If you sell subscriptions to UK consumers, the DMCCA changes how customers leave. It adds cooling-off rights, reminder notices, and a rule that cancelling be as easy as signing up.

The subscription rules are not live yet. They are expected in Spring 2027, which gives you time to prepare. This guide covers what changes, the penalties, and how to get your cancel flow ready.

A quick note

This is a practical guide, not legal advice. The subscription rules come from the DMCCA 2024 and will arrive through secondary legislation, so exact details and timing can shift. Confirm your setup with counsel.

How to prepare for the DMCCA

Audit your subscription lifecycle against the coming rules. This checklist covers the main obligations.

Show clear pre-contract information. State the price, renewal terms, and how to cancel before signup.

Send reminders. Notify customers before a trial converts and before a contract renews.

Honor two cooling-off periods. Allow 14 days to cancel at signup, and again after a trial converts or a 12-month+ contract renews.

Offer an easy online exit. Let customers cancel online if they signed up online, in as few steps as it took to join.

Drop the dark patterns. Remove confirmshaming and repeated "are you sure?" prompts from the cancel path.

What the DMCCA is

The Digital Markets, Competition and Consumers Act 2024 is a UK law covering competition, digital markets, and consumer protection. Two parts affect subscriptions.

The CMA's consumer enforcement powers went live in April 2025. A separate subscription contracts regime, the part about cooling-off and cancellation, is due in Spring 2027.

The new subscription contract rules

1. Pre-contract information and reminders

You give clear information before signup. You then remind customers before a free or discounted trial converts, and before a contract renews.

2. Two 14-day cooling-off periods

Customers get 14 days to cancel when they sign up. They get a second 14-day window after a trial converts to paid, or when a contract of 12 months or longer auto-renews.

3. Easy online exit

Customers must be able to cancel as easily as they subscribed. If they signed up online, they must be able to exit online. Giving only an email address is unlikely to count.

Why it matters for subscription businesses

UK consumers waste £1.6 billion a year on unwanted subscriptions. Difficulty cancelling accounts for around £382 million of that. The DMCCA targets it directly, and dark patterns like repeated "are you sure?" prompts are unlikely to pass.

Enforcement and fines

The CMA can now act directly, without going to court, and fine up to 10% of global turnover.

It has started using these powers. In April 2026 it fined the AA £4.2 million, plus over £760,000 in refunds, for hiding a mandatory fee until checkout. It was the first penalty under the new regime.

The high-profile Oasis ticketing probe shows the same appetite for consumer cases.

Who does it apply to?

The rules cover businesses selling subscriptions to consumers in the UK, wherever the business is based. That includes SaaS, streaming, memberships, and any auto-renewing consumer contract.

When the rules take effect

The CMA's consumer enforcement powers have applied since April 2025. The subscription rules are expected in Spring 2027, delayed from 2026. Because the timing rests on secondary legislation, treat it as a deadline to prepare against.

Challenges businesses face

Cancellation logic tends to sit across billing, support, and custom code. Wiring the new reminders, cooling-off windows, and easy-exit path through that stack is the hard part.

Many teams also worry that easy cancellation means losing every customer who starts to leave. A well-designed flow answers that.

How Churnkey helps you prepare and reduce churn

Churnkey gives you a hosted, self-serve Cancel Flow that customers complete online in a few clicks. That meets the easy-exit standard the DMCCA sets.

Its automatic compliance detects each customer's region and shows the right cancel option per jurisdiction, set up with a no-code editor. You can segment by market so each audience sees relevant copy, and A/B test flows to find what saves revenue.

Before a customer confirms, Churnkey can offer a fair alternative like a pause or discount through Adaptive Offers, while leaving them free to cancel. On average, companies using Churnkey save 20 to 40% of the revenue they would otherwise lose to churn.

Churnkey is GDPR compliant and SOC 2 Type II certified. It supports compliance with cancellation rules like this one, but does not replace legal review.

FAQ

What is the DMCCA?

The Digital Markets, Competition and Consumers Act 2024, a UK law covering competition, digital markets, and consumer protection. It includes a new subscription contracts regime focused on reminders, cooling-off rights, and easy cancellation.

Does it apply to my subscription business?

If you sell subscriptions to consumers in the UK, yes, wherever your business is based. It covers SaaS, streaming, memberships, and any auto-renewing consumer contract.

What are the new DMCCA subscription cancellation rules?

Clear pre-contract information, reminder notices before trials convert and before renewals, two 14-day cooling-off periods, and an easy exit that lets customers cancel online if they signed up online.

What are the cooling-off periods under the DMCCA?

One 14-day window when a customer signs up, and a second 14-day window after a free or discounted trial converts to paid, or when a contract of 12 months or longer auto-renews.

When do the DMCCA subscription rules come into force?

They are expected in Spring 2027, delayed from 2026. The CMA's broader consumer enforcement powers have applied since April 2025. Timing depends on secondary legislation.

Can the CMA fine my business, and how much?

Yes. The CMA can enforce directly, without going to court, with fines up to 10% of global turnover. In April 2026 it fined the AA £4.2 million in its first penalty under the new powers.

Does a confirmation step or retention offer break the rules?

No. The rules require that cancelling be as easy as subscribing. They do not forbid a confirmation step or a relevant offer the customer can decline. Avoid anything that hides, blocks, or complicates completing the cancellation.

How can Churnkey help my business prepare?

Churnkey provides a hosted, self-serve Cancel Flow that completes online in a few clicks, with automatic compliance by region, segmentation, and A/B testing. You can present a fair offer before the customer confirms while leaving them free to cancel. It supports compliance with rules like this one, but does not replace legal review.