The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) introduced new UK rules on subscription contracts with consumers, including stricter requirements on auto-renewal notices, easy cancellation, and clear pre-contract information. The consumer-protection provisions came into force in stages from 2025. For UK businesses with consumer subscription products, compliance is not optional.

The DMCC Act addresses a real consumer harm: subscription traps. Free trials that quietly convert to paid plans. Cancellation paths buried under retention flows. Auto-renewal of contracts the consumer forgot about. The new rules push businesses toward clearer practice.

What the DMCC Act covers

The Act has several parts. The consumer subscription rules apply to:

Contracts with consumers (not B2B).
Subscription contracts where the consumer pays a recurring amount for goods, services, or digital content.
Both fixed-term subscriptions and indefinite/rolling subscriptions.

It does not apply to:

B2B subscriptions.
One-off purchases.
Insurance contracts.
Utility supplies.
Financial services.

So a consumer streaming service, software subscription, magazine subscription, or fitness app is in scope. A B2B SaaS subscription is not.

What businesses must do

The key changes for in-scope subscription businesses:

1. Clear pre-contract information

Before the consumer enters the subscription, they must be given clear information in a prominent way:

The subscription is auto-renewing (if it is).
The price including any introductory or trial pricing.
When the price will change (end of trial, scheduled increase).
How to cancel.
The cancellation period and any cooling-off rights.

The information must be more prominent than typical T&Cs. Buried in a 20-page document doesn't comply.

2. Reminder notices

Before automatic renewal at a different price, or before a long renewal period, the business must send a reminder.

The Act specifies:

For annual or longer renewals: reminder sent in good time before renewal.
For shorter renewals or material price changes: appropriate notice.

Reminders must include: that the contract will renew, the price after renewal, and how to cancel.

The specific timing requirements depend on the type of subscription. The implementing regulations and guidance from the Department for Business and Trade specify.

3. Easy cancellation

The consumer must be able to cancel in a way that is at least as easy as how they signed up.

If they signed up online with a click, they must be able to cancel online with similar ease. Forcing the consumer to phone, write, or visit a physical location when they signed up online does not comply.

4. Cooling-off period

A standard 14-day cooling-off period applies to most consumer subscription contracts entered into at a distance (online, phone).

Plus a separate "cooling-off" right where the consumer can cancel within 14 days of any contract change.

5. Refund on cancellation

When the consumer cancels mid-period, refund of any unused portion (with limited deductions for actual costs).

Penalties

The Competition and Markets Authority (CMA) enforces the DMCC Act consumer rules. Penalties include:

Civil fines up to 10% of global turnover.
Individual director fines up to £300,000.
Public undertakings and consumer compensation orders.

This is a significant uplift from previous consumer protection enforcement. The CMA has signalled active enforcement on subscription traps.

What subscription businesses need to change

If you operate a consumer subscription in the UK:

Is the auto-renewal clearly disclosed before signup?
Is the price after any trial period prominently shown?
Are cancellation instructions visible during signup?
Is there a clear written summary of the subscription terms?

Audit the cancellation flow

Can consumers cancel as easily as they signed up?
Are retention flows reasonable or do they create barriers?
Are cancellations processed promptly?
Is the consumer told their cancellation has been processed?

Set up reminder notices

When are subscriptions due to renew?
When are price changes scheduled?
What reminder system sends notices?
Do the notices include all required information?

Most modern subscription billing platforms (Stripe Billing, Recurly, Chargebee) have native support for these requirements. Older custom systems may need development work.

Update terms and contracts

Most existing subscription T&Cs need updating:

Pre-contract information requirements.
Clearer renewal terms.
Reference to the consumer's rights under the DMCC Act.

Common areas of concern

Free trials converting to paid

The classic subscription trap pattern. Free trial, then auto-charges the consumer's card.

Compliance requires:

Clear disclosure that the trial will convert to paid.
The price after trial.
When the charge will hit.
A reminder before the trial ends.

Multi-month commitments

Some subscriptions require a 12-month or 24-month commitment.

The Act requires this to be clearly disclosed at signup and reminded before renewal. Early termination consequences must be clear.

Hidden price increases

Some businesses include "we may increase the price at any time" in the T&Cs. Then they actually do it.

Under the DMCC Act, material price changes must be notified clearly to the consumer with a reasonable opportunity to cancel before the change takes effect.

Cancellation gauntlets

Cancellation processes that involve calling, navigating multiple screens, answering retention questions, waiting on hold, are at significant risk of non-compliance.

The requirement is that cancellation is at least as easy as signup. Most online signups are simple; many cancellation flows are not.

What this doesn't change

You can still offer subscriptions.
You can still auto-renew them.
You can still have multi-month commitments.
You can still offer free trials.
You can still increase prices.

What changes is how clearly and prominently you disclose these things, and how easily the consumer can exit.

What to do this quarter

If you run consumer subscriptions:

Audit your signup, renewal, and cancellation flows against the DMCC requirements.
Update T&Cs and pre-contract information.
Set up reminder notices.
Make cancellation as easy as signup.
Document the changes for compliance evidence.

If you're B2B only or non-subscription, the consumer provisions don't apply, but the rest of the DMCC Act (competition, consumer rights generally) is worth being aware of.

Bottom line

The DMCC Act is the largest UK consumer law reform in over a decade. For consumer subscription businesses, the rules are real, the enforcement is real, and the penalties are real. Adopt the practices now rather than waiting for a CMA investigation.

DMCC Act 2024: auto-renewal rules explained