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The DMCC Act and Auto-Renewals: What UK Businesses Should Know

Kyriaki Chaldaiou

Kyriaki Chaldaiou

Head of Procurement Strategy

17 July 20265 min read

Please note: This article is general information, not legal advice, and reflects the position as at July 2026. The subscription rules described below are not yet in force and their timing has already moved more than once. For advice on your specific situation, please consult a qualified solicitor.

The UK is tightening the rules around auto-renewing subscriptions. The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) introduces a new subscription-contracts regime aimed at ending "subscription traps" — the recurring payments people forget they signed up to. The government estimates UK consumers spend around £1.6 billion a year on subscriptions they don't want.

If you run a business, this matters in two different ways depending on which side of a subscription you're on. This guide covers both — starting with the one most businesses overlook: the contracts you are paying for.


First, the timing (because it keeps changing)

It's worth being clear up front: these rules are not in force yet. The DMCC Act itself is law, but the subscription-contracts regime is being implemented through separate secondary legislation, and the start date has slipped more than once — first expected in spring 2026, then autumn 2026, and following the government's consultation response of 2 April 2026, now expected to apply from around early 2027.

So this is a deadline on the horizon, not one that has landed. Which means businesses have time to prepare — the point of preparing early is that these obligations tend to need process and system changes, not last-minute fixes.


If you buy subscriptions and supplier contracts

Most businesses are, first and foremost, buyers of subscriptions — software, services, memberships, retainers, maintenance contracts. The DMCC regime is designed to protect consumers, so it won't hand your business new statutory rights over your suppliers. But it makes a point worth acting on regardless of the law: auto-renewal is a recognised, expensive problem, and the discipline the law is about to force on sellers is exactly the discipline smart buyers already apply to themselves.

The law is essentially codifying good practice: know when something renews, get a reminder before it does, and be able to get out easily. You don't need to wait for legislation to give yourself those protections on your own contracts. In practice that means:

The businesses that don't fall into subscription traps aren't waiting for regulation to save them — they simply have visibility of what renews and when.


If you sell subscriptions

If your business offers subscriptions or memberships — SaaS, service retainers, subscription boxes, recurring plans — then the DMCC regime is a compliance deadline heading your way. When the subscription rules come into force (expected around early 2027, subject to change), businesses selling to consumers are expected to have to:

  • Provide clear pre-contract information so customers understand the price and renewal terms before they commit.
  • Send reminder notices before an auto-renewal, so customers aren't renewed unawares.
  • Offer straightforward cancellation — subscriptions should be "as easy to exit as to join."
  • Provide cooling-off rights, including a 14-day window after certain renewals (such as after a free trial or the start of a 12-month-plus term).

Enforcement has teeth: since April 2025 the Competition and Markets Authority (CMA) has been able to decide a business has broken consumer law and impose fines directly — up to 10% of global annual turnover — without first going to court. Note too that the regime has a list of excluded contracts (Schedule 22 of the Act covers things like regulated utilities and financial services), so not every subscription is caught. Whether your particular arrangements fall in scope is exactly the kind of question to check with a solicitor.

The practical takeaway: if you sell subscriptions, part of getting ready is knowing every customer's renewal date well enough to send a timely, compliant reminder. That's a contract-and-date visibility problem as much as a legal one.


What to do now

Whichever side you're on, the preparation overlaps:

  1. Get every contract and its renewal date into one place. You can't manage — or comply — around dates you can't see.
  2. Identify the auto-renewals, and the notice deadline attached to each.
  3. Set reminders that fire in good time, not on the renewal date itself.
  4. If you sell subscriptions, review your pre-contract information and cancellation process against the forthcoming requirements, and take advice on whether you're in scope.

None of this is urgent in the "act this week" sense — the rules aren't live. But it's the kind of visibility that's useful long before any deadline, and awkward to retrofit under time pressure.


FAQ

When do the DMCC subscription rules come into force? As at July 2026, they are expected to apply from around early 2027. The date has already been pushed back more than once, and depends on secondary legislation, so treat any specific date as provisional and check the current position.

Does the DMCC Act protect my business when I buy from suppliers? The subscription regime is primarily consumer-protection law, so it doesn't give your business new statutory rights over your suppliers. But it reflects good practice any buyer can adopt: track renewal dates and notice periods so nothing renews without a decision.

What happens if a business doesn't comply? Once in force, the CMA can enforce the rules directly, with fines of up to 10% of global annual turnover. Enforcement powers already strengthened in 2025.

Are all subscriptions covered? No — the Act excludes certain contracts (Schedule 22), such as regulated utilities and financial services. Whether a specific arrangement is in scope is a question for legal advice.


Timemy keeps every contract, renewal date and notice period in one place and alerts you before each deadline — useful whether you're avoiding subscription traps or getting ready to send compliant renewal reminders. Try it free or read how to avoid missing a contract renewal.

Disclaimer: The above is provided for general information only, reflects our understanding of the position as at July 2026, and does not constitute legal advice. Legislation and timing are subject to change. You should obtain advice from a qualified legal professional before making decisions based on the DMCC Act or its subscription-contracts regime.

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