UK Subscription Contract Rules: Quick Compliance Guide for Traders

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