On October 19, 2026, the UK government published draft guidance on the country’s new consumer subscription contracts regime. This regime, which is set to come into force on January 1, 2027, will introduce new requirements for traders to provide transparent information to consumers, deliver renewal reminders, provide simple cancellation mechanisms, and respect cooling-off rights. The government also previously announced that it will consult on whether certain pricing practices, including “fake” discounts, should be added to the UK’s list of banned commercial practices, with the aim of facilitating effective enforcement action.

The new rules come amid heightened regulatory scrutiny of consumer-facing practices in the UK. The Competition and Markets Authority (CMA), which is responsible for enforcing the new regime, has launched a series of investigations in recent months, and has also imposed fines for prior infringements.

The New Subscription-Contract Regime

The Digital Markets, Competition and Consumers Act (DMCCA) sets out the framework for the new subscription contracting regime. Key requirements will include:

• Providing clearer up-front information, so consumers understand before signing up what they are agreeing to and what it will cost. This information must be integrated into the purchase journey, in clear and plain language, as close as possible to the point of contracting (e.g., before consumers confirm their order).
• Sending reminder notices ahead of certain renewal payments, including when a free or discounted trial is about to convert to a paid plan, so consumers can decide whether to continue. For subscription contracts that auto-renew weekly, monthly, or quarterly, and that do not include a concessionary period, reminder notices must be delivered roughly every six months.
• Making cancellation straightforward, without unnecessary barriers or friction. For instance, when a subscription is entered into online, consumers must be able to cancel online, although the draft guidance clarifies that subscription entry and exit mechanisms do not need to be identical.
• Providing a new 14-day “renewal” cooling-off period. Consumers have two 14-day cooling-off periods: an initial period that arises when they enter a subscription contract, and a renewal period that arises when a free or discounted trial converts to a paid subscription or when a contract auto-renews onto a term of 12 months or longer.

If businesses do not meet these requirements, the DMCCA provides that consumers will have the right to cancel the relevant contract, extinguishing any future payment obligations, and potentially giving rise to refund rights. In addition, the CMA may take enforcement action against non-compliant businesses, including through imposing fines of up to the higher of £300,000 or 10 percent of worldwide annual turnover.

Global Regulation and Enforcement

The majority of the DMCCA’s consumer provisions have been in force since April 2025. The CMA has already used its powers under the legislation to conduct several investigations, with a particular focus on unlawful pricing practices (see Wilson Sonsini alerts here and here). Its recent investigation into Microsoft’s marketing of consumer Microsoft 365 plans suggests that subscription practices are also becoming an important part of the CMA’s consumer protection agenda.

The Microsoft investigation concerns changes made by the company to its consumer Microsoft 365 plans in January 2025. Customers initially received the new features, including Copilot, at no extra cost, but were automatically moved onto a higher-priced plan at renewal. To avoid the increase, customers had to take active steps and cancel or opt into a time-limited “Classic” plan preserving the original features and pricing. The CMA is now investigating whether the way Microsoft communicated these changes might have misled consumers, and in particular, whether, before being moved onto the higher-priced plan, consumers were clearly informed of their options and how they compared on price.

The CMA is not the only regulator investigating the conduct. In October 2025, the Australian Competition and Consumer Commission (ACCC) sued Microsoft for allegedly misleading subscribers by presenting a binary choice between the higher-priced plan and cancelling, while omitting the Classic option, which was disclosed only after a subscriber began the cancellation process. The Italian competition authority has also opened an investigation examining the same conduct. Subscription traps, lack of pricing transparency, and unfair cancellation terms have also attracted the attention of regulators in the Asia-Pacific region, which may likewise review practices under existing antitrust, consumer protection, or e-commerce regulations, with consumer protection being one of the key drivers of enforcement.

Further changes to regulatory frameworks broadening regulators’ enforcement remits are also anticipated—as an example, in July 2026, Australia passed a bill which bans subscription traps with effect from July 1, 2027. The new law introduces certain obligations on businesses in relation to subscription contracts entered into with consumers and small business subscribers, including requirements to clearly disclose certain prescribed information such as contract duration and an obligation to give users an easy and straightforward method to cancel their “subscription contract.”

Next Steps

The new regulations will apply to all contracts entered into from January 1, 2027, therefore businesses offering subscription-based goods and services to consumers in the UK should now begin preparing for the expected January 2027 implementation date. Businesses are likely to need to review subscription terms, sign-up processes, and reminder notices to identify any required changes. They may also want to assess whether implementation will require changes to product functionality or billing systems, given the limited time remaining before the regime is expected to take effect.

Wilson Sonsini’s Regulatory practice assists clients with consumer protection, privacy, antitrust, and other consumer law-related matters. Please contact Deirdre Carroll, Jocelyn Chow, Tom Evans, or Andrew Morrison for more information.