Legal briefing | 30 Sep 2026 |

B2C subscription contracts: where are we now?

In August, the UK Government announced that it was bringing forward the date for implementing the UK's new subscription contracts regime to January 2027 (it had previously said "Spring 2027"). There are now only 3 months left in which to prepare – and as we explain below, the sooner you start that process, the better.

The new UK subscription contracts regime: a reminder

Many UK consumer-facing businesses use a subscription model and the market as a whole is estimated to be worth £26 billion a year (with an estimated £1.6 billion a year spent on unwanted subscriptions). The UK Government decided to regulate because of concerns that consumers often forget what they've signed up for and don't realise when contracts have renewed, potentially locking them into purchasing goods or services they aren't always using for a significant period. The new regime is intended to ensure that consumers:

Are given clearer information when they first sign up;
Benefit from a cooling-off period (allowing them to withdraw if they change their minds); and
Get periodic reminders before subscriptions are due to renew.

As we explain in our detailed briefing, the new rules are quite prescriptive and are not entirely straightforward to apply. We also explain what's covered – and what's out of scope.

Start preparing now

The regime will require most businesses to make significant changes to their existing consumer journey for subscription contracts - and some of those changes (e.g. to CRM systems) may have quite long lead times attached to them. Our advice is to start thinking about the impact of the changes now – particularly in light of the significant compliance risks (see below). Although the Government has said that it plans to issue guidance on the new rules and also needs to pass secondary legislation, it's not clear when this will be finalised. Given that time is already short, we would advise against delaying until both the guidance and secondary legislation have been published. The legislation and the Government's response to consultation provide a reasonable level of detail on how to comply, albeit that uncertainty remains in some areas.

What do you need to consider?

Key questions to ask yourself include:

Sign-up process: What changes do we need to make to reflect the new pre-contract information requirements? How do we strike the right balance between compliance and keeping the process as simple and straightforward as possible?
Cancellations: Given consumers' enhanced rights, do we need to look again at our approach to cancellations? Could we be accused of making it "disproportionately difficult" to cancel?
CRM systems: How much of an uplift is required to ensure that our CRM systems can handle the pre-contract information, reminder notices and other requirements of the new regime?
"Binge and cancel" risk: Are we at risk of being left out of pocket by consumers who make use of their new rights to use a subscription and then cancel and claim a refund? Do we need to look at restructuring some aspects of our subscriptions to mitigate this risk?
Competitive opportunity: How might our competitors respond to the changes? Can we "make a virtue of compliance" and turn it into an opportunity to attract more consumers to our offering?
Outsourcing: If aspects of our subscription contract offering are outsourced, to what extent are these contracts impacted by the new regime? In particular, do these arrangements need amending to ensure that suppliers acting on our behalf comply with the new rules?

For more information, see our detailed guide to the new regime, which has been updated to reflect the Government's April 2026 consultation response.

Don't underestimate the compliance risks

The compliance risks are significant and could involve a substantial financial "hit" to the business, as well as reputational damage. They include the following:

CMA enforcement: The CMA now has tough new enforcement powers under the Digital Markets, Competition and Consumers Act 2024 - including the ability to impose fines of up to 10% of turnover and to issue "redress orders" requiring businesses to compensate affected consumers. Whilst the CMA may allow businesses a short grace period in which to sort out any teething problems with compliance, we expect that after that, it will be actively looking for enforcement targets. It has recently fined the AA's driving school business £4.2 million and ordered it to repay £800,000 to consumers in unlawful booking fees. This shows that the CMA is not afraid to use its new powers. Meanwhile, it is already showing an interest in subscription contracts, having recently launched an investigation into whether Microsoft may have misled consumers over subscription plans for Windows 365 software.
Consumers exercising their new rights: If a business fails to notify consumers about their 14-day cooling-off rights under the new regime, consumers can cancel at any time for the next 12 months. It is not difficult to imagine an internet campaign pointing out that a business has not complied fully with the pre-contract information requirements and encouraging consumers who want to get out of their contracts to do just that. This could result in a business losing a significant portion of its expected revenue stream for the next 6-18 months — and highlights the importance of ensuring that the various notices required under the legislation are provided to consumers in the correct form.

How we can help

The new subscription contracts regime – though well intentioned – is not particularly straightforward. At Travers Smith, we understand the importance of achieving compliance in a way which fits with how you want to engage with consumers and minimises disruption to your business. We won't lose sight of the bigger picture and can guide you through how the subscription contracts regime interacts with other relevant legislation, such as the distance selling rules and the law governing unfair terms and unfair practices.

More widely, our team has extensive experience in advising on consumer law matters (including CMA investigations). We recognise the need to adopt a pragmatic approach, focussing on the highest areas of risk whilst ensuring that you are still able to achieve your commercial objectives.

To find out more, please speak to any of the contacts listed below.

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