UK Subscription Contract Rules Accelerated to January 2027

If your business sells anything on subscription to UK consumers, the runway to comply with new subscription contract rules just got shorter, not longer. After nearly two years of delays, the government has done something it rarely does with regulation: brought the deadline forward.

The new rules sit under the Digital Markets, Competition and Consumers Act 2024, and they’re aimed squarely at what the government calls “subscription traps”, the free trials that quietly roll into paid contracts, the cancellation processes that take six phone calls and a cancelled direct debit to actually work. Businesses running subscription models now have less time than they’d been told to expect to get ready.

In this article, we look at what’s actually changed, what the new rules will require, and who needs to be paying attention.

What’s actually changed

The timeline for this regime has moved more than most pieces of legislation manage in their entire lifecycle. It was originally expected in spring 2026, then pushed to autumn 2026, then pushed again to spring 2027 when the government finally published its consultation response in April this year.

On 10 August, the Prime Minister announced the opposite of another delay: the regime would now come into force in January 2027, brought forward as part of a wider package the government has described as “everyday fixes” for the cost of living. The core requirements haven’t changed, only the timing, but that timing now gives businesses roughly two months less than they’d been planning around.

What businesses will actually need to do

Three changes matter most. Before a customer signs up, businesses will need to give clearer pre-contract information: pricing, billing frequency, minimum commitment periods, how and when the contract renews and exactly how to cancel it. Much of this already needs disclosing under existing consumer law, but the new rules make it more prescriptive about how and when it has to be shown, including notices given on a durable medium and written so their purpose is immediately obvious rather than buried in general terms.

Second, there will be two separate 14-day cooling-off periods rather than one. The first applies when a customer first signs up, much like existing consumer rights. The second is new: a further 14-day window after a free trial ends or after a contract auto-renews onto a term of 12 months or more, during which a customer can cancel and get a refund proportionate to what they’ve actually used. That second window is the part most businesses haven’t had to build for before.

Third, cancelling has to be genuinely straightforward, without a customer having to jump through steps that aren’t reasonably necessary just to get out of a contract they’ve already decided to leave. Signals from the government’s response suggest a single point of contact for cancelling will count in a business’s favour when regulators assess whether an exit process is straightforward enough.

Who’s actually in scope

The rules catch most paid, auto-renewing consumer subscriptions for goods, services or digital content, including ones that start with a free or discounted trial. Free subscriptions aren’t caught, since there’s no payment to protect a consumer from.

A number of sectors are excluded because they’re already regulated elsewhere: telecoms, utilities and financial services subscriptions, along with certain charitable, cultural and heritage memberships added to the exclusion list more recently. Business-to-business subscriptions sit outside the regime entirely, so a SaaS company selling to other businesses isn’t caught in the same way as one selling directly to consumers.

The CMA isn’t shy about using its powers

Since April 2025, the Competition and Markets Authority has had direct fining powers for consumer law breaches, up to 10% of a business’s global annual turnover. This isn’t a theoretical threat. In April this year the CMA issued its first fine under these powers, £4.2 million, for pricing practices under a different part of the same Act. That’s a clear signal of appetite, even before the subscription-specific rules are fully in force.

What’s still missing

The secondary legislation and CMA guidance that will spell out the practical detail, exactly what counts as a “straightforward” exit, how notices need to be worded and presented, haven’t been published yet. That leaves a gap between knowing the direction of travel and knowing precisely what to build. Given the accelerated date, that detail needs to land soon if businesses are going to have a realistic run at getting ready.

What to check now, ahead of the detail

A few things are worth starting on before the secondary legislation lands, since they don’t depend on the fine print:

• Map every point where a customer currently enters, renews or tries to leave a subscription, from the sign-up page to the cancellation button.
• Check what happens at the end of a free trial and at a 12-month renewal, since that’s where the new cooling-off period bites hardest.
• Review renewal reminder emails and notices against the requirement for clear, prominent disclosure on a durable medium.
• Look honestly at your cancellation process. If it currently takes more than one contact to actually leave, that’s the part regulators will focus on first.

Getting your subscription terms ready

None of this needs a finished answer today, but it does need a plan, particularly for anything touching pricing pages, renewal emails, and the terms customers actually sign up to. A shorter runway means less room to leave it until the new year.

If you’d like help reviewing your subscription contracts and terms and conditions ahead of January 2027, please get in touch. WCL provides business law support to help you review and update the terms your subscription customers sign up to, so you’re ready before the new rules land. We’d love to hear from you.