- within Cannabis & Hemp, Law Practice Management and Privacy topic(s)
- in United Kingdom
The UK government has indicated that the new subscriptions rules under the Digital Markets, Competition and Consumer Act 2024 will not now commence before the autumn of 2026. This is a six-month delay from the previous target, which was the spring of 2026.
The government says that it has been analysing the responses to its consultation on implementing the subscriptions rules and appreciates that businesses need time to prepare for implementation. We are now waiting for its response to the consultation with the final confirmation of when the rules will come into force, as well as what they will be.
Businesses are likely to be relieved about this. Although many have already been rushing to put new terms and systems in place for the supposed spring deadline, this has been with one arm tied behind their backs due to not having the final rules and accompanying guidance in place. As that spring deadline has drawn ever nearer, it was getting pretty late in the day for this essential information to arrive. The hope is that the extension will mean we can expect the final rules and guidance to arrive with a little more lead time before the new rules come into force.
New EU rules from 19 June 2026
As well as the UK rules, it's worth remembering that if a business sells to EU consumers, it will very soon need to comply with the new rules under a somewhat-under-the-radar financial services Directive. Even though the Directive mainly applies to financial services, it will still affect businesses that sell other products.
Businesses selling goods, services or digital content to consumers in the EU will need to offer a cancellation button, or in the language of the Directive, a prominent, easy to find 'withdrawal function' on the user interface. This aims to increase consumers' awareness of their right to cancel and to ensure that withdrawing from a contract is not more difficult than entering into it. The function must be continuously available during the cancellation period for the contract. So mark the date, because we know how long it can take to implement new website functionality: 19 June 2026.
This is different to the rules under the DMCC Act, which require businesses to provide exit routes which are straightforward and do not impose unreasonable steps or obstacles to exit the contract. If a consumer can sign up online, they must be able to exit online. But there's no need for a specific button.
It is also worth noting that certain other provisions in the Consumer Rights Directive will also apply to financial services distance contracts. These include provisions on inertia selling, additional payments, enforcement, and reporting.
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