The DMCCA: Subscription Contracts - The Timeline Just Got Shorter

The UK Government has brought forward the date on which new laws on subscription contracts will come into force in the UK. Previously delayed until Spring 2027, the new consumer subscription contracts regime introduced by the Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) will now start in January 2027.

As previously discussed in our blog, many of the important details under the DMCCA were left to be addressed through secondary legislation. The Government published its consultation response in April 2026, and the responses within that will help shape the regulations that follow. Given the secondary legislation is to be passed via the negative procedure (Parliament is not required to approve the statutory instrument for it to become law) we would expect a draft of legislation to be published around 30 days prior to its enforcement date.

Background: what is changing under the DMCCA

As a reminder, the DMCCA introduces a new unified regime for consumer protection. We have detailed the changes in detailed in previous blogs here and here.

In relation to subscription contracts, the Act aims to end “subscription traps” where customers are stuck in contracts with ever increasing prices and no way to exit.

Businesses will need to give clearer information before customers sign up, send renewal reminders, make cancelling straightforward, and offer proper cooling-off periods and refunds. The application of the subscription rules is wide and will apply to most sectors and product offerings. Some charitable memberships for cultural and heritage organisations stay outside the regime (see our previous blog).

The change to the implementation date now means businesses have less time to prepare. In addition to updating terms and conditions and pre-contract information, many organisations will need to update their websites, apps IT systems to ensure that consumes are provided with the right information at the right time, If you’ve been working to a spring 2027 deadline, it’s time to revisit your timetable.

In the same press release, the Prime Minister’s Office also announced a separate consultation commencing in autumn 2026 on whether pricing tactics such as invented discounts, misleading RRPs and fake “was/now” prices should be added to the list of practice considered unfair under the DMCA. A positive outcome from this consultation could broaden the scope of the DMCCA further, and businesses should monitor the progress from that consultation.

CMA’s Microsoft investigation

If the accelerated enforcement timeline wasn’t reason enough to focus consumer protection law, the CMA’s latest enforcement action should be.

On 29 July 2026, the CMA announced an investigation into Microsoft. The concern was some customers may not have been given clear, upfront information about their subscription options when Microsoft 365 plans changed to include new features like Copilot.

From January 2025, Microsoft gave existing subscribers free access to new features, including Copilot, for the rest of their subscription term. Once their current subscription term ended, customers were automatically moved onto a higher-priced plan including those features unless they actively chose otherwise or cancelled.

The CMA is looking at whether Microsoft's pre-renewal communications were misleading. Specifically, whether customers were provided with all the information they needed to make an informed choice.

The CMA hasn't reached any conclusions yet on whether Microsoft has broken the law.

Since April 2025, the CMA has direct consumer enforcement powers which allow it to decide whether consumer was breached itself, instead of going to court. The CMA has reported that since these new powers were introduced, they have levied fines close to £6.2 million. Understanding the CMA’s approach to monitoring and enforcement, and staying ahead of legislative changes will help businesses ensure compliance and avoid regulatory action.

What should businesses be doing now?

Given the accelerated timeline (and the CMA’s ongoing focus on consumer protection) businesses that offer subscriptions should treat review of their subscription contract offerings as an urgent priority. Commercial and legal teams should:

• Map your existing sign-up, renewal and cancellation journeys, and identify gaps against the updated DMCCA requirements.
• Update system and UX designs to ensure an “easy exit” route. Remember, if customers can subscribe online, they must be able to cancel online too.
• Review your pre-contract and pre-renewal notification wording for clarity, especially where there is a risk existing customers may “roll over” onto a higher price come the renewal date. Ensure that your IT systems are set up to send required reminders in plenty of time.
• Consider your businesses’ approach to calculating “proportionate” refunds if a customer leaves early, and make sure your policy is clear in your customer terms.
• Talk to any third-party suppliers involved in the customer journey (such as third-party payment processors, or platform providers) about their DMCCA readiness now. Identify any gaps in their processes and/or understanding of the new regime. International suppliers will still need to conform with the requirements of the DMCCA if they are interacting with UK consumers.
• Keep an eye on CMA enforcement activity and the publication of draft secondary legislation.

The DMCCA subscription rules now arrive in January 2027, and the CMA’s Microsoft investigation shows regulators are keenly focused on subscription fairness. Businesses offering subscription should review processes now in advance of the new year. Preparing early will reduce both your compliance risk and the disruption of a compressed implementation window.