The Digital Markets, Competition and Consumers Act 2024, usually shortened to the DMCC Act, is the biggest overhaul of UK consumer law in a decade. Most of it is already in force, but the part that matters for subscription brands, a new set of rules aimed at ending so-called subscription traps, has been delayed twice and is now due in Spring 2027. If you run a subscription business on Shopify, this guide covers what the rules say, why the delay isn't a reason to relax, and what to sort in your Recharge or Skio setup now.
What is the DMCC Act?
The DMCC Act passed in 2024 and does three big things. It gives the Competition and Markets Authority (CMA) new powers over large tech platforms, it strengthens general consumer protection law, and it creates a standalone regime for consumer subscription contracts.
The teeth are real. The CMA can now enforce consumer law directly and issue fines of up to 10% of a business's global turnover, without going through the courts first. That's a very different enforcement landscape to the one subscription brands grew up in.
The government's motivation is straightforward. There are roughly 155 million active subscriptions in the UK, worth around £26 billion a year, and an estimated £1.6 billion of that is spent on subscriptions people don't actually want. The new rules are designed to end the patterns that create that number: unclear sign-ups, forgotten renewals and cancellation journeys built to wear people down.
When do the DMCC subscription rules come into force?
Spring 2027, based on the government's consultation response published in April 2026. That's the second delay. The rules were originally due in Spring 2026, then Autumn 2026.
It's tempting to read two delays as a signal the whole thing might quietly go away. It won't. The direction of travel, clear information at sign-up, real cooling-off rights, renewal reminders and easy cancellation, has been consistent through every consultation. The details are still being finalised in secondary legislation, but the shape of the regime is settled.
What the subscription rules require
Clear information before sign-up
Customers must be given key information before they subscribe: the price, how often they'll be charged, when a trial converts to a paid plan, and how to cancel. If your subscription widget buries the renewal price or the billing frequency, that's the first thing to fix.
Two cooling-off periods, not one
Alongside the familiar 14-day cooling-off period when someone first subscribes, the Act adds a renewal cooling-off right. Customers get 14 days to cancel after a free or discounted trial converts to full price, and after a contract of 12 months or more auto-renews. If they cancel in that window, they're entitled to a full or proportionate refund.
The government has confirmed this renewal cooling-off right can't be waived, even though it acknowledged the risk of customers bingeing on a product and then cancelling for a refund. Brands will need refund processes that handle this cleanly.
Reminder notices before renewals
Brands will have to send reminders before a trial converts and before longer contracts auto-renew, so customers get a genuine chance to opt out before money leaves their account. The format and timing will be set out in secondary legislation, but the principle is fixed: no more silent renewals.
Cancellation that's actually easy
The government will legislate against terms that make it disproportionately difficult to exit an auto-renewing contract, narrow cancellation windows being the obvious example. It has also confirmed that customers can't be made liable for a renewal payment before the contract actually renews.
In practice, if your cancellation journey involves more steps, more friction or more persuasion screens than your sign-up journey, assume it's in scope.
Who's covered
The rules cover subscription contracts between a trader and a UK consumer, whether the trader is based in the UK or not. There's a list of exclusions, including insurance, financial services and certain charitable, cultural and heritage memberships, but a standard DTC subscription for food, drink, beauty or wellness products sits squarely in scope.
What Shopify subscription brands should do now
Here's the honest take: if the DMCC subscription rules worry you, the problem isn't the legislation, it's that your retention is propped up by friction. Everything the Act bans is something good subscription brands stopped doing years ago, because retention built on people forgetting to cancel isn't retention. We wrote about this distinction in real growth vs fake growth.
Audit your cancel flow
Walk through your own cancellation journey as a customer would. Count the steps, the retention offers and the dead ends. A good cancel flow can still save customers, with a pause option, a swap, a discount offered once, but it has to end in a working cancel button. There's a full breakdown of how to build one in our subscription retention strategy guide.
Build renewal reminders into your flows
Upcoming-charge notifications shouldn't wait for legislation. Both Recharge and Skio support upcoming order notifications, and a well-built reminder email doubles as a retention touchpoint: it's the natural place for swap, add-on and delay options. We cover how to structure these in Klaviyo flows for subscription brands.
Check your trial and discount mechanics
Free and discounted trials that convert to full price are the highest-risk pattern under the new regime, because they trigger the renewal cooling-off right and the reminder requirements. Map exactly what a customer sees at sign-up, what they're told before conversion, and what happens if they cancel just after. If any of those answers are fuzzy, that's your gap.
Make sure your platform can keep up
The operational load of the new rules, reminders, cooling-off refunds, proportionate refund calculations, will land on your subscription platform. It's worth factoring into any platform decision you're weighing up now. Our Recharge vs Skio comparison covers how the two handle notifications and customer portals, and the wider setup questions are in the ultimate guide to Shopify subscriptions.
Why acting early is the cheap option
Spring 2027 sounds distant, but the work isn't small. Reminder flows need building and testing, cancel journeys need redesigning, refund processes need agreeing with finance, and the legal wording at sign-up needs reviewing. Brands that leave it until secondary legislation lands will be doing all of that in a rush, alongside everyone else.
There's also a commercial upside to going early. Transparent renewals and easy cancellation are trust signals, and trust converts. The brands we work with that run honest, low-friction subscription mechanics consistently see better long-term retention than those that rely on inertia. Compliance and good retention practice point in exactly the same direction here.
DMCC Act subscription FAQs
What is the DMCC Act?
The Digital Markets, Competition and Consumers Act 2024 is UK legislation that regulates large tech platforms, strengthens consumer protection law and creates a new regime for consumer subscription contracts. It gives the Competition and Markets Authority direct enforcement powers, including fines of up to 10% of a business's global turnover for consumer law breaches.
When do the DMCC subscription rules start?
The subscription contracts regime is expected to apply from Spring 2027, following the government's consultation response published in April 2026. This is the second delay, after original targets of Spring 2026 and then Autumn 2026. The core requirements are settled, with the detail to be confirmed in secondary legislation and guidance.
Which subscriptions do the DMCC rules cover?
The rules cover subscription contracts between a trader and a UK consumer for goods, services or digital content, including auto-renewing contracts and free or discounted trials that convert to paid plans. Traders outside the UK are covered if they sell to UK consumers. Insurance, financial services and certain charitable memberships are excluded.
What cooling-off rights does the DMCC Act add?
Alongside the initial 14-day cooling-off period, the Act adds a renewal cooling-off right: customers get 14 days to cancel after a trial converts to full price, or after a contract of 12 months or more auto-renews, with a full or proportionate refund. The government has confirmed this renewal right cannot be waived.
What should subscription brands do before the rules apply?
Audit the cancellation journey and remove disproportionate friction, build renewal and trial-conversion reminder emails, review what customers are told at sign-up about price and billing frequency, and agree a refund process for cooling-off cancellations. These changes take time to build and test, so starting well before Spring 2027 avoids a compliance rush.
The DMCC Act's subscription rules arrive in Spring 2027, but the brands that treat them as a retention upgrade rather than a compliance chore will get the benefit early. If you want help auditing your Recharge or Skio setup, cancel flows or reminder emails against what's coming, talk to us.