Compliance, cancellations, and the customer experience

Indeed, these new models have transformed the way many businesses interact with their customers, applying lessons learned from established subscription-based services, such as gyms and streaming services. From both traditional retailers and ecommerce specialists offering scheduled deliveries of household essentials, groceries, and entertainment products, to the now-ubiquitous software-as-a-service model and premium subscriber options on popular social media platforms, there are numerous channels for forward-thinking businesses to establish 'sticky' streams of income, with more still to reveal themselves.

However, the rules around offering and managing subscriptions and memberships of any sort are about to change, particularly with regards to cancellations…

Throughout 2026, the Competition and Markets Authority (CMA)'s regulations around buyer protection and autorenewals are going to evolve, as part of the existing Digital Markets, Competition and Consumers Act 2024 (DMCC Act), in order to help consumers avoid getting trapped in unwanted subscriptions. Organisations found to be in violation of these new regulations can expect to face fines of as much as 10% of their annual revenue.

As a result, any retailer that offers subscriptions or memberships of any kind must be aware of how these changes will impact them in the months ahead and, adapt their systems and processes to ensure they remain fully compliant with all applicable regulations, and – most importantly – ensure that they are still able to offer a world-class experience for their subscribers. 

• Specific pre-contract information must be provided. The DMCC Act distinguishes between key pre-contract information and full pre-contract information. Both must be provided in full at the initiation of the contract, or the customer will not be bound by the stated terms. Compulsory elements include:
• Full details of payments, include frequency and amounts
• Minimum total liability
• Schedule of reminder notices
• Full cancellation rights
• Reminder notices will be compulsory. It is no longer enough to assume a customer will automatically want to renew their subscription. Reminder notices must be sent in advance of the renewal date.
• Cooling-off periods will also be compulsory. This applies to both new subscriptions and renewals. Customers must have 14-day window to cancel their subscriptions without penalty.
• Cancellations must be as simple as possible. Cancellation instructions must be provided, and the process must not include any unnecessary steps. This also applies to online subscriptions. Confirmation must be provided within 24 hours.