UK Subscription Rules January 2027: What Businesses Must Do

The government laid draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 before Parliament on 19 October 2026. Subject to approval, the new subscription rules apply to consumer contracts entered into from 1 January 2027. UK businesses selling subscriptions, memberships or free trials should start redesigning sign-up, reminder and cancellation journeys now.

This is general information about draft legislation, not legal advice. The regulations still need Parliament's approval and the final guidance may change.

Key takeaways

Draft subscription regulations were laid before Parliament on 19 October 2026 and would apply to contracts entered into from 1 January 2027.
Traders must give key pre-contract information, send reminder notices before trials end and roughly every six months, and make exit straightforward.
If customers sign up online they should be able to exit online, and the draft guidance says an email address alone is not a straightforward online exit route.
The CMA can fine up to £300,000 or 10% of global turnover, whichever is higher, under its direct consumer enforcement powers.

What happened

The new regime sits in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA). It has been delayed several times. The government's consultation response of April 2026 pointed to spring 2027.

The UK Parliament's statutory instruments register records the draft regulations as laid on 19 October 2026, with a coming-into-force date of 1 January 2027. The draft regulations are on legislation.gov.uk and the government published draft guidance alongside them.

The draft guidance says: "The subscription rules apply to subscription contracts entered into on or after 1 January 2027." Contracts signed before then stay under the existing Consumer Contracts Regulations 2013.

The main duties for traders

Duty	What the draft guidance says
Key pre-contract information	Given before the consumer signs up, "first, prominently" and separately from the full information
Full pre-contract information	Given or made available before the contract, building on existing consumer law
Reminder notices	Before a free or discounted period ends, roughly every six months, and an extra earlier reminder before an auto-renewal onto 12 months or more
Reminder timing	You must state in the key pre-contract information when reminders will be sent, and the period must be reasonable
Easy exit	Exit must be "easy and straightforward", without steps that are not reasonably necessary
Online exit	Likely via the same online medium used to sign up, such as a clearly labelled button or simple webform
End of contract notice	Written confirmation on a durable medium, such as email, after a consumer ends a contract
Cooling-off	A 14-day initial cooling-off period, plus a 14-day renewal cooling-off period after a trial or after auto-renewal onto 12 months or longer

Two details will catch many small businesses. First, the draft guidance states: "We do not consider that offering an email address meets the criteria for a straightforward online exit route." Customers can still tell you by email that they want to leave, but email cannot be your only online route. Second, retention offers and feedback surveys are allowed but must not "prolong the exit process" and feedback must not be compulsory.

Exclusions

The draft guidance lists excluded contracts, including certain charitable memberships, utilities, financial products, medical prescriptions, telecoms, accommodation, micro-grocery businesses, package travel, timeshares, childcare and gambling.

Enforcement

Under its direct consumer enforcement powers, the CMA can investigate, accept undertakings and "impose financial penalties where appropriate (up to £300,000 or 10% of global turnover, whichever is higher)", according to the draft guidance. Law firm Lewis Silkin's summary of the guidance notes the CMA intends to focus early on helping businesses comply.

Who this affects in the UK

E-commerce subscriptions: coffee, beauty boxes, supplements, pet food and meal kits.
Software and apps sold to consumers, including monthly and annual plans.
Gyms, clubs and memberships, where cancellation by letter or in person only is common.
Content and media: paid newsletters, courses and streaming.
Any business offering a free trial that rolls into a paid plan.

Business-to-business contracts are not covered; the rules regulate business-to-consumer subscription contracts.

Practical checklist

List every subscription product and how customers sign up: website, app, phone, in person.
Map the renewal pattern for each: trial length, discount steps, billing frequency, renewal term.
Draft key pre-contract information that sits above the "subscribe" button, including price, frequency, how to cancel and when reminders arrive.
Build reminder emails with an unmistakable subject line, the renewal date and amount, and a direct cancellation link. Set them up as automated triggers in your billing or email platform.
Add a clearly labelled online cancel button or webform. Test that it takes as few steps as sign-up.
Send end of contract notices automatically once someone cancels.
Plan refunds for both cooling-off periods, including how to handle partly used services.
Check deliverability. Reminder notices that land in spam help no one. Test your sending domain with our free email deliverability checker and DMARC checker.
Update terms and FAQs, and train customer service staff on the new rights.

Subscription journeys are a natural fit for automation, from reminder scheduling to cancellation confirmations, but a person should own the policy and handle disputes. Make It Flow helps e-commerce brands and software companies map these workflows first; see our e-commerce automation guide or browse free tools for e-commerce and fitness and gyms.

FAQ

When do the new UK subscription rules start?

Subject to Parliament approving the draft regulations, they apply to subscription contracts entered into on or after 1 January 2027. The draft regulations were laid on 19 October 2026. Contracts signed before 1 January 2027 remain under the existing Consumer Contracts Regulations 2013 for pre-contract information and cancellation.

Do I need an online cancel button?

The draft guidance says it is likely consumers will be able to exit via the same online medium used to sign up, such as a clearly labelled button or a simple webform. It states that offering only an email address does not meet the criteria for a straightforward online exit route.

Can I still show a retention offer when someone cancels?

Yes, but carefully. The draft guidance says offers should not prolong the exit process or discourage the consumer from finishing it, and feedback must not be compulsory. A single, skippable offer screen is far safer than several steps or a mandatory call.

How often do I have to send reminder notices?

Broadly, before a free or discounted period converts to a higher price, then roughly every six months. If a contract auto-renews onto a term of 12 months or more, an additional, earlier reminder is needed. You must state the reminder timing in your key pre-contract information.

Does this apply to B2B subscriptions?

No. The regime regulates business-to-consumer subscription contracts. B2B software and service contracts fall outside it, although general contract law still applies. If you sell the same plan to both consumers and businesses, check which customers are consumers and apply the rules to them.

UK Subscription Rules From January 2027: Draft Regulations Explained

What happened