The UK's Digital Markets, Competition and Consumers Act 2024 introduces a subscription regime for consumer contracts entered into from 1 January 2027. Businesses must give clear pre-contract information, send reminder notices, and make exiting straightforward. Consumers get two 14-day cooling-off periods: one at sign-up, and another after a free or discounted trial converts or a long-term contract renews.
Key takeaways
- The rules apply to consumer subscription contracts entered into on or after 1 January 2027, after being pulled forward from spring 2027.
- Two 14-day cooling-off periods: at sign-up, and again after a trial converts or a long-term contract renews.
- The government rejected industry calls to let continued use after renewal waive the second cooling-off period.
- The UK government estimates consumers spend £1.6 billion a year on subscriptions they don't want.
Picture an annual subscription renewing in February 2027.
The customer gets the charge. They shrug. Then two weeks later they're tidying up their bank statement, see it, and think: "Do I actually still use this?"
Today, in most places, it's too late. They've renewed. They're stuck until next year.
In the UK, for contracts made from January 2027, it won't be. They'll have a second 14-day cooling-off period after the renewal. And a proportionate refund if they leave.
That one rule changes how subscription businesses in the UK will have to think about renewals.
What does the UK's new subscription regime require?
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) includes what is arguably the world's most detailed set of rules for consumer subscriptions. The key features:
| Requirement | What it means |
|---|---|
| Pre-contract information | Clear details on price, renewal and how to cancel before the customer signs up |
| Reminder notices | Before renewals, and before free or discounted trials convert to full price |
| First cooling-off period | 14 days from sign-up |
| Second cooling-off period | 14 days after a trial converts or a long-term contract renews, with proportionate refunds |
| Easy exit | Straightforward, timely ways to cancel |
How did the start date move?
More than once.
| When | What happened |
|---|---|
| Earlier target | Autumn 2026 |
| Consultation response | Pushed back to spring 2027. Rejected industry calls to let continued use after renewal waive the second cooling-off period |
| 9 August 2026 | The Prime Minister announced "everyday fixes" on the cost of living and brought the rules forward to January 2027, "in time for when customers often start new subscriptions for the year ahead" |
| October 2026 | Draft guidance and regulations published, applying to contracts entered into on or after 1 January 2027 |
The government's announcement put numbers on the problem: around 155 million active subscriptions in the UK, and an estimated £1.6 billion a year spent on subscriptions consumers don't actually want. It said the change would save an average of £14 a month for each unwanted subscription.
Why is the second cooling-off period such a big deal?
Because it turns a renewal into a re-sale.
Under most subscription models, renewal is where inertia does the work. The customer doesn't cancel in time, the card is charged, and you've got another year. The UK rules take that away. Every annual renewal becomes a fresh decision, with a reminder beforehand and two weeks to change their mind afterwards.
"Set and forget" revenue gets less certain. Businesses will need to earn renewals with value delivered, not inertia.
Notice too that the government explicitly rejected the industry's idea that using the service after renewal should cancel the second cooling-off right. That was the loophole businesses wanted. They didn't get it.
My take
In the book I describe how shoe retailer DSW had a loyalty program so automated that some customers forgot they were in it. So DSW sent personalized emails telling each person how many points they needed for their next $10 certificate, and which rewards they could already claim. That's exactly how I'd treat a UK renewal reminder. Not a legal notice. A personal summary of what the customer got from you this year.
What would more renewal churn cost you?
Calculate your customer and revenue churn, and what each extra point of churn costs you.
Is the UK going further than Australia and the US?
On renewals, yes.
- Australia passed its subscription law in July 2026, starting 1 July 2027. It requires key terms at sign-up, prescribed notices and an easy exit, but there's no renewal cooling-off period. Reminder timing is left to regulations. See Australia's subscription trap laws.
- The US has no single federal rule as at October 2026, after the FTC's click-to-cancel rule was struck down in July 2025. Enforcement continues case by case. See how the click-to-cancel rule died and changed nothing.
If you sell in all three markets, design for the UK and you'll be close to covered elsewhere on renewals. Check the detail in each market, though.
What should a UK renewal reminder look like?
Here's an outline I'd test:
- The headline: "Your year with us," not "Your subscription will renew."
- What they got: usage, savings, results, in numbers.
- What's coming: one or two things they'll get next year.
- The renewal details: the date, the price, and how to change plan or cancel. Plainly.
- The downgrade option: if they're not using everything, show the cheaper plan.
The Australian renewal reminder email templates are a good starting point. The structure works in any market.
What can you steal from the UK rules?
Even if you never sell to a UK customer, these ideas lower churn.
- Send a "your year with us" summary with every renewal reminder. Show usage, savings and results.
- Price trials and introductory offers expecting some customers to cancel at conversion. If your numbers only work when nobody leaves, fix the offer. The freemium vs free trial guide helps.
- Map every sign-up and renewal email against the notice requirements before January 2027.
- Make the exit easy, with one save offer. The cancellation flow guide shows how.
- Rethink annual discounts. If annual customers can leave in the first 14 days after renewal, your discount has to win them on value. The annual discount calculator can help.
For more on how renewals work in Australia, see the automatic renewals guide.
What to do next
Work out how much of your revenue comes from renewals customers don't actively choose. Then model what happens if a slice of them leave in the cooling-off window.
Churn Rate CalculatorCustomer and revenue churn, plus what it costs you.Open the free tool →If that number scares you, start your "year in review" emails now. They work whether the law requires them or not.
Frequently asked questions
When do the UK subscription rules start?
The government has said the rules apply to consumer subscription contracts entered into on or after 1 January 2027. The date moved several times: an earlier autumn 2026 target became spring 2027, then on 9 August 2026 the Prime Minister brought it forward to January 2027. Draft guidance and regulations were published in October 2026.
Do the UK rules apply to Australian or US businesses?
They're aimed at subscriptions sold to UK consumers, so an overseas business selling subscriptions to people in the UK should assume they're likely to apply to those customers. Check with a UK adviser, especially on how the rules treat digital content, renewals and refunds.
What refund is due if someone cancels in a cooling-off period?
Refunds are meant to be proportionate, reflecting what the customer has already received. The exact rules, including how they apply to digital content and services already used, are set out in the regulations and guidance. Read the final government guidance before you design your refund process.
Are any subscriptions excluded from the UK rules?
Yes, some. The government's August 2026 announcement said certain charitable memberships for cultural and heritage organizations are excluded. Other exclusions are set out in the Act and regulations. If you're unsure whether your contract is covered, take advice rather than assuming you're exempt.
Get both books free
The Subscription Playbook (ebook + audiobook) and Feed a Starving Crowd, instantly. In Australia? Claim the free hardcover.
Robert Coorey, MBA
Robert is the author of The Subscription Playbook and Feed a Starving Crowd and a Director at BPAG Accountants in Sydney. More about Robert.
Sources
- GOV.UK, PM starts roll out of 'everyday fixes' on the cost of living, ending rip-off discounts and subscription traps (9 Aug 2026)
- GOV.UK, Government response to consultation on the implementation of the new subscription contracts regime
- Winston Taylor, DMCCA subscription contracts regime faces further delay
- Reed Smith, DMCC subscription rules delayed to spring 2027 (2026)
- Lewis Silkin, UK government publishes draft guidance and regulations for new subscription contract rules (21 Oct 2026)
- Limio, The complete guide to the DMCC Act subscription rules landing in January 2027 (vendor guide, 2026)
Facts and prices checked 27 October 2026. Spotted something out of date? Tell us.