New Subscription Rules: Are You Ready For January 2027?

For businesses that sell subscriptions to consumers, the fact that the Digital Markets, Competition and Consumers Act 2024 (DMCCA) introduces a new subscription regime is unlikely to be surprising news. However, until recently the government had stated it was working to a spring 2027 timeframe, with a view to draft secondary legislation and further guidance being published in the lead-up to this to help businesses further understand the obligations required of them; particularly given the inevitable grey areas and questions that arise under the existing limited framework of the DMCCA.

However, the level of urgency was ramped up a degree recently following the new government’s announcement that, as part of Andy Burnham’s series of “everyday fixes” to help address some of the current cost of living issues faced by the British public, this new regime would be brought forward to January 2027. This therefore requires businesses to get their houses in order several months earlier than