DMCCA 2024: Key changes to subscription contracts

The Digital Markets, Competition and Consumers Act 2024 (DMCCA) introduces wide-ranging reforms that will impact how you manage subscription contracts with consumers. If your business offers auto-renewing services or free trial periods followed by paid terms – as many SaaS, e-commerce and digital content providers do – the new law introduces clear legal duties around transparency, cancellation rights and renewal notices. Non-compliance could carry serious commercial and regulatory consequences.

Our commercial law solicitors can help you review your processes, revise your contract terms and ensure your business is fully prepared to comply with these changes.

Understanding the new requirements

The DMCCA defines a subscription contract as one where consumers pay for goods, services or digital content on terms that include auto-renewal, or a promotional period followed by full-price billing – unless they actively cancel.

Contracts involving insurance, energy and financial services are excluded, but for those in scope, four key obligations apply:

• Pre-contract information: You must present both 'key' and 'full' pre-contract information in a durable medium.
• Renewal reminders: Customers must receive timely and clear notices ahead of each renewal.
• Cooling-off rights: A 14-day cancellation period must be available for both the initial term and each renewal, with no penalties.
• Simple cancellation: The cancellation process must be straightforward and easy to access.

For example, if you operate a monthly SaaS subscription for consumer users, your system must notify customers before each renewal and offer cancellation via a clear online route, such as a website or app interface.

Failure to meet these obligations could result in contract cancellations, enforcement by the Competition and Markets Authority, or in serious cases, fines of up to 10% of global turnover.

Implementation timeline and legal strategy

While the DMCCA is expected to take full effect in stages, the consumer protection enforcement provisions are due from April 2026. The government’s consultation  on the proposed regulations closed in February 2025, with further details expected shortly.

Julia Ellis, our Senior Commercial Solicitor, comments:

As a subscription-based business, you have time to prepare but you need to start reviewing your subscription processes now, particularly around renewal notifications and cancellation procedures. This isn't just about compliance – it's an opportunity to strengthen customer relationships through increased transparency.

Taking steps now to assess your current subscription model, update terms and train relevant teams can prevent disruption later and support stronger customer relationships.

Plan now to stay compliant

Julia continues:

With legal obligations becoming more prescriptive under the DMCCA, subscription-based businesses should act now to understand their exposure and implement changes in good time. Reviewing your business-to-consumer contracts, digital journeys and compliance procedures will be critical to staying on the right side of the law.

Our commercial law solicitors provide tailored legal guidance to help you meet the DMCCA requirements efficiently, reducing risk while protecting your commercial interests as the regulations take effect.