Walker Morris / News & Insights / Subscription contracts under the DMCCA: What the new government guidance means for businesses
Walker Morris / News & Insights / Subscription contracts under the DMCCA: What the new government guidance means for businesses
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Subscription contracts under the DMCCA: What the new government guidance means for businesses
22nd October 2026
“Following the Prime Minister’s promise earlier this year to bring forward new rules to tackle “subscription traps”, the government has now published guidance on the rules governing business-to-consumer subscription contracts under the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The new requirements will apply from 1 January 2027, so businesses offering subscriptions to consumers must act now to ensure compliance once the new legislation comes into force.”
The new rules governing subscription contracts represent the latest step in the government’s broader programme of strengthening consumer protection through the new consumer enforcement regime introduced by the DMCCA. Drawing on the government’s recently published draft guidance, this article will cover:
What types of contracts do the rules apply to?
The new rules will apply to all business-to-consumer subscription contracts entered into on or after 1 January 2027, regardless of whether they are entered into online, over the phone, or in person.
However, contracts in relation to certain sectors and services are excluded from the regime, including contracts for:
What are the obligations placed on traders?
Under the new rules, traders must:
What additional rights will consumers have?
The new rules give consumers a number of new cancellation rights. In particular, consumers will generally be entitled to cancel without giving a reason and without penalty during:
Consumers may also have cancellation rights where a trader fails to comply with certain obligations under the regime and, depending on the circumstances, may be entitled to a full or partial refund upon exercising those rights.
What can businesses do to prepare?
If you’re a business that offers subscription services to consumers, you should begin preparing now to ensure that you’re ready to comply with the new rules. In particular, you should review the customer journey from sign-up through to cancellation, to identify any areas where changes may be required. Such a review should cover:
Consumer law compliance – How we can support you
The new rules governing subscription contracts are part of a wider shift towards stronger consumer protection enforcement in the UK, and the next step in the government’s crackdown on business practices that could be harmful to consumers. Our specialist Competition lawyers can help you to stay ahead by providing user-friendly compliance checklists to aid in your reviews, tailored training sessions for marketing and compliance teams, and strategic advice on compliance risk, CMA engagement, and enforcement risk mitigation. In addition to this, if/when complaints or a CMA investigation occur, we can support you with an effective strategic response.
If you’re unsure whether your practices are compliant under the new rules, now is the time to act. If you would like to get in touch, please contact Sarah Ward or Alicia Moyo.
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Partner
Competition & Foreign Investment
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sarah.ward@walkermorris.co.uk
Sarah
Ward
Partner
Competition & Foreign Investment
Sarah's contact details
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