DMCCA: Saying goodbye to subscription traps from spring 2027

Businesses offering subscription services to UK consumers need to tread carefully, with the Government proposing a further crackdown on subscription contracts as part of the Digital Markets, Competition, and Consumers Act 2024 (DMCCA).

On April 2 2026, the Government announced that the new rules governing subscription contracts are expected to come into force in spring 2027, which is a further delay on the previous goal of Autumn 2026. The new measures aim to protect UK consumers from costly ‘subscription traps’ by making subscriptions simpler and easier to cancel.

In this article, David Wozniak, associate solicitor in our commercial team, outlines the proposed changes and what businesses need to know.

What are ‘subscription traps’?

Subscription traps can occur where consumers are locked into a recurring contract , incurring contractual payments, without any clear guidance on how to terminate. They can also occur where there is an automatic increase in the original price. For example, where a consumer doesn't cancel a free trial within a specified period and they become tied into a payment plan.

There is a long list of excluded contracts, such as utilities contracts and contracts that are regulated by OFCOM.

To avoid legal, financial, and reputational risks, businesses need to refrain from using tactics like these.

What’s changing?

The new regulations demand clear, simple information to be provided to consumers before they sign up to a subscription contract. Proposed changes also require businesses to give consumers a 14-day cooling-off period when they initially sign up to the subscription contract and a cooling-off notice on renewal. Importantly, for the first time, it is a criminal offence if a business fails to provide a consumer with their cooling-off rights.  

Businesses will also have to ensure consumers can cancel subscriptions easily (this includes online subscriptions and app subscriptions).

The risks of non-compliance

Businesses that engage in subscription traps can face financial penalties of up to 10% of their global turnover or £300,000 (whichever is higher). Non-compliance can also lead to significant reputational damage and loss of trust and confidence from consumers, so it’s essential for businesses to stay compliant.

For more information on the DMCCA or any area of consumer law, contact David Wozniak on [email protected] or 0191 2117831.