Selling subscriptions in the UK under the new rules: reminders, cancellation and refunds
The DMCC Act subscription rules are due on 1 January 2027 if Parliament approves the draft Regulations. What they will require, what the 2013 Regulations require today, a checklist of what to write and send, and what Orbit sends. Checked 9 November 2026.
This guide is for a UK shop owner selling subscriptions: a monthly box, a refill, a membership, a software plan. It covers what subscription law requires before sign-up, before each renewal, at cancellation and at refund time, and what your platform does for you. We build Orbit Commerce, so weigh the Orbit parts with that in mind. Every legal point was read on legislation.gov.uk or gov.uk on 9 November 2026 and is linked; none of it is legal advice.
In short
- The subscription rules in the Digital Markets, Competition and Consumers Act 2024 were not in force on 9 November 2026. Draft Regulations before Parliament would start them on 1 January 2027 for contracts made from that day.
- From then: key information together before sign-up, a reminder roughly every six months on a monthly plan, an online way out, a confirmation within 24 hours, and 14-day cooling-off periods at the start and after a long renewal or a trial.
- Until then the Consumer Contracts Regulations 2013 apply, and the CMA can already fine up to 10% of global turnover or £300,000 for misleading practices.
- On Orbit, from £25 a month: customers cancel, pause and change plan from their account, a reminder goes out before each charge, and each renewal charges the saved card and creates an order. You write the pre-contract wording and any cooling-off notice.
Do the new subscription rules apply yet?
No. Sections 253 to 281 of the Act hold the rules, and on 9 November 2026 legislation.gov.uk still marked the chapter “prospective” (Part 4, Chapter 2 of the Act).
The switch is the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, laid before Parliament in October 2026 and awaiting approval by both Houses. Regulation 1 says they “come into force on 1st January 2027”; regulation 2 applies them only to contracts entered into on or after the day section 254 of the Act commences (read 9 November 2026). The government anticipated “spring 2027” in its consultation response of 2 April 2026, then said on 9 August 2026 that the rules “will now come into force in January 2027”, and published 77 pages of draft guidance on 19 October 2026, final once the Regulations are made.
So the rules are due on 1 January 2027 for new sign-ups but not yet approved, and the date has moved before. Existing subscriptions stay under today’s law: the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the Consumer Rights Act 2015 for faulty goods, and the Act’s ban on misleading commercial practices, in force since 6 April 2025. Section 254 catches any paid consumer contract for goods, services or digital content that renews unless the customer acts or starts with a free or discounted period, so boxes, refills, memberships, software plans and paid newsletters all fit. Schedule 22 excludes utilities, financial services, prescriptions, Ofcom-regulated telecoms, rent, package holidays, timeshares, childcare, gambling and a micro-entity’s own regular food deliveries (“an individual milkman”, read 9 November 2026).
What must you tell people before they subscribe?
Today
Schedule 2 of the 2013 Regulations lists the information for a distance sale; for a subscription that means “the total costs per billing period”, the duration and the conditions for ending a contract that is extended automatically, the minimum commitment, and how to cancel. Regulation 14 wants the price, recurring cost and duration “in a clear and prominent manner, and directly before the consumer places the order”. It also wants an explicit acknowledgement of the obligation to pay, and an order button saying “order with obligation to pay” or something equally clear, or the customer is not bound (both read 9 November 2026). Then confirm the contract on a durable medium such as email (gov.uk).
From the start date
The key pre-contract information (Schedule 23, Part 1, read 9 November 2026) must be given all together, apart from everything else, in writing for an online sale, just before the customer commits. It covers nine points: that the contract renews unless ended; any minimum period; that the customer will be charged unless they act, and when; the frequency, amount and monthly equivalent of payments; the minimum total payable; whether amounts can change; how to end it and any notice period; when reminders will be sent; and a summary of the cooling-off rights. The full information adds trading details, delivery, complaints, statutory rights and the cooling-off detail; online it can sit behind a clear link, then goes out on a durable medium after sign-up. The last step must acknowledge the obligation to pay, or the customer is not bound (section 257).
When do you have to send renewal reminders?
Today there is no fixed timetable, though the CMA’s nine compliance principles for auto-renewing contracts (19 October 2021) already say to remind customers “in good time before it happens” with the amount, the date, the deadline for turning renewal off and how (principle 5). From the start date, sections 258 and 259 of the Act fix the timetable (guidance section 4.4):
- Weekly or monthly rolling plan: before the last renewal payment in each six-month period from sign-up: sign up on 1 June, pay monthly, and reminders go before the 1 December and the next 1 June payments, not every month.
- Quarterly: the same rule, so before every second payment.
- Every nine or twelve months: before every renewal, plus an earlier extra reminder where the period is 12 months or more.
- Free or discounted first period: before the first payment at the higher price, then the six-month rhythm.
Each reminder must say the customer will be charged unless they end the contract, the renewal date and amount, the previous payment and any increase, the frequency and amount of later payments, the minimum total if they stay, the next renewal date, and how to end it and by when (Schedule 23, Part 3). Send it in writing on a durable medium, its purpose plain from the subject line, the required information more prominent than anything else, inside the window you promised (guidance 4.4).
How easy must cancelling be?
The Act separates ending (stopping the next renewal; the customer keeps what they paid for until the period ends) from cancelling (a cooling-off right or a right arising from your breach, covered next). The customer may end the contract at any time (draft regulation 32), by a route that is “straightforward” with no steps beyond those reasonably necessary (section 260), and online if they signed up online, with the instructions where they would look.
The guidance’s good routes are a clearly labelled button in the account or a simple web form. An email address alone does not count, asking for account details is fine and a compulsory feedback form is not. Offers must not prolong the exit, and a clear statement from the customer is enough (section 4.5). Within 24 hours of an online exit, send an end-of-contract notice stating the end date, within three working days otherwise (section 261). A term that charges a renewal before the new period starts has no effect (section 273).
Cooling-off periods and refunds, today and from 2027
Today, under Part 3 of the 2013 Regulations (read 9 November 2026), a distance buyer can cancel within 14 days for any reason, and for up to 12 months if you never told them. Regulations 29 to 37 cover the periods, the clear statement, the 14-day refund and services or downloads already started. Faulty goods are the Consumer Rights Act: a full refund if rejected within 30 days of delivery (section 22 of the Consumer Rights Act 2015, read 9 November 2026); our guide to what UK returns law requires has the rest. The table sets today’s rules beside the Act’s, with the refund maths from the draft Regulations and guidance sections 6 and 7.
| Duty | Today (2013 Regulations) | From the start date |
|---|---|---|
| Cancel at the start | 14 days from the contract or from receiving the goods | 14 days from the day after sign-up or the first delivery; up to 12 months if you gave no cooling-off information |
| After a renewal | None | 14 days after a free or discounted period converts or after a 12-month-plus renewal, with a cooling-off notice sent on its own on day one |
| Refund deadline | 14 days, same means, no fee | 14 days from the day after cancellation, same means unless the customer agrees otherwise |
| Service already used | A proportionate charge if the customer asked you to start early | A proportionate charge by time or units: £4 of a £365 annual membership cancelled on day four, £10 of a £50 ten-visit month after two visits, or a full refund if you prefer |
| Digital content | Nothing to pay unless consent and acknowledgement came first | The same waiver at the start; a proportionate charge in a renewal cooling-off period |
| Perishable or made-to-order goods | No change-of-mind right | Cancel only within 14 days of signing up; goods already supplied reduce the refund by their value |
What happens if you get it wrong?
For the customer, the duties become implied terms, a breach gives a right to cancel and a refund, and a contradicting term has no effect (sections 262, 263 and 273). Since 6 April 2025 the Competition and Markets Authority can decide for itself that consumer law was broken and fine “up to 10% of your business’ global turnover or £300,000 (whichever is greater)” (how the CMA uses its direct consumer enforcement powers, 28 August 2025, read 9 November 2026). The guidance lists the subscription chapter for that route. On 27 July 2026 the CMA opened a case into whether Microsoft’s pre-renewal communications were misleading, with no finding made (CMA case page). In a dispute over whether a notice was sent, you prove it (section 272).
A checklist of what to write and send
- The subscribe screen. Price per period, frequency, monthly equivalent, minimum total, how to end it, any notice period, when reminders come and a cooling-off summary, together, beside a button that says what it costs, with the full terms one click away.
- The confirmation email. Plan, price, next charge date, how to cancel.
- A reminder diary. Before each renewal that needs one, inside the promised window, with amount, date, deadline and the cancel route.
- A cancel button in the account. No phone call, no compulsory survey, and a confirmation within 24 hours stating the end date.
- A cooling-off notice the day a 12-month-plus plan renews or a trial converts, sent on its own.
- A refund routine paying inside 14 days by the same method, with a written rule for proportionate refunds.
- Records of what was sent, to whom and when.
Where Orbit fits
Subscriptions are a product type on every Orbit plan, from Solo at £25 a month (£19 a month billed yearly, ex VAT), with a 14-day trial and no card. A product carries one plan or several, from weekly to yearly, and checkout will not place the order until the shopper ticks an authorisation for the recurring charges that says they can cancel at any time from their account. There they see each subscription’s status, current period and next charge date, and can pause, resume, change plan or quantity, or cancel with an optional reason; cancelling runs to the end of the paid period and emails you both. Each renewal charges the saved card and creates an order in your Orders list, with a delivery on it for a product that ships. The subscriptions page covers the plans and the account. Every plan charges its full price from the first payment. A discount code used on a first subscription order comes off that order only, which makes the first period a discounted one under the Act, so keep the renewal reminder switched on: it goes out before the first full-price payment.
| Duty | What Orbit does | What you still do |
|---|---|---|
| Key information | Shows the price per period and the recurring schedule, and takes the recurring billing authorisation before the order | Write the Schedule 23 items on the product page and in your terms |
| Reminder notices | A Subscription Payment Reminder email before every charge, the number of days before that you set, headed “Your subscription renews on” the date, with the plan, the amount with VAT and a Manage subscription button | Add the previous payment, any increase, the minimum total and the date to act by to the template; match the days to the window you promised |
| Online exit | Cancel, Pause and Change plan buttons in the account, each governed by its own switch in Subscription settings (“Allow customers to cancel”, “Allow customers to pause”, “Allow customers to change plan”) and on from the start; the reason is optional | Keep all three on, so every subscriber has the online exit the Act asks for |
| End-of-contract notice | A Subscription Cancelled email at once, stating “Your access continues until” the date | Check its wording against the final guidance |
| Cooling-off notice after a 12-month-plus renewal | The Subscription Renewed email confirms the charge on renewal day, and the renewal order in your Orders list is your prompt | Send the notice yourself that day, on its own, as the Act requires it to stand alone |
Refunds are issued from the order in the dashboard; the proportionate maths is yours. Every subscription email is a template you edit in your branding and send from your own domain once you add three DNS records (customer emails), and each subscription keeps an activity timeline, the record section 272 asks for. The subscriptions guide covers cadences and pausing; selling IT support plans online and memberships for creators on your own site are worked examples; selling digital products, subscriptions and services covers VAT.
Read next: selling supplements online and what you may claim, selling pet food and supplies online and selling software with licence keys from your own website.
Questions people ask about selling subscriptions under the new rules
When do the new UK subscription rules start?
Not on 9 November 2026. The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, laid before Parliament in October 2026, come into force on 1 January 2027 for subscription contracts entered into from the day section 254 of the Act is switched on, once both Houses approve them. The date has moved before.
Do I have to send a reminder before every monthly payment?
Not under the Act. On a weekly or monthly rolling plan a reminder is due before the last renewal payment in each six-month period, roughly twice a year. Another is due before every renewal of 12 months or more and before a free or discounted period converts. That is the minimum; Orbit’s reminder goes out before every charge.
Do the new rules apply to subscribers I already have?
The draft Regulations apply only to subscription contracts entered into on or after section 254 of the Act comes into force, so existing contracts stay under the 2013 Regulations and the ban on misleading practices. Treating every subscriber the same way from day one is simpler.
Does a customer get a refund if they cancel a monthly subscription part-way through?
No. Ending a rolling plan stops the next payment, and the customer keeps the goods or service until the paid period ends. Change-of-mind refunds arise only inside a cooling-off period: 14 days from sign-up today, and once the new rules start also 14 days after a 12-month-plus renewal or a trial converting, less a proportionate amount for any service already supplied.
Does Orbit send the renewal reminder for me?
Yes. Switch on Payment reminder in Subscription settings and set the days before the charge (three by default), and every subscriber gets a Subscription Payment Reminder email before each charge with the plan, the amount including VAT, the renewal date and a Manage subscription button. Edit the template to add the other items the Act lists, such as the date to act by.
If you sell on repeat, set up one plan on the 14-day free trial, no card required, subscribe to it yourself, and read every email it sends you against the checklist above.