UK CMA Issues Draft Guidance on New Subscription Rules
Companies with UK customers must overhaul their subscription processes—enforcement is expected to be swift and costly.
UK’s Competition and Markets Authority (CMA) has released draft guidance on new subscription rules under the Digital Markets, Competition and Consumers Act (DMCC Act). Effective Jan 2027, the rules apply to any business‑to‑consumer contract that auto‑renews and imposes ongoing payments. Key obligations include upfront plain‑language disclosures, mandatory reminder notices, a simplified cancellation process, and two 14‑day cooling‑off periods. The CMA signals aggressive enforcement, having already pursued 20 cases with multi‑million‑pound penalties and pledging to target early‑compliance violators. Firms with UK customers—including those with remotely governed contracts—must audit their sign‑up, renewal, and cancellation workflows, update terms, and flag exclusions (e.g., charitable memberships, utilities, financial products). Immediate actions: review pre‑contract information against the new checklist, test reminder triggers, and train staff to handle disputes within the cooling‑off windows. Failure to align could expose firms to costly investigations and mandatory consumer redress, making proactive remediation a priority for all subscription‑based businesses.