The UK Government has announced that the new subscription contract regime under the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) will now come into force in January 2027, bringing forward the previously anticipated spring 2027 implementation date.
As noted in our previous updates on the DMCCA and forthcoming subscription reforms, the regime will introduce significant new obligations for businesses offering subscription products and services, including enhanced pre-contract information requirements, renewal reminders, cooling-off rights at key points in the subscription lifecycle, and “easy-to-exit” cancellation processes. The Government’s announcement shortens the implementation timeline for these changes and signals a continued focus on subscription practices as an enforcement priority.
Whilst the Government has confirmed the policy direction and consultation outcome, the draft secondary legislation still needs to be laid before Parliament, alongside accompanying statutory guidance covering practical requirements like exit mechanics and disclosure requirements. This will need to be happen imminently to give businesses time to adjust their billing systems, UI flows and terms before the January deadline.
The Government has also confirmed plans to consult this autumn on additional pricing transparency measures, including whether practices such as misleading “was” prices, artificial discounts and misleading recommended retail prices should be added to the list of automatically prohibited practices under the DMCCA. If adopted, these practices would automatically be treated as unfair commercial practices, making enforcement easier for regulators and increasing the compliance risk for consumer-facing businesses.
Why this matters For consumer-facing, technology and digital platform businesses, the announcement is a reminder that subscription compliance projects may need to be accelerated. Businesses with auto-renewing services, free-trial conversions, memberships or other recurring payment models should review subscription journeys, renewal communications and cancellation flows ahead of January 2027.
If you’d like to explore any of these issues in more detail, please reach out to the Baker McKenzie Consumer Regulatory team.
