New Subscription Contracts Regime Brought Forward
The Prime Minister’s Office has announced that the subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) will now take effect in January 2027, ahead of the previously expected Spring 2027 start date.
The regime will impose new obligations on traders offering subscription contracts, including requirements to provide pre-contract information, send auto-renewal reminders, and give consumers cancellation and termination rights. Secondary legislation will be needed before commencement to clarify certain aspects of the regime, such as exit mechanics and disclosure requirements but businesses should take steps now to ensure they are ready for the new regime in January.
The Prime Minister’s Office also confirmed that the government intends to consult in Autumn 2026 on whether pricing practices such as fake “was/now” prices, fabricated discounts and misleading RRPs should be added to the DMCCA’s list of practices that are prohibited in all circumstances.
If you would like any further information or advice on this matter, please contact a member of the Commercial Team.
*This information is for guidance purposes only and does not constitute, nor should be regarded, as a substitute for taking legal advice that is tailored to your circumstance.
