Consumer software and media, United Kingdom benchmark

Key takeaways

12 of 24 sign-up flows: annual or higher-priced plan selected before the customer chooses. No additional payment without the customer's express consent; a plan selected in advance is not the customer's choice.
4 of 26 sign-up flows: offer condition only in a footnote or on the next page. A condition that changes the price belongs where the price is shown, not one level deeper.
7 of 9 findings stay on the existing screen; 2 need a new screen or route.

What we saw across 30 sign-up flows walked

Each finding with the screen it sits on, the rule it touches and how big a change usually is (S label or text, M layout or order, L new screen or route). Walked against the full Flowlane checklist for the United Kingdom (16 checks); shown here: every finding that came up in more than one flow. Each number counts only the flows in which that step could be checked.

Every rule chip opens its card on the rules page.

What we saw	Flows	Rule (market rules)subscription regime expected January 2027	Change
Annual or higher-priced plan selected before the customer choosesWhere it sits: Plan page, basket	12 of 24	B · CCR reg 40 No additional payment without the customer's express consent; a plan selected in advance is not the customer's choice.	SSmall
Offer condition only in a footnote or on the next pageWhere it sits: Plan page footnote, plan detail	4 of 26	B · DMCC s 230 A condition that changes the price belongs where the price is shown, not one level deeper.	MMedium
Account or email required before any plan price is shownWhere it sits: Registration step	4 of 30	C · DMCC ss 226-228 An account required before the customer can see what the plan costs is an obstacle worth a look.	LLarge
Refusing cookies takes more effort than accepting themWhere it sits: Cookie banner on the first page	9 of 19	D · PECR reg 6 Refusing non-essential cookies is as easy as accepting them, on the same layer; advertising cookies wait for a clear yes.	MMedium
Also seen in two or three flows
How to cancel missing where the plan is confirmedWhere it sits: Checkout summary	2 of 6	A · DMCC ss 256-257 Term, renewal and how to end it belong where the customer commits, not only in the terms.	SSmall
Trial or intro price rolls on with no reminder announcedWhere it sits: Plan page, checkout	2 of 14	A · DMCC ss 258-259 A reminder is due before a free or discounted period ends and before a renewal.	SSmall
Cancelling only by phone, though joining is onlineWhere it sits: Help pages, FAQ	2 of 21	A · DMCC s 260 Ending the contract has to be straightforward; a contract taken out online can be ended online.	LLarge
First-year discount shown without the price that followsWhere it sits: Basket, order summary	2 of 26	A · DMCC ss 256-257 The price after the introductory period belongs next to the introductory price, where the customer commits.	MMedium
Marketing consent bundled into sign-up or ticked in advanceWhere it sits: Account or checkout step	3 of 16	D · PECR reg 22 A pre-ticked box is not consent to marketing; where the existing-customer route is used, a clear opt-out belongs here.	SSmall

Three examples

Written as categories, no company identifiable.

Choosing

In one sign-up flow, the higher tier was selected on arrival, at more than twice the monthly price of the smaller plan offered next to it.

Joining

In one sign-up flow, a short questionnaire led straight to an account form; no plan and no price appeared before a name and email were asked for.

Leaving

In one sign-up flow, joining took a few screens online, but the help page said cancelling needs a phone call to customer care.

What the rules ask

The pricing and unfair-practice rules have applied since 6 April 2025. The subscription regime is expected to apply from January 2027; the date is not yet fixed. Shown here: the rules this report touches.

Subscriptions

A · DMCC ss 256-257 A · DMCC ss 258-259 A · DMCC s 260Expected January 2027

Pre-contract information before the customer commits, reminders before a trial or introductory period ends and before renewals, and an exit that is as easy as the sign-up.

Fees and total price

B · DMCC s 230 B · CCR reg 40In force since April 2025

The total price, including every mandatory charge, in the headline price. No additional payment without the customer's express consent, so nothing pre-ticked.

Banned and unfair practices

C · DMCC ss 226-228In force since April 2025

No false urgency, no claims of limited availability that are not true, no omission of information the customer needs to decide.

Consent

D · PECR reg 6 D · PECR reg 22In force

Non-essential cookies and marketing messages wait for a clear yes; refusing is as easy as accepting.

Check your own flow in ten minutes

One question per finding. A "no" is worth a look; it is not a verdict.

Does the plan page open with no plan, or the monthly or smallest plan, selected?B · CCR reg 40Is every condition behind an offer price, such as new customers only or upfront billing, readable next to that price?B · DMCC s 230Can a customer see the plans and what they cost before creating an account or giving an email?C · DMCC ss 226-228Does the screen where the customer commits say how to cancel, not only that they can?A · DMCC ss 256-257Is a reminder before the end of a trial or discounted period announced where the customer signs up?A · DMCC ss 258-259Can a customer who joined online also cancel online, without a call or a written notice?A · DMCC s 260Does the order summary state the price that applies after a first-year or introductory discount?A · DMCC ss 256-257Is rejecting non-essential cookies one click on the first banner, with no ad trackers set before a choice?D · PECR reg 6Is marketing consent a separate, unticked choice, apart from accepting the terms?D · PECR reg 22

Not observed in this benchmark

What a public walk cannot show. Not part of the benchmark; included in a Flowlane review of your own flow.

Reminders before a trial or offer ends

Sent by email after sign-up; most flows stopped before the payment step where one could be announced.

Included in a Flowlane review

We walk it with a test account you provide.

Cancellation steps inside the account

Behind the login; we read only the public help pages and terms.

Included in a Flowlane review

We walk the exit with a test account.

Plans behind a sign-up wall

Four flows asked for an account before showing any plan or price.

Included in a Flowlane review

We walk them with a test login you provide.

Method and anonymity

Same walk, same checklist, same rule mapping for every sector.

Public flows, walked as a guest

Each flow was walked in a desktop browser set to the market's language, time zone and storefront, from the entry page to the last screen before payment or personal data. Cookie banners were read before the first click and spot-checked from the market; banners shown only to visitors from other countries were left out. Nothing was bought, no account was created, no personal data was submitted.

One screenshot per observation

An observation counts only with a screenshot, the URL, the step number, the date and the exact wording on the screen. Uncertain observations are not counted.

Rule, not verdict

Each pattern is matched to the provision it touches. It marks a screen worth a look, not a legal finding: whether a rule applies depends on facts a public walk cannot see.

Anonymous by design

No company is named, quoted or identifiable. Examples are written as categories. The sample is drawn from the sector, not from clients, and no participant was told.

20-minute walkthrough

Your own flow against 30 walked flows, in 20 minutes.

20 minutes
Reviewed before the call
No system access

The two steps worth a look first, with the screen they sit on
The rule each one touches, under the UK rules
Where your flow sits against the sector benchmark, for you only

What the 20 minutes look like →