DMCCA subscriptions regime: Are you ready for 1 January?

After a very long wait, and with the implementation deadline of 1 January fast approaching, the government has finally provided the final piece of the puzzle for the DMCCA subscriptions regime. On 19 October, the government laid the draft secondary legislation (The Consumer Subscription Contracts (Cancellation and Information) Regulations 2026) before parliament, and published the accompanying guidance, filling in the gaps in the DMCCA provisions.

What are the DMCCA subscription rules?

The new UK consumer subscription rules require traders to give clearer information before sign-up and make cancellation easier, addressing concerns about so-called “subscription traps”.

The framework for the new subscriptions regime was introduced under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), within Chapter 2 of Part 4. This identifies the key requirements that traders must satisfy when operating consumer subscriptions.

The operational detail to enable businesses to fully implement the new regime is provided in the Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, laid before parliament on the 19 October, and the recently published accompanying guidance.

When do the new rules apply, and will there be a grace period?

The new regime will apply to all consumer subscriptions entered into on or after 1 January 2027.

Until recently (following a number of delays) the subscription rules had been expected to come into force in Spring 2027. However, within 3 weeks of becoming Prime Minister, on 9 August 2026, Andy Burnham announced that these would be brought forward to apply from 1 January 2027.

With the much-needed detail adding flesh to the bones of the DMCCA requirements only being published in October 2026, this has left little time for businesses to ensure compliance by the 1 January deadline.

Despite intense lobbying from industry bodies, the government has refused to provide a statutory grace period to allow time for businesses to implement the new rules following publication of the final guidance and secondary legislation. The government concluded that a statutory grace period would have undermined the Prime Minister's strong message that he would put an end to subscription traps from January.

However, the CMA has provided a degree of comfort for businesses. In a blog post published on 14 October 2026, Emma Cochrane (Executive Director of Consumer Protection at the CMA) confirmed that the CMA's focus in the early months of the regime will be on helping businesses to comply. This does not mean a total hiatus on enforcement, and egregious breaches of rules which are already well understood are at risk of enforcement action from day one. However, the CMA's promise to apply a proportionate approach to enforcement should offer reassurance to businesses making clear efforts to comply.

What do I need to do to comply?

We have prepared a user-friendly Subscriptions Guide which provides a summary of the requirements under the new subscriptions regime to help you understand the key rules. It is designed to help you identify where your business may need to implement changes to current subscription contracts, user interfaces and processes.

Click here to request a copy.

We will also be hosting a webinar on 10 November that unpicks everything you need to know about the new regime. Visit our webinar page to sign up and learn more.

How can TLT help?

TLT's consumer law experts have market-leading expertise on subscription contract rules and all aspects of the DMCCA. We can help you map out the full UX and customer journey to identify and remediate any compliance risk.

As the BIST Guidance is sector agnostic and ambiguous in places, there will still be difficult judgment calls for many businesses. We specialise in helping clients identify clear, practical commercial solutions to the most difficult and complex compliance challenges. Get in touch with the team to find out about our DMCCA Subscriptions Healthcheck.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at October 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.