This guide provides a high-level overview of the key compliance steps traders should take to prepare for the UK subscription contract rules introduced under the Digital Markets, Competition and Consumers Act 2024. It is intended as a quick reference only.
For detailed guidance, our full guide is available upon request to frank.suttie@freeths.co.uk or martha.sales@freeths.co.uk.
Consider your organisation’s status and whether it is actually excluded from the regime in relation to its day to day activities. The exemptions include (but are not limited to) contracts for:
The regular delivery of consumable goods where the supplier is a micro entity (an organisation that meets two out of three of the following criteria – turnover not greater than £620,000, balance sheet totals no greater than £316,000 and no greater than ten employees)
Charitable cultural and heritage memberships, and
Childcare services, including school-age education provision
If your subscription product is not exempt and is caught by the regime (i.e. auto-renewing goods, services or digital content), map the full customer sign-up journey across all channels (website, app, phone and offline).
Provide mandatory pre-contract information before sign-up (not buried in T&Cs), ensuring clear and prominent disclosure of:
price, payment frequency and auto-renewal mechanics
minimum term, cancellation rights and cancellation process
Ensure information presented is consistent with the Consumer Contracts Regulations 2013 (CCR)
Subscription T&Cs must clearly explain renewal, cancellation rights and cooling-off rights
Ensure acceptance mechanisms (tick-box/checkout) clearly confirm the customer understands they are entering an auto-renewing contract with ongoing payment obligations
Manage information data bases and understand how your payment processor is responding to the regulations
Provide 14-day cooling-off periods:
on initial sign-up (existing CCR-aligned and with special rules for digital products and services);
on renewal where a free/discounted trial converts to paid, or a subscription renews into a 12-month + term
Ensure systems can process full or pro-rata refunds within cooling-off periods (generally within 14 days). Calculate proportionate refunds where the customer has had use of the service
Send automated reminder notices before key renewal points (trial-to-paid conversion; 12-month + renewal), clearly setting out:
renewal date and amount payable; and
how to cancel
Configure CRM/e-commerce systems to trigger notices at required intervals
Ensure simple, accessible cancellation – available online if sign-up was online. Remove unnecessary friction (e.g. forced phone calls, hidden cancellation paths)
Train customer service teams and update help pages/FAQs/scripts accordingly
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In the next edition of our Commercial Education Brief
Due out in August, we will be taking an in depth look at the way the Competition and Markets Authority has been wielding its power to designate major tech businesses with strategic market status in relation to specific services provided - such as cloud computing and app sales platforms.
With no AI regulation bill appearing in the Kings Speech commentators are noting that the UK is increasingly out of step with the EU over the significant challenges involved. We will be taking a look at various initiatives within the EU including a recently launched review of existing legislation.
We will also be reporting back on the forthcoming "Good for Growth" Northern Education Business Forum meeting and, of course, our usual dot. gov round up of what is happening in government and its agencies.
If you are not yet on our mailing list you are welcome. Please email frank.suttie@freeths.co.uk with your request!
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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