it reads like settled law. It isn’t yet. "The final guidance will be issued once the Regulations are made."

The date that matters is when your customer signs up: "The subscription rules apply to subscription contracts entered into on or after 1 January 2027." The government estimates there are "around 155 million active subscriptions in the UK", with people spending "£1.6 billion a year on ones they don’t actually want". Those are its figures; we haven’t checked how they were worked out.

Does it cover your business?

Probably, if you sell to the public on a plan that renews. The draft guidance defines a subscription contract as one between a business and a consumer, for goods, services or digital content, "which will auto-renew (and the consumer automatically charged) unless the consumer takes action to stop it". And: "This includes free or reduced-cost periods which auto-renew onto a full or higher price period." It applies however people sign up: online, by phone, in your premises or on their doorstep.

So, for example: a gym or studio membership, a monthly treatment plan at a salon, a window-cleaning or gardening plan paid by card, a coffee, flower or pet-food box, software or an app sold to individuals, and anything with a free trial that turns into a payment.

What isn’t covered:

• Sales to businesses. "No, they do not apply to business-to-business contracts."
• Excluded sectors, including utilities, financial products, prescriptions, phone and broadband contracts, renting a home, package holidays and timeshares, childcare, gambling, and museum, gallery and heritage memberships run by charities.
• Very small food and drink rounds. Regular deliveries of groceries by a micro-business, delivered by the business itself or collected from it, are excluded. The guidance’s example: "an individual milkman who delivers within their local area."
• Contracts taken out before 1 January 2027. "No, the rules only apply to new subscription contracts entered into on or after the subscription regime comes into force on the 1 January 2027." The guidance adds: "In general, we consider best practice would be for consumers to receive consistent protections, regardless of when they take out their contract." In practice, running two sets of rules side by side may be more trouble than moving everyone over.

Two edge cases worth knowing. Contact lenses and glasses are not part of the health exclusion: "a contract for the supply of contact lenses or spectacles is not covered by the exclusion". And if you sell through an app store or use another company for billing, the guidance says "the duties under the subscription rules are on the trader with whom the consumer enters into the subscription contract". It doesn’t say who that is in an app-store sale, so check your store terms rather than assume.

Before someone signs up

There are two layers of information. The key pre-contract information is the short list that has to come first, together, and stand out. The guidance’s summary of it includes:

• that the plan will continue and keep charging unless the customer acts, and any minimum period before they can leave;
• for a trial or discount: that it will turn into a higher payment, when, and how much;
• how often you charge and the minimum each time. If you don’t charge monthly, the monthly equivalent too: "if it is an annual contract for £120 per year, this is equivalent to £10 per month";
• the minimum total they are committing to. On £30 a month with a six-month tie-in, "the minimum amount would be £180";
• any right you have to change the price or how often you charge;
• how to leave, any notice needed, and when you’ll send reminders;
• a summary of the cooling-off rights.

Online, that list has to be on the page, not behind a link: "Essentially, the consumer should be able to read it during the purchase journey without having to click on a link to read it elsewhere." The full pre-contract information (the key list plus details such as your business name and a description of what they’re buying) can sit behind a clear link, but you then have to send it by email or on paper after sign-up, before the service starts.

And the final button has to make clear that it commits the customer to paying. The guidance gives a clearly labelled "order/buy/subscribe button" as an example, and adds: "If the trader does not do this, the consumer is not bound by the contract."

Reminders: when, how and what they say

A reminder is needed in three cases:

How far ahead is up to you, within reason. You state the window in your key information (the guidance’s example is "X to Y days before"), and the Act, in section 259, requires "a period in advance of the last cancellation date which is reasonable" for the customer to decide and act. You may read that reminders must go a fixed number of hours or days beforehand. We found no fixed number in the Act, the draft regulations or the guidance.

How you send it matters. A reminder must be in writing on a "durable medium", something the customer can keep. On that, the guidance says: "we expect a letter, email, SMS or WhatsApp message may qualify, as long as the consumer could retain and retrieve it." And: "pop-up or push notifications which are not retrievable would not meet this requirement". It should be obvious what the message is (the guidance suggests a subject line that says it’s an important reminder about a payment), and the required details have to be more prominent than anything else in it, such as marketing.

What it says: that the plan will renew unless they act; the amount and the date; the previous amount, and the difference if the price is going up; the minimum they’ll owe if it renews; and how to leave, with the date by which they must do it.

Letting people leave

"The policy intention of the legislation is that exiting should be as easy as signing up." Customers can stop a plan from renewing at any time, including straight after joining, and they keep what they’ve paid for until the current period ends. The rules:

• Online in, online out. If people can sign up online, they must be able to leave online, with the instructions somewhere they’ll find them. The guidance’s examples are a clearly labelled button on your website or app, a button on an account page, or a simple web form. "We do not consider that offering an email address meets the criteria for a straightforward online exit route."
• No obstacle course. Asking for account details is likely to be fine. "Requiring the consumer to fill in a compulsory feedback form about why they are leaving before they can proceed to the exit process is unlikely to meet the requirements."
• Offers are allowed, within limits. "If offers are made, they should not prolong the exit process or discourage the consumer from seeing it through".
• Confirm it in writing. An end-of-contract notice, stating the date the plan ends, "within 24 hours of the consumer’s notification, if the consumer ends the contract online", or "within 3 working days (beginning the day after the consumer notifies the trader), if the consumer ends the contract by other means."

The two cooling-off periods

Customers will be able to cancel, without a reason and without penalty, during two 14-day windows:

• After signing up. For a service, the 14 days run from the day they sign up: join on 1 January and the last day is 15 January. If you send goods, it ends 14 days after the first delivery arrives in full.
• After a renewal. When a trial or discount ends and the first higher payment is taken, and when a plan renews for 12 months or more. You must send a cooling-off notice on the first day of that window, or as soon as reasonably practicable, saying the plan is continuing and how to cancel.

A refund isn’t always the whole amount. If the customer asked you to start the service straight away and you gave the cooling-off information properly, they pay for what they used. The guidance’s example: an annual membership at £365, cancelled on day 4, and "the consumer is liable to pay £4 to reflect that the trader had supplied the agreed services for four of the 365 contracted days."

Get the information wrong and the window stretches. If you don’t tell people about the first cooling-off period properly, it continues until 14 days after you do, "up to a maximum of 12 months". A missing renewal cooling-off notice works the same way.

When you can take the money

One rule that catches billing systems: a renewal payment can’t fall due before the period it pays for has started. The guidance’s example is a monthly plan taken out on the 15th: "a term of the contract that makes the consumer liable for a renewal payment before the 15th of each month would be of no effect." Letting customers choose a later payment date is still fine.

If you get it wrong

• The customer can cancel. If you don’t give the key information, don’t send the reminders, don’t set a reasonable reminder window, or make leaving harder than it should be, the customer gets a right to cancel, and may be owed a refund.
• The regulator can fine. The Competition and Markets Authority can impose penalties "up to £300,000 or 10% of global turnover, whichever is higher". The CMA has the same powers over the ban on hidden fees: our post on what drip pricing is covers the gym it fined £45,000 this month.
• Doorstep sales carry a criminal offence if you don’t give the cooling-off information.

A to-do list for a small business

This is our reading of the draft guidance, not part of it:

1. List every plan you sell to individuals that renews and charges automatically, including trials and introductory prices.
2. Rewrite the sign-up page so the key terms sit together beside the button, with the monthly equivalent and the minimum total where they apply, and a button that clearly commits to paying.
3. Set up the reminders: who gets one, when, by email or text, and what it says. Pick a window you can defend as reasonable, and put it in the sign-up terms.
4. Build an online exit: a button or form, findable, with no compulsory survey, and an automatic confirmation within 24 hours.
5. Check your billing dates against the start of each period.
6. Decide what to do about existing customers before January, given the guidance’s "best practice" line.
7. Re-read the final guidance when it’s published, in case anything changed after Parliament.

What the guides on page one say

The three page-one guides for “subscription traps” we read in full were all written before 19 October, so none of them could quote the draft regulations or the new guidance. Some have also been overtaken by the date change. One guide for small businesses, last updated in June, still says: "The UK government will enforce the DMCC Act subscription regulations in Spring 2027". That was right in June; since 9 August, the date has been January 2027. The same guide says "you are required to provide 14-day cooling-off reminders and easy cancellations". The draft rules have reminder notices and cooling-off periods, and a cooling-off notice after a renewal, but they’re separate things. (Our search tool shows US results, so the British page one may differ.)

What argues the other way

• It’s a draft. Parliament could reject the regulations or the government could change them. If so, this post will say so.
• The guidance isn’t the law. It says itself that it "is not a substitute for the legislation" and that interpretation is ultimately "a matter for the courts".
• We’ve left things out. The guidance runs to 77 pages: returns of goods, digital content, bundles and charities each have their own rules. This post covers what most small service businesses will meet.
• We’re not lawyers. If a lot of your income comes from subscriptions, take advice on your own terms.
• We have an interest. We build websites and automate things like reminder emails and online cancellation, so new rules that need those are good for our line of work. Nothing here needs paying anyone, us included: check what your booking or payment system can already do before buying anything new.

Sources, and what we checked

• The Department for Business and Trade’s subscription contracts page and its draft guidance (PDF, 77 pages), published 19 October 2026.
• The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 on legislation.gov.uk, read in its full text, and section 259 of the Digital Markets, Competition and Consumers Act 2024.
• The government’s announcements of 2 April 2026 and 9 August 2026.
• Page one: the results for this search, seen through a US search tool. We read three of them in full, including the guide we quote.
• Every document above was read on 20 October 2026. We read the regulations, the guidance, the government’s pages and the guide we quote again on 22 October 2026, the morning we published; nothing we quote had changed, and the regulations were still a draft.
• Every quotation above was tested automatically against the text of its source before publication.