UK Government responds to consultation on new subscription contracts regime

The question

What are the proposals for a new subscription contracts regime and how do they look now the UK Government has published a response to its consultation?

The key takeaway

In Spring 2027, the Government plans to implement new regulations under the subscription contract provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCCA). These will introduce key rules governing refunds during initial and renewal cooling-off periods, as well as strict requirements for pre-contract information and reminder notices.

The background

Currently, it is estimated that there are roughly 10 million unwanted active subscriptions in the UK. The Government anticipates that making cancellation easier will save the British public around £400 million every year.  On 2 April 2026, the Government issued its response to the consultation on implementing the new subscription contracts regime introduced by the DMCCA. The response sets out the framework for upcoming secondary legislation.

The development

Following the consultation, the Government is carrying forward several core proposals with minor targeted amendments:

• refunds for digital content: currently, under the Consumer Contracts Regulations 2013 (CCRs), a consumer waives their initial 14-day cooling-off right if they want digital content supply to start immediately. The Government has decided to retain this initial waiver. However, consumers will now benefit from a new renewal cooling-off right (14 days after a trial ends or a 12-month+ contract auto-renews). If a consumer cancels during this renewal window, they will be entitled to a proportionate refund for the digital content supplied;
• information and reminder notices: reminder and cooling-off notices must be provided in writing (on a durable medium), and their purpose must be immediately apparent to the consumer. For physical goods subscriptions, cooling-off notices must also include prominent details regarding the costs of returning items if a cancellation right is exercised;
• exclusions: in a notable concession to the non-profit sector, the Government confirmed it will exclude charitable cultural and heritage memberships from the scope of the new regime.

The Government has also confirmed that it will ensure that the consequences and remedies for breaches are fair and that the technical operation of the regime is consistent with the CCRs where possible. Guidance to support businesses will also be published in due course.

Why is this important?

By retaining the initial cooling-off waiver for digital content, the Government has avoided an unnecessary divergence from existing UK and EU consumer standards, a move widely welcomed by businesses. However, the introduction of a renewal cooling-off period means digital providers must develop systems to calculate dynamic, proportionate refunds. While parts of the industry expressed concern that renewal cooling-off windows could lead to "binge and cancel" behaviour during trials, the Government prioritized consumer protection, stating the evidence of such risk was not substantial.

Any practical tips?

With a commencement date expected in Spring 2027, businesses should review their subscription structures and lifecycles as soon as possible. Cross-functional teams (legal, web design, and customer support) need to reallocate resources to update checkout processes, build compliant online cancellation hooks ("click-to-cancel"), and prepare backend systems to calculate precise, proportionate refunds for cancelled renewals.

Perhaps most importantly, businesses offering subscriptions to consumers (whether goods, services or digital content) should keep an eye out for developments as this is an area where more detail and guidance are still to come, ahead of Spring 2027.

Summer 2026