UK subscription rules laid: cancel online from 1 January 2027

The government has laid the regulations that will switch on Britain’s new subscription contract rules, and the start date is now fixed in the draft: 1 January 2027. From that day, anyone who signs up to a subscription box, a streaming service, a meal kit, a delivery pass or a members’ scheme should be able to leave online as easily as they joined, receive written reminders before trials convert and renewals bite, and claim a refund within a fresh 14-day window after a free trial ends.

The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 were laid before Parliament on 19 October, according to an analysis published by law firm CMS, alongside a set of consequential amendments and 77 pages of draft government guidance. Lewis Silkin, a second firm tracking the regime, confirmed that the rules apply to business-to-consumer subscriptions entered into on or after 1 January 2027. The Competition and Markets Authority (CMA) will enforce them directly, with fines of up to 10% of global turnover.

For UK shoppers the timing matters in a very practical way. Subscriptions taken out during Black Friday and the Christmas run-in will still sit under the old rules, while anything signed from New Year’s Day falls under the new ones. For British retailers and online sellers running subscriptions, there are roughly ten weeks left to rebuild sign-up pages, reminder emails and cancellation journeys, and the CMA has signalled there is no formal grace period.

What did the government publish and when do the rules start?

On 19 October 2026 the government laid two draft statutory instruments before Parliament, according to CMS. The first is the Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, which runs to 41 regulations and a Schedule. The second is a consequential amendments instrument that adjusts existing consumer law so it works alongside the new regime.

Alongside the regulations sits a 77-page draft guidance document covering cooling-off rights, refunds, reminder notices and what officials call “easy exit”. CMS notes that the guidance will be finalised once the regulations are made. Both draft instruments need approval by a resolution of each House of Parliament before they can take effect.

The commencement date written into both instruments is 1 January 2027. That is earlier than the “spring 2027” timetable that the government set out in its consultation response on 2 April 2026, which itself followed two earlier delays. According to law firm TLT, the Prime Minister announced the acceleration on 10 August 2026 as part of a package of “everyday fixes” for cost of living pressures, explaining that January was chosen because it is when consumers start new subscriptions for the year ahead.

The regime is set out in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act), which received Royal Assent in 2024 but whose subscription chapter has not yet been switched on. The October instruments supply the operational detail that the Act left to secondary legislation. Without them, the headline duties in the Act could not be enforced in practice.

The same Act gave the CMA its direct consumer enforcement powers, which have already been used. CMS reports that the authority has issued fines totalling more than £12 million since those powers came into force. Shoppers who followed our coverage of the CMA’s move to open up iPhone contactless payments will recognise the pattern: the DMCC Act is steadily turning into the main rulebook for how digital services treat UK consumers.

It could, but the risk looks limited. CMS cautions that parliamentary delay could push commencement back, and that details may still change before the regulations are made, but it does not expect substantial change. With about ten weeks to go, both law firms are advising businesses to plan on the basis that 1 January holds.

Which subscriptions are covered and which are not?

The rules apply to subscription contracts between traders and consumers for goods, services and digital content. In everyday terms that takes in streaming and music services, app subscriptions, software plans, coffee and meal kits, beauty and pet food boxes, razor and contact lens deliveries, gym memberships, magazine subscriptions and retailer delivery passes. Lewis Silkin says the guidance covers all three categories (goods, services and digital content).

A number of sectors sit outside the regime because they have their own regulators or rules. According to CMS, the exclusions in Schedule 22 of the Act continue to cover utilities, financial services, telecoms, gambling, childcare and micro-grocery businesses. The draft regulations add one new exclusion and narrow another.

The new exclusion is for cultural and heritage charity memberships, which means a National Trust-style membership is expected to fall outside the regime. The narrowed exclusion is for medical prescriptions: it no longer covers optical appliances such as contact lenses and spectacles, CMS reports. Recurring contact lens deliveries, one of the most common online subscriptions in the UK, are therefore expected to come within the new rules.

Subscription type	In scope from 1 January 2027?	Notes
Streaming, music and app subscriptions	Yes	Digital content; special rules on cooling-off once streaming starts
Subscription boxes (food, beauty, pet, razors)	Yes	Goods; refund rules for returnable, sealed and perishable goods
Retailer delivery passes and memberships	Yes	Services; proportionate deductions possible during cooling-off
Contact lens and spectacle subscriptions	Yes	Prescription exclusion narrowed to remove optical appliances
Gym and fitness memberships	Yes	Services; online exit required where sign-up was online
Cultural and heritage charity memberships	No	New exclusion in the draft regulations
Energy, water, broadband and mobile contracts	No	Utilities and telecoms remain excluded
Insurance, credit and other financial services	No	Financial services remain excluded
Gambling and childcare	No	Excluded under Schedule 22 of the DMCC Act

For in-scope subscriptions, the new rules replace the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the existing source of the 14-day cancellation right for online purchases. Those 2013 regulations continue to apply to subscriptions entered into before 2027 and to other consumer contracts. The Consumer Rights Act 2015 and the DMCC Act’s ban on unfair commercial practices also still apply alongside the new regime.

How will cancelling a subscription change for UK shoppers?

The most visible change for shoppers is the right to leave without a fight. Under regulation 32 of the draft, consumers may end a subscription at any time, and the exit process must be straightforward, with no steps that are not reasonably necessary. If the sign-up happened online, the exit must also be available online.

The draft guidance goes further than many retailers may expect. CMS reports that, in the government’s view, providing only an email address for cancellation requests is not enough to meet the online exit duty. In practice, that points towards a working cancel button or an equivalent self-service journey in the account area or app.

Retention offers are not banned. Traders may still show a discount or a pause option when a customer tries to leave, but such offers must not prolong the exit. Requests for feedback must be optional, so a mandatory “tell us why you are leaving” form that blocks cancellation is unlikely to comply.

Once the customer has cancelled, the trader must send an end-of-contract notice confirming it. CMS says that notice is due within 24 hours where the exit happened online and within three working days otherwise. For shoppers, that written confirmation is the evidence to keep if a payment is taken after cancelling.

Readers who follow subscription behaviour will know why this matters. Our analysis of why shoppers cancel retail subscriptions found that friction at exit is one of the most resented features of the model. The new UK rules make that friction a legal risk rather than a retention tactic.

What reminders must traders send before renewals and trials end?

Reminder notices are the second pillar of the regime. Traders must send them before certain renewals and before a free trial or discounted introductory period ends, according to both CMS and Lewis Silkin. The timing depends on the type of subscription, but the draft sets clear examples.

For subscriptions paid monthly, CMS reports that a reminder is required every six months. Where a discount spans several payments, the reminder is tied to the first payment at the higher price, under regulation 33. A shopper on a three-month half-price offer for a meal kit, for instance, should get a reminder before the first full-price charge rather than at sign-up.

Situation	Reminder required?	What the trader must do
Free trial converting to paid	Yes	Send a reminder before the trial ends, leaving time to cancel
Introductory discount ending	Yes	Tie the reminder to the first payment at the higher price
Monthly rolling subscription	Yes	Send a reminder every six months
Renewal onto a 12-month or longer term	Yes	Send a reminder before the renewal and offer a renewal cooling-off period after it
Contract signed before 1 January 2027	Not under the new regime	Existing 2013 rules and general consumer law still apply

The draft is strict about format. Notices must be given on a durable medium, clearly identified as reminders and more prominent than any other information sent with them, according to regulation 34 and section 4.4 of the draft guidance as summarised by CMS. A line buried at the bottom of a marketing newsletter will not do.

CMS adds that non-retrievable push notifications and generic service emails are unlikely to be sufficient. Retailers that currently rely on an app alert before a trial converts will need a written message the customer can keep. For shoppers, the practical effect should be fewer surprise charges on a bank statement after a forgotten free trial.

How do the new 14-day cooling-off and refund rights work?

The new regime gives consumers a 14-day cooling-off period at the start of a subscription, during which they can cancel with immediate effect. It then adds something the 2013 rules did not have: renewal cooling-off periods. According to CMS, a fresh 14-day window opens after a free trial or other concessionary period ends, and after each renewal onto a term of 12 months or more.

That second window is designed for the classic trap of a trial that silently becomes an annual plan. A shopper who notices an unexpected annual charge for a software or streaming plan will, under the draft, be able to cancel within 14 days of the renewal. For services, and for digital content in a renewal cooling-off period, the trader may keep a proportionate amount for what was actually supplied, under regulations 19 and 20.

Refund timing and the payment method

Refunds must be made without undue delay and within 14 days, using the original payment method unless the consumer expressly agrees otherwise (regulation 21). Regulations 11 to 22 set out detailed rules for goods that can be returned, sealed goods, perishables, hired goods and mixed contracts. Cancelling during the initial cooling-off period also automatically cancels any ancillary contracts, including linked credit, under regulation 22.

The linked credit point matters for subscription bundles that come with a finance agreement, such as a device sold with a monthly service. Shoppers using buy now, pay later to fund a subscription purchase should not be left paying off a plan for a service they have already cancelled during the cooling-off window.

Streaming and app businesses keep one important carve-out. The initial cooling-off right for digital content can be lost if supply starts early, but only where the consumer gives express consent to supply beginning, acknowledges that the right will be lost and receives written confirmation of both on a durable medium (regulation 7). The renewal cooling-off right, by contrast, still applies to digital content subscriptions, with a proportionate refund.

Traders that fail to give the required cooling-off information or notice face an extended cancellation period. CMS reports that the window can stretch by up to 12 months under regulations 5 and 6. The same failure prevents the trader from making certain deductions from refunds.

What must appear before a shopper signs up

The draft rules split pre-contract information into two layers. Traders must give “key” pre-contract information together and separately from other information, and must also give or make available the full pre-contract information. Lewis Silkin describes both as core duties of the regime.

The online presentation rules are tight. According to CMS, consumers cannot be required to take extra steps to read the key information beyond those needed to sign up, and the key information cannot sit behind a link or a dropdown unless opening it is a necessary part of signing up. A checkout that hides the renewal price inside an expandable “terms” box is likely to fall foul of this.

This dovetails with the CMA’s wider push on pricing presentation. Our earlier report on all-in checkout pricing across UK and EU retail set out how drip pricing rules already require mandatory fees to appear in the headline price. The subscription rules apply the same logic to recurring charges: the shopper should see what they are committing to before they press the button.

What happens if a retailer breaks the rules?

The regime creates two parallel consequences: public enforcement by the CMA and private rights for consumers. On the public side, the CMA can enforce directly, without going to court first, and fines can reach £300,000 or 10% of annual global turnover, whichever is higher, according to CMS. Trading Standards can also act, and consumers can bring their own claims in court.

On the private side, compliance with four “relevant” requirements is treated as an implied term of the contract under section 262 of the DMCC Act. CMS lists them as giving key pre-contract information, sending reminder notices, allowing a reasonable window after a reminder and offering straightforward exit. Breaching one gives the consumer a right to cancel without penalty under section 263, exercisable within 12 months (regulations 23 and 24).

The Schedule to the draft regulations lists specific failures, such as missing key information, missed or incomplete reminders and an unreasonable reminder window. For those, CMS reports that the consumer gets a refund of payments made from the relevant date until cancellation. For other breaches, a refund is due only if the breach caused a payment the consumer would not otherwise have made (regulations 25 and 26).

Refunds can be reduced where the consumer delayed unreasonably in cancelling (regulation 27). Where several cancellation rights overlap, CMS says the trader should apply the one most beneficial to the consumer. Regulation 37 also treats an auto-renewal as happening on the first day of each new contract period, and terms that try to fix liability earlier have no effect.

The CMA has set out a measured opening stance. In a blog post on 14 October 2026 reviewing 18 months of direct consumer enforcement, it said its initial focus would be on supporting compliance, with enforcement aimed at the most egregious conduct, according to both CMS and Lewis Silkin. Lewis Silkin adds that conduct during the early months may still be taken into account in later enforcement, and that genuine efforts to comply will be weighed.

CMS expects the authority’s first targets to be missing sign-up information, reminder failures and non-compliant cancellation processes. It stresses that there is no grace period, and recommends that businesses be compliant, or at least substantially compliant, by 1 January.

How much do subscription traps cost UK consumers?

The government’s case for the regime rests on a cost estimate it has repeated since the DMCC Bill stage. The Department for Business and Trade has said that almost 10 million of the UK’s 155 million active subscriptions are unwanted, costing consumers about £1.6 billion a year, according to law firm DWF’s summary of the department’s consultation papers.

Earlier government figures split that cost into components. Industry summaries of the estimates attribute around £573 million a year to subscriptions consumers have forgotten about and around £602 million to subscriptions that roll over accidentally from a free or reduced-price trial. The department has also estimated that individuals could save on average £14 a month for each unwanted subscription they are able to leave earlier.

Government estimate	Figure	Rule aimed at it
Active UK subscriptions	About 155 million	Whole regime
Unwanted subscriptions	Almost 10 million	Easy exit and reminders
Annual cost of unwanted subscriptions	About £1.6 billion	Easy exit, reminders, refunds for breaches
Spent on forgotten subscriptions	About £573 million a year	Six-monthly reminders on monthly plans
Spent after accidental trial roll-overs	About £602 million a year	Pre-conversion reminder and renewal cooling-off
Average saving per unwanted subscription	About £14 a month	Online exit at any time

These are policy estimates rather than audited data, and they date from the consultation stages of 2023 and 2024. They nonetheless explain why the Prime Minister framed the earlier start date as a cost of living measure: the biggest single group of losses comes from trials that quietly convert, which is exactly what the reminder and renewal cooling-off rules target.

What does this mean for Black Friday and Christmas subscriptions?

The cut-off date creates an awkward gap for shoppers this winter. Because the regulations only apply to contracts entered into on or after 1 January 2027, a discounted subscription taken out on Black Friday or as a Christmas gift in December will be governed by the existing rules for its whole life, not by the new regime, according to both law firms.

That matters because the run-up to Christmas is peak season for introductory subscription deals. Streaming services, coffee and wine clubs, beauty boxes and retailer delivery passes routinely use heavy first-month or first-quarter discounts to recruit customers in November and December. Under the 2013 rules, shoppers keep a 14-day cancellation right at the outset, but there is no statutory renewal cooling-off period and no statutory six-monthly reminder.

Practical steps for shoppers this winter

• Note the date any free trial or discounted period ends, and set your own reminder a few days before.
• Check whether a deal renews monthly or annually; an annual renewal signed in December will not get the new renewal cooling-off right.
• Screenshot the price, renewal terms and cancellation route at sign-up.
• If you are considering a subscription in late December, waiting until 1 January will bring it under the new rules, assuming Parliament approves them on time.
• Keep any cancellation confirmation; from 2027 traders must send one within 24 hours of an online exit.

Some traders may choose to apply the new standards early, since rebuilding cancellation journeys only for post-2027 customers would mean running two systems. None of the published analyses suggest that early compliance is required, however, so shoppers should not assume it.

What should UK retailers and subscription sellers do now?

For British retailers, marketplace sellers and direct-to-consumer brands, the October instruments turn a long-delayed policy into a ten-week project. CMS and Lewis Silkin both point to the same priority areas: sign-up pages, reminder notices, cancellation journeys and refund processes.

A compliance checklist for the next ten weeks

1. Map every subscription product. Identify which plans are in scope, which are excluded, and which mix goods, services and digital content.
2. Rebuild the sign-up page. Present key pre-contract information together, separately from other terms, and not behind a link or dropdown.
3. Build the reminder engine. Set triggers before trial and discount ends, before 12-month renewals and every six months for monthly plans, sent by email or another durable medium.
4. Add an online exit. Provide a self-service cancellation route wherever sign-up was online, and keep retention offers and surveys optional and short.
5. Automate confirmations. Send an end-of-contract notice within 24 hours of online cancellation, or within three working days otherwise.
6. Rework refunds. Refund within 14 days to the original payment method, calculate proportionate deductions for services, and handle linked credit cancellations.
7. Run two rulebooks. Keep the 2013 rules for pre-2027 customers while applying the new regime to anyone signing from 1 January.

Smaller online shops often run subscriptions through plug-ins on platforms such as WooCommerce and Shopify. Our guide to WooCommerce subscriptions and recurring billing covers the failure points in those set-ups; under the new UK rules, reminder emails and customer-facing cancel buttons move from good practice to legal requirements. Retailers relying on a plug-in should check whether the vendor plans a UK compliance update before January.

The international comparison

Britain is not alone in tightening subscription rules, but it is moving further than most. New York City’s click-to-cancel rule took effect on 1 October, and South Korea’s competition regulator has issued guidance on dark patterns including cancellation design. The UK version stands out for combining online exit, mandatory reminders, a renewal cooling-off right and turnover-based fines in one regime.

Feature	Current UK rules (2013 regulations)	New UK regime (from 1 January 2027)
Initial cooling-off	14 days	14 days, with stricter information duties
Cooling-off after trial or 12-month renewal	None	New 14-day renewal cooling-off period
Renewal and trial reminders	No specific statutory duty	Mandatory written reminders, every six months for monthly plans
Online cancellation	Not specifically required	Required where sign-up was online; email alone not enough
Cancellation confirmation	No fixed deadline	Within 24 hours online, three working days otherwise
Key information presentation	General clarity duties	Key information grouped, separate, not behind links or dropdowns
Consumer remedy for breaches	General consumer law claims	Right to cancel within 12 months plus refunds for listed failures
Regulator fines	Court-based enforcement	CMA direct fines up to £300,000 or 10% of global turnover

What happens next in Parliament

The next step is parliamentary approval. Both draft instruments must be approved by each House before ministers can make them, after which the government’s draft guidance will be finalised. If that happens on schedule, the rules will apply to new contracts from 1 January 2027.

The CMA has said it will begin by helping businesses comply and reserve enforcement for the most serious cases, but its 18-month record of direct consumer fines suggests that patience will be limited for traders that ignore the rules. For UK shoppers, the practical change arrives with the first subscriptions signed in the new year: a cancel button where there was once a phone queue, a reminder before a trial ends and a second chance to get money back after an unwanted renewal.

Frequently asked questions

When do the new UK subscription rules start?

The draft regulations are written to come into force on 1 January 2027, subject to approval by both Houses of Parliament. They apply only to subscription contracts entered into on or after that date.

Will the new rules cover a subscription I already have?

No. Subscriptions taken out before 1 January 2027 remain under the existing Consumer Contracts Regulations 2013 and general consumer law, including the Consumer Rights Act 2015. Only contracts made from 1 January 2027 fall under the new regime.

Can I cancel a subscription online under the new rules?

Yes, if you signed up online. The trader must offer an online way to leave, and the draft government guidance says providing only an email address is not enough. You can end the subscription at any time, and the trader must confirm it within 24 hours of an online cancellation.

Will I get a reminder before my free trial ends?

Yes. Traders must send a written reminder before a free trial or discounted period ends. Monthly subscriptions also require a reminder every six months, and reminders must be clearly labelled and sent on a durable medium such as email.

What is the renewal cooling-off period?

It is a new 14-day window to cancel that opens after a free trial or discounted period ends, and after each renewal onto a contract of 12 months or more. For services and digital content, the trader can keep a proportionate amount for what you used.

Which subscriptions are not covered?

Utilities, financial services, telecoms, gambling, childcare and micro-grocery businesses remain excluded. The draft regulations add a new exclusion for cultural and heritage charity memberships. Contact lens and spectacle subscriptions are now expected to be covered.

What can the CMA do to a business that breaks the rules?

The CMA can enforce the rules directly and fine a business up to £300,000 or 10% of its annual global turnover, whichever is higher. Trading Standards can also act, and consumers can cancel and claim refunds where traders fail key requirements.

Should I wait until January to sign up for a subscription deal?

If you are unsure about a subscription and do not need it before the new year, signing up on or after 1 January 2027 brings it under the stronger rules, assuming Parliament approves them on time. If you take a Black Friday or Christmas deal, note the renewal date and set your own reminder.

How much do unwanted subscriptions cost UK consumers?

The Department for Business and Trade has estimated that almost 10 million of the UK’s 155 million active subscriptions are unwanted, costing consumers around £1.6 billion a year. It has also estimated an average saving of about £14 a month for each unwanted subscription a consumer can leave earlier.