Cancel culture: the small print arrives for the UK’s subscription rules

Finally, we have (some) detail. On 19 October 2026, the UK government laid the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 (SCRs) before Parliament, along with 77 dense pages of draft guidance for some light bedtime reading. If approved, the SCRs will apply to subscription contracts entered into from 1 January 2027.
 
We’ve focused below on what’s new, what will feel familiar, what’s still unclear, and what’s realistic before New Year’s Day 2027.

Recap: what we already knew

The Digital Markets, Competition and Consumers Act 2024 requires key and full pre-contract information, reminders before certain renewals, an easy exit (online, for online sign-ups), and new cooling-off rights, replacing the equivalent rules in the Consumer Contracts Regulations 2013 (CCRs). It covers consumer subscriptions for goods, services, and digital content, whether sold online, by phone, or in person, with exclusions for sectors such as financial services, telecoms, utilities, and gambling. The UK government’s April 2026 consultation response confirmed that a waiver of the initial cooling-off right would remain for digital content, but not for renewal cooling-off periods.
 
Customers get 14 days to cancel at sign-up and, from January, another 14 days when a free or discounted trial converts to full price or a contract renews for 12 months or more. Rolling monthly contracts need a reminder every six months, and annual renewals need two reminders beforehand and a cooling-off notice afterwards. Three things are easily confused:

• Reminder notice. Comes before a payment falls due and explains what the customer will pay and how to cancel.
• Cooling-off notice. Comes after a free or discounted trial converts, or an annual plan renews, and explains that the customer has 14 days to cancel.
• Turning off auto-renewal. Possible at any time. Access continues until the paid period ends, whereas cancelling ends the contract straight away.

The new rules only apply to contracts entered into on or after 1 January 2027, so existing subscribers are unaffected. The guidance does, however, describe extending the same protections to existing customers as “best practice”. Since running two sets of journeys side by side is rarely appealing, many businesses may choose to switch everyone over at once.

A regulator that is paying attention

According to a recent blog post, the Competition and Markets Authority (CMA) will initially focus on helping businesses comply and will take genuine efforts into account, but enforcement won’t be delayed (a grace period in spirit, then, not in law). The CMA has opened 20 consumer protection investigations since April 2025 and imposed more than £12 million in fines, and penalties can reach 10% of global turnover or £300,000, whichever is higher. Customers’ refund rights don’t depend on the CMA, though. They come straight from the legislation and apply to contracts made from 1 January, whatever the CMA’s priorities, so complaints and refund requests are likely to be the first sign of trouble.

New in the October package: what the draft SCRs and guidance add

The October package mostly fills in detail. The 14-day cooling-off period, pre-contract information, confirmation on a durable medium, express consent before early supply, proportionate charges for services already used, and refunds to the original payment method all carry over from the CCRs. What’s new is how these rules apply to subscription contracts and what happens when things go wrong.

• Refunds for breaches. For listed failures, such as missing key pre-contract information, an incomplete reminder, or an unreasonable reminder period, a customer who cancels gets back every payment since the “relevant date” (broadly, the renewal payment linked to the failure), without having to show that the failure caused them to pay. They have 12 months from that date to cancel, and the refund is due within 14 days from the day after cancellation, not once you’ve finished investigating, as previously stipulated in the consultation. The only real brake is unreasonable delay: if a customer knowingly sits on their rights, the refund period can be reduced. This is much more than a technical cancellation right. Across a large subscriber base, a single defective reminder template can create significant refund exposure.
• Introductory offers. If one fixed discounted price applies across several payments, the first reminder is now due before the first payment at the higher price. Stepped discounts still need a reminder before the first renewal payment.
• Timing of renewal payments. Renewal payments can’t fall due before the contract actually renews, and contract terms allowing earlier collection have no effect. Check whether your billing takes renewal payments in advance.
• No waiver for bundles. The initial waiver covers content-only contracts, so in a mixed contract the content element is refundable in full if the customer cancels during the initial cooling-off period. On renewal, the usual proportionate rules apply.
• Add-ons fall away too. Cancelling in the initial cooling-off period automatically cancels any ancillary contract, such as a partner subscription, and any third-party supplier needs to be told. This doesn’t apply on renewal or breach.
• How notices are sent. Reminder, cooling-off, and end-of-contract notices must be in a durable medium, so vanishing push notifications won’t count. Reminders may carry marketing if the required information stands out more, subject to direct marketing rules. Cooling-off notices can’t contain marketing and must be sent separately from reminders. End-of-contract notices are due within 24 hours of an online cancellation, or three working days otherwise.
• Ways to cancel. An email address alone isn’t enough for online exit, but a clearly labelled button, web form, or even a chatbot can work, as there is no single prescribed form provided the route is straightforward. Ideally, customers should not have to contact you more than once.

So, what does this look like in practice?

Compliance doesn’t have to mean rebuilding everything, but with holiday code freezes fast approaching, there isn’t long left to get the engineering sorted.

• Sign-up. Key pre-contract information must be grouped and clearly visible. It can share a screen with the purchase button but not sit behind a link, so test mobile, console, and TV journeys before assuming you need a new UK screen. Third-party store purchase screens leave little room for your own wording, so key information may need to appear on your own screens before the hand-off. Full pre-contract information is more forgiving: it can sit behind a clearly labelled link, or even within your terms and conditions, provided it is presented together rather than scattered across different clauses. If it wasn’t sent on a durable medium before sign-up, it must be provided by email or similar before supply begins.
• Initial waiver. The rules are largely as we know them under the CCRs, except that the draft SCRs confine the waiver to content-only contracts. If the waiver isn’t obtained correctly, customers can watch or play for 14 days and still get their money back. That risk isn’t new, but with refund rights expanding and the CMA able to fine directly for unfair practices, the low-friction consent flows common across the industry deserve a second look. The trade-off is friction at sign-up versus refund exposure.
• Free trials. Each one now needs a reminder before it converts, a cooling-off notice afterwards, and a refund process for the following 14 days. If your cooling-off notice is late or missing, the window stays open until 14 days after it’s sent, for up to 12 months.
• Renewals. Record turning off auto-renewal and cooling-off cancellation as different events. One “cancel subscription” button in the back end can’t cover both.
• Renewal refunds. The renewal cooling-off right can’t be waived. You can keep a proportionate amount only if you sent a compliant cooling-off notice. Otherwise, the customer gets a full refund. The guidance works through both time-based and unit-based examples: cancelling on day four of a renewed £365 annual plan costs £4, while a customer who has downloaded two of 10 monthly films pays £10 of a £50 fee. Many refund systems can’t calculate individual amounts based on the exact time elapsed in the 14-day window, though, and it may be cheaper and less painful just to offer full refunds.
• Cancellation flows. Retention offers, such as pauses, downgrades, or discounts, are allowed if they don’t prolong the exit or put the customer off completing it, so a run of “are you sure?” screens may cause some trouble. Feedback can be invited during the exit or requested afterwards, but compulsory surveys are unlikely to comply.
• Refund rights. In practice, refund exposure comes from a handful of mistakes. These are the listed failures above, a late or defective cooling-off notice (which turns a proportionate refund into a full one), and a digital content waiver that wasn’t properly obtained. A cancellation process that isn’t straightforward also lets customers cancel, but they must show that it cost them a payment. These rights can overlap, and where a customer could cancel on more than one basis, they get the better outcome unless they choose otherwise. Refunds aren’t automatic, as the customer must cancel, but the burden of proof sits with you. Keep records of what each customer saw, and which notices went out, when, and how.
• Small errors, big refunds. One of the biggest pain points here is the annual renewal reminder email. Get it wrong and a customer who cancels could potentially recover the whole annual fee, however many box sets they’ve watched. Across a large customer base that adds up quickly. In theory, one faulty reminder template sent to 50,000 annual subscribers paying £100 could put £5 million at risk.

What we still don’t know

The draft fills in a lot, but some questions remain open. How should a bundle price be split? Are cloud gaming, online multiplayer, or cloud storage content or services? How should virtual currency or credits be valued on cancellation? What is a “reasonable” reminder period, and how far can retention offers go? None has a single right answer, but each needs a defensible, documented position before launch.
 
Final guidance may land uncomfortably close to go-live, so the most sensible approach is to build against the draft now and revisit your positions when the final text arrives. Cancel culture, in other words, is coming to subscriptions, and from 1 January, businesses that make leaving easy may well find that customers are more willing to stay.

Client Alert 2026-203