The consumer landscape is rapidly evolving following the introduction of the Digital Markets, Competition and Consumers Act 2024 (DMCCA). The Act sees a number of changes to consumer law being rolled out over the course of 2025 and 2026. Last year we saw the implementation of enhanced consumer protections against banned practices like fake reviews and drip pricing. Looking ahead to 2026, there are still a number of anticipated changes including tighter regulations around subscription contracts.
Timeline for the New Regime
The Department for Business and Trade announced on 20 November 2025 that the implementation of the new subscription contracts regime will be delayed. It was initially expected to come into force in spring 2026 but is now anticipated to be later in the year, around autumn at the earliest. Whilst we do not yet know exactly when the new regime will take effect, it remains beneficial for businesses to be proactive in preparing for such changes.
Subscription Contracts – What Are They?
Most of us are all too familiar with subscription contracts which have become the new norm for television services and beyond, but what contracts are legally caught by the term “subscription contract”?
For the purposes of the DMCCA, the two key elements of a “subscription contract” are:
- The agreement is between a trader and consumer for the supply of goods, services or digital content by the trader in exchange for payment by the consumer;
- The terms of the subscription must either automatically renew at full price or include a promotional discounted period which rolls over into a full price subscription unless the consumer actively cancels the contract.
Whilst most subscription contracts will be caught by the new regime, there are some exclusions such as utility contracts, insurance, financial services and childcare. Although these agreements may not be caught by the DMCCA, they will be governed by other consumer laws.
New Rights for Consumers Mean New Requirements for Providers
New requirements will be introduced to ensure consumers are given sufficiently clear information as close to entering the subscription contract as possible to ensure consumers are fully aware of their rights and obligations under the contract.
Traders must also send reminders to their consumers at key points during the contract term which include:
- Before a trial period expires
- Before long-term contracts (12 months or more) roll over into a new term; and
- Approximately every 6 months for monthly rolling contracts.
The renewal information is of key importance and specific attention must be drawn to it, making it more obvious than any other information provided to the consumer at that time.
A new cooling-off period will also be introduced which will apply to subscription contract renewals. Consumers will benefit from a 14-day cooling off period either from when the initial free / discounted period ends or from the point of renewal for a long-term subscription contract (more than 12 months), in each case these are known as a ‘relevant renewal’.
Traders must also ensure that cancelling a subscription contract is simple and easy for consumers and they must be able to cancel the contract is the same way as they entered the contract e.g. online.
Further Details to Come
There are still details from the Government’s consultation that are yet to be published. One of the topics we expect to receive further information on is the consumers right to a refund when cancelling a subscription contract.
If you have any questions about your consumer contracts, whether you are a consumer or trader, Nockolds is here to support you. Please get in touch using our online enquiry form or by calling 0345 646 0406 and a member of the team will be in touch.