GB
The Digital Markets, Competition and Consumers Act 2024 (the DMCCA) brings major UK consumer law changes for businesses selling to consumers. It became law in May 2024 and introduces some of the biggest changes to consumer and competition rules in over twenty years.
The practical takeaway? Check your pricing, reviews and marketing now, and prepare your consumer subscription contracts for the next stage of the rules.
This guide explains what already applies, what’s coming in 2027 and what founders and leadership teams should review as they scale.
For a growing business, these changes reach into the everyday. They affect how you earn recurring revenue from subscriptions, win and keep customers through free trials and automatic renewals, and design your product and sign-up journey. They also affect what investors are likely to ask about in due diligence.
With the regulator now able to fine businesses the higher of £300,000 or 10% of global annual turnover, getting this wrong could be expensive.
Four things matter most if you run a consumer-facing business:
The updated consumer protection rules went live on 6th April 2025. If you sell directly to consumers, particularly online, start here. The CMA can already enforce these rules.
It’s now clearly unlawful to write, commission or publish fake reviews, or to publish reviews without disclosing that they were incentivised. You’re expected to take reasonable and proportionate steps to check that reviews on your site are genuine.
If you host user reviews, display testimonials or work with affiliates and influencers, it’s worth taking a closer look at your process.
You know the experience. A price looks attractive, then unavoidable fees appear as you work your way through checkout.
The rules push businesses to show the total unavoidable cost up front. Take a look at your pricing displays, checkout journey and any “from” pricing in ads and on landing pages.
The wider bans on misleading and aggressive practices carry over and have been refreshed. It’s a good time to sense-check your marketing claims, urgency messaging and any default opt-ins.
This is where the stakes get higher. The CMA can now decide that a business has breached consumer law and impose a penalty itself, rather than taking the business to court. That penalty can be the higher of £300,000 or 10% of global annual turnover.
It can’t use these powers for conduct before April 2025, but conduct from that date onwards is in scope.
And it has already started using them. In November 2025, the CMA opened its first cases under the new regime against eight businesses over their online pricing practices, and wrote to around 100 others asking them to check their compliance.
What to do now: review how you handle reviews, display prices and make key consumer-facing claims against the new rules. Keep a record of those checks too. Good record keeping helps show that you took reasonable steps.
These parts came into force in January 2025. For most businesses, the key point is the new merger control threshold, which started on 1st January 2025. It widens the range of deals the CMA can review, including acquisitions of small but promising rivals.
If you’re buying businesses, raising investment or planning a sale, check early whether your transaction could be caught.
There’s also a regime for the largest digital firms, known as the Strategic Market Status (SMS) regime. In October 2025, the CMA designated Google with SMS in search, and Apple and Google with SMS in mobile platforms.
Unless you’re a very large platform, this is unlikely to apply to you directly. But it does shape the markets many businesses operate in.
If any of your revenue comes from subscriptions or auto-renewing plans, this is the part to plan for.
The DMCCA created a new regime for consumer subscription contracts to tackle “subscription traps”. It left the practical detail to secondary legislation, which is why these rules didn’t take effect when the Act became law.
On 19th October 2026, the government laid the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 before Parliament, with draft guidance published alongside them by the Department for Business and Trade.
The draft regulations set a start date of 1st January 2027 and apply only to subscriptions entered into on or after that date.
But the draft guidance says it’s best practice to give consumers consistent protections, regardless of when they signed up. So it’s worth considering whether to extend the new protections to existing subscribers, even though you’re not required to.
The rules apply to subscription contracts between a business and a consumer for goods, services or digital content in exchange for payment. There are two useful carve-outs. Genuinely free services aren’t caught, and neither are services paid for only with data rather than money.
The rules only protect consumers, meaning individuals acting wholly or mainly outside their trade or business. If you only sell to other businesses (B2B), such as a SaaS platform sold to companies under a business contract, the new regime is unlikely to apply.
If you sell to both businesses and individuals, perhaps through a self-serve plan that anyone can buy with a personal card, the consumer side of your business is likely to be caught.
To be in scope, the subscription generally needs to either:
There’s also a list of excluded contracts. Here are the ones most relevant to our clients.
Financial services and insurance
Banking, credit, insurance, personal pension, investment and payment services contracts are excluded. But don’t assume every fintech subscription falls outside the rules. A paid budgeting or analytics tool that isn’t itself a financial service may still be caught.
Healthcare
Being a healthcare business doesn’t automatically take you outside the rules. The exclusions cover health-related supplies made under or in connection with a prescription, medicines given by a prescriber, and supplies by healthcare professionals as part of NHS arrangements.
The draft regulations also confirm that optical appliances, such as glasses and contact lenses, aren’t covered by this exclusion. A paid wellness app or digital health membership is therefore likely to be in scope.
Other exclusions
Other exclusions include energy and water supply, residential rent, package holidays, timeshares, childcare and gambling. The draft regulations also add narrow exclusions for certain memberships of charitable, cultural and heritage organisations.
The reach is broad. The draft guidance confirms that a UK-based business may be caught even if its customers are overseas, depending on how closely the contract is connected with the UK.
A business based abroad will be caught if it offers subscriptions to UK consumers. So an overseas parent selling into the UK shouldn’t assume it’s outside the rules.
If your business is in scope, you’ll have obligations across the whole customer journey, including:
In practice, the DMCCA subscription rules are likely to mean changes to your sign-up flow, account and cancellation settings, reminder emails, and subscription terms and conditions.
Cancellation deserves particular attention. Many current journeys will need work, because the rules require leaving to be as easy as joining.
For cooling-off rights, the government chose what the consultation called “Option 2”. Here’s what that means:
This gives businesses slightly less flexibility than some had hoped for. But it broadly aligns the new regime with rules already in place, which should make implementation a little easier.
One proposed requirement has been dropped. The draft regulations confirm that key information in reminder notices and end-of-contract notices doesn’t have to be the very first thing a consumer sees. It does, however, need to be more prominent than anything else in the communication.
That gives you more flexibility over the layout than the original proposals suggested, which is useful to know when redesigning those messages.
Here’s what businesses in three of our key sectors should be reviewing now.
Offering a free trial that rolls into a paid plan, or a plan that renews automatically? Check that prices and renewal terms are clear before sign-up, reminders go out before a trial ends or a plan renews, and customers can cancel online as easily as they signed up.
Paid memberships, coaching programmes and app subscriptions are likely to be caught unless the service is prescription-related or provided as part of NHS arrangements.
Review your membership terms, renewal notices and cancellation process. Being a healthcare business alone doesn’t take you outside the rules.
If you use testimonials, AI-generated marketing content, dynamic pricing or automated customer journeys, there are a few things to check.
Reviews and testimonials need to be genuine and properly labelled. AI-generated content shouldn’t make claims you can’t back up. The full price needs to be clear up front, even when prices change. And automated flows, such as chatbots or cancellation steps, shouldn’t pressure customers or stand in their way.
The regulations laid on 19th October 2026 are still in draft and need approval from both Houses of Parliament, so the timing or detail could change.
The accompanying guidance is also in draft and doesn’t have legal force. The government will publish final guidance once the regulations are made.
For now, treat 1st January 2027 as the working date and plan around it, with a review point when the final regulations and guidance arrive.
Here’s a sensible order to work through:
The new subscription regime protects consumers. If you only sell to companies under business contracts, it is unlikely to apply. If you also offer consumer subscriptions, that part of your business is likely to be caught.
Financial services and insurance contracts are excluded, but a fintech tool that is not itself a financial service may still be caught. Healthcare exclusions are specific, so a wellness app or digital health membership is likely to be in scope.
The draft regulations set a start date of 1st January 2027 for subscriptions entered into on or after that date. Parliamentary approval is still needed, so businesses should plan around that date and review the final regulations and guidance when published.
If you’re scaling a consumer-facing business, our team can help you work through what the DMCCA means for your subscriptions, pricing and customer journeys, whether your customers are in the UK or, in some cases, overseas.
From reviewing subscription terms and conditions to practical consumer law advice for your business, we can help you assess whether the rules apply and what needs to change ahead of 1st January 2027. Get in touch and we’ll help you work through it.
