UK Subscription Contracts: New Consumer Rules Coming in 2027

Subscription and membership businesses have become a huge part of everyday life.

From online memberships and fitness programmes to subscription boxes, digital platforms, courses and communities, there are now millions of contracts in the UK where customers pay regularly for continued access to a product or service.

If your business uses UK subscription contracts to sell memberships or subscriptions directly to consumers, some significant changes are coming.

The Digital Markets, Competition and Consumers Act 2024 introduces a new set of rules specifically for consumer subscription contracts. The Government currently expects the new regime to come into force in spring 2027.

That may sound some way off, but businesses operating subscription models will need more than a quick Terms and Conditions update. Websites, checkout processes, reminder emails and cancellation procedures may all need reviewing.

So, what is changing?

First, what counts as a UK subscription contract?

The new rules are aimed at contracts between a business and a consumer where goods, services or digital content continue or renew automatically and the consumer has to take action if they want the arrangement to stop.

They also cover arrangements where a customer starts with a free or reduced price period and then automatically moves onto a paid or higher priced subscription unless they cancel.

That means the rules are potentially relevant to a wide range of businesses, including:

• online membership communities

• fitness and wellbeing memberships

• coaching memberships

• subscription boxes

• software and digital services

• paid content platforms

• online learning memberships

• clubs and membership organisations

• recurring product subscriptions

The new regime is specifically concerned with consumer contracts. If you only sell subscriptions to other businesses, these particular subscription rules will not apply in the same way.

There are also specific exclusions for certain types of contracts, including some financial services, insurance, utilities and healthcare arrangements.

Customers will need clearer information before subscribing

One of the main themes running through the new legislation is transparency. Before someone enters into a subscription, businesses will need to give them prescribed information about how the subscription works.

This is designed to make sure that customers understand things such as what they are signing up for, how much they will pay, when payments will be taken, how the subscription renews and how they can cancel.

For businesses, this means it will not necessarily be enough for all of this information to be buried somewhere in lengthy Terms and Conditions. Your customer journey and checkout process will need to work alongside your contract.

The Government has confirmed that the new regime will contain specific pre contract information requirements, with further guidance expected before the rules come into force.

Subscription reminder notices are coming

This is one of the biggest practical changes. Businesses will have to remind customers about their subscription at certain points rather than simply continuing to collect recurring payments indefinitely.

The legislation provides for reminder notices, including reminders connected with the end of trial or discounted periods and ongoing subscription payments.

Where there is no introductory or concessionary period, reminder requirements are generally linked to six month periods. Where there is a free or discounted introductory period, a reminder will also be required before the customer becomes liable for the first full renewal payment.

The Government has confirmed that reminder notices will need to be provided in writing on a durable medium, and the reason for the notice must be immediately apparent to the customer.

In practice, many businesses are likely to deal with this by email, but the final guidance will be important.

If you currently use Stripe, PayPal, Shopify, WooCommerce or another platform to manage recurring payments, this is something you should start thinking about now. Do not automatically assume that your payment provider will deal with every legal requirement for you.

Cancelling must be straightforward

We have probably all experienced it. Signing up takes approximately 30 seconds. Cancelling requires six clicks, a hidden account setting, an email to customer support and possibly sacrificing your first born child.

The new rules are specifically designed to tackle this. Consumers must be able to end their subscription in a straightforward way without unnecessary hurdles.

Crucially, where consumers can sign up online, they must also be able to cancel online. Businesses can still make an offer to encourage the customer to stay or ask why they are leaving, but this must not frustrate or unreasonably prolong the cancellation process.

The Government also intends to prevent contractual terms which make it disproportionately difficult for consumers to stop automatic renewal.

So wording such as:

“You may only cancel your renewal between 30 and 60 days before your renewal date” could become a particular problem.

The Government has confirmed that consumers should be able to stop automatic renewal rather than being trapped by narrow cancellation windows.

There will be a new cooling off period when some subscriptions renew

This is another major change. Consumers already have cooling off rights for many contracts entered into online.

The new regime introduces an additional renewal cooling off period.

A customer will generally have 14 days to cancel after:

• a free or discounted trial rolls over into a paid subscription; or

• a subscription lasting 12 months or more automatically renews.

This means that sending a reminder before renewal will not necessarily be the end of the matter. Even once the renewal has happened, the consumer may still have a statutory opportunity to change their mind.

For service subscriptions, where the service has already started during this renewal cooling off period, the Government intends to allow businesses to retain a proportionate amount for the part of the service that has already been supplied.

There are separate rules proposed for goods and digital content, so businesses offering mixed subscriptions will need to look carefully at how the regime applies to them.

Digital memberships need particular care

If your membership mainly gives customers access to digital content, there is an important distinction.

Under the existing Consumer Contracts Regulations, customers can agree to digital content being supplied immediately and acknowledge that they will lose their normal initial cooling off right once supply starts.

The Government intends to retain that approach under the new subscription regime.

However, the renewal cooling off right will still apply after a trial or qualifying long term subscription renews. If the customer cancels during that renewal cooling off period, the Government intends for them to receive a proportionate refund.

That means businesses selling online libraries, resources, digital memberships or similar products will need their wording and customer processes to distinguish carefully between initial cancellation rights and renewal cancellation rights.

What happens if you fail to tell customers about their cooling off rights?

Potentially quite a lot. The Government intends that if a business fails to give a consumer the required information about their cooling off rights, the cooling off period could be extended.

It may continue until 14 days after the business finally gives the required information, subject to a maximum extension of 12 months.

That makes getting the required notices and wording right considerably more important than simply having a technically correct clause hidden away in your Terms and Conditions.

Refunds will also be regulated

Where a customer is entitled to a refund, the Government intends to require businesses to make it without undue delay and generally within 14 days.

For services and some digital subscriptions, the business may be able to deduct an appropriate proportion for the part of the service already supplied. 

Different rules are proposed for returnable goods, bespoke goods, perishable goods and certain sealed products.

Again, the important point is that your refund policy cannot be looked at in isolation. It needs to work with your cancellation rights, renewal arrangements, Terms and Conditions and actual subscription process.

Your Terms and Conditions are only one piece of the puzzle

This is probably the biggest takeaway for businesses.

Compliance with the new rules for UK subscription contracts is unlikely to be achieved simply by adding another paragraph to your Terms and Conditions.

You may need to review:

• your Subscription or Membership Terms and Conditions

• the information shown before a customer subscribes

• your checkout process

• free trial wording

• automatic renewal wording

• reminder emails

• renewal notifications

• cancellation processes

• account settings or customer portals

• cooling off notices

• refund procedures

Your website and systems will need to do what your Terms and Conditions say they do.

Do you need to change everything now?

Not quite. As at September 2026, the new subscription regime is not yet in force.

The Government currently expects it to commence in spring 2027 and still needs to introduce further secondary legislation. It has also said that guidance will be published to help businesses implement the new requirements.

So we would not recommend businesses completely rewriting their subscription arrangements based on rules which have not yet been finalised. But we would recommend starting to prepare.

Businesses using UK subscription contracts should start reviewing how their current renewal and cancellation processes work, particularly where memberships automatically renew or customers have to contact the business manually to cancel.

If you currently do not send renewal reminders, that is another area worth putting on your radar now.

Consumer law is already being taken more seriously

The subscription regime is not the only reason to review your consumer Terms and Conditions.

Since April 2025, the Competition and Markets Authority has had much stronger powers to enforce consumer protection law directly.

The CMA can impose penalties of up to 10% of a business’s global turnover or £300,000, whichever is greater, for relevant breaches of consumer law.

That does not mean every small business making an innocent mistake is suddenly going to receive an enormous fine. It does mean, however, that consumer compliance should not be treated as an afterthought.

Running a subscription or membership business?

Your UK subscription contracts should properly reflect how your membership actually works, including payments, renewals, cancellations, access, refunds and what happens when either party wants to bring the arrangement to an end.

We have B2C Subscription and Membership Terms of Sale templates available through our online store, designed specifically for businesses selling recurring memberships and subscriptions to consumers.As the new rules move closer to implementation, we will be updating our templates to reflect the new legal requirements.

If your subscription model is more complicated, or you would prefer Terms and Conditions drafted specifically around your business, K&K Legal Consulting can also prepare bespoke Subscription or Membership Terms and Conditions for you.

The new rules may not arrive until spring 2027, but if recurring payments are an important part of your business, now is a good time to make sure your foundations are right.