The UK Government has published the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 (SCRs) and draft statutory guidance. The new requirements will apply to subscription contracts entered into on or after 1 January 2027, subject to Parliament approving the draft regulations.
Businesses offering products to consumers through subscription models will need to comply with new requirements at each stage of the subscription lifecycle. Companies should act now to ensure that their consumer subscription arrangements comply with the new requirements for customers in the UK, while also considering the implications and approach for pan-European or global subscription processes.
Background
Although most aspects of the enhanced consumer law regime under the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) came into operation in April 2025, the requirements relating to consumer subscriptions were initially delayed until Spring 2027. However, as covered in our recent article, the Government then announced its intention to bring implementation forward to January 2027.
The core elements of the consumer subscription regime have been known since the DMCCA received Royal Assent in 2024 and were supplemented by the Government’s consultation response in April 2026. However, questions remained about how businesses should implement certain requirements in practice, pending secondary legislation and guidance. The Government has now published draft secondary legislation, along with detailed draft statutory guidance, providing clarifications and practical guidance on those outstanding issues. Note that the subscription contracts guidance is currently described as ‘draft guidance’. The final guidance will be issued once the necessary secondary legislation is approved by Parliament, although we do not expect the guidance to materially change from its current draft form.
This is the first in a series of articles providing a refresher of the consumer subscription requirements and highlighting the important new details provided by the draft secondary legislation and statutory guidance, to help unpack the action required by businesses.
What is changing?
Under the DMCCA, businesses will be subject to new subscription rules covering pre-contract information, renewal reminders, cooling-off periods and refunds, and simplified exit processes. The table below compares the existing rules with the new subscription requirements.
| Requirement | Existing rules | New rules from January 2027 |
| Subscription information at sign-up | Businesses should provide clear information on price, delivery charges, payment and delivery frequency, minimum commitment period and cancellation rights. | Businesses must provide two layers of prescribed information at sign up. Although businesses may already provide some of the required information, the new regime prescribes additional content and imposes detailed requirements concerning its timing, grouping, prominence and format. |
| Notification requirements | No general statutory requirements for subscription reminders. | Specified notices must be provided at specified stages in the subscription lifecycle, in a durable medium, and their purpose should be immediately clear to the consumer. |
| Cooling-off rights and refunds | Consumers have a statutory initial cooling-off right of 14 days to cancel a contract and get a full refund (subject to certain exceptions). This does not apply at each subsequent renewal. | Consumers still have cooling-off rights at sign up, but further cooling-off rights apply at the end of a free trial or discounted period, and when renewing for 12 months or more. Refund calculations will depend on the type of product/service and the extent to which it has already been supplied. |
| Exit rights | General consumer law restrictions on unfair terms or misleading tactics in respect of exiting. | Exit must be straightforward without obstructive additional steps or pre-conditions. Online sign up requires an online exit route. |
We will explore each of these areas in more detail in our subsequent articles in this series.
Scope
The new rules will apply to contracts entered into on or after 1 January 2027 and will not have retrospective effect. Existing contracts that are renewed will not automatically become subject to the new rules. However, the draft guidance suggests that, as a matter of best practice, businesses apply consistent protections regardless; doing so may also be operationally preferable. Companies should therefore consider whether to maintain separate processes for legacy and new contracts or move towards common compliance standards.
The regime does not apply to certain specified sectors, including Ofcom-regulated telecommunications contracts. The rules apply to all businesses selling to consumers in the UK, including businesses established overseas. The guidance reiterates that businesses generally cannot outsource responsibility for compliance to third parties. Where a consumer enters into a subscription through a third party, such as an app store or payment service provider, the business with which the consumer contracts remains responsible for complying with the subscription rules.
How does the UK position compare to the EU?
There is currently no single EU-level consumer regime equivalent to the DMCCA regime for subscription contracts, and some Member States have their own national requirements. For example, Germany requires a specific cancellation button for certain subscriptions. This is separate from the requirement to provide EU consumers with a compliant withdrawal function, which has applied since 19 June 2026. The UK subscription reforms therefore represent further divergence between UK and EU consumer law. Baker McKenzie is helping clients navigate this increasingly fragmented compliance landscape, particularly where the same processes or systems are used across the UK, EU and other markets.
What does this mean for businesses?
The Government’s decision to bring forward implementation of the consumer subscription requirements means businesses have a compressed implementation window.
Implementation will require more than a simple update to terms and conditions. Businesses should assess their systems and processes across the entire subscription lifecycle, from updating the information provided to consumers to ensuring that communications systems can issue the required notices at the specified intervals. The practical implications will vary by subscription model: businesses offering weekly or monthly subscriptions are likely to need to operationalise renewal reminders more quickly than those offering annual subscriptions.
Crucially, the drafts do not provide for a statutory grace or transitional compliance period. Businesses should therefore plan on the basis that the requirements will apply from commencement. The CMA has been active in consumer enforcement (see our summary of its latest enforcement action here). It is therefore important that businesses act now to implement the new subscription requirements. Baker McKenzie supports businesses with subscription-model risk assessments, consumer journey mapping, advice on practical changes to products and systems, T&Cs updates and engagement with consumer regulators.
For more information, please reach out to the Baker McKenzie Consumer Law Team.
