Key takeaways
- Review one flow at a time, from the offer to the confirmation email.
- The UK subscription regime is expected January 2027; Australia's rules apply from 1 July 2027.
- Save each observation with its screen, date and provision, then recheck after every release.
The rules side by side
Five checks, each with the UK and the Australian rule next to each other.
1Before sign-up
DMCC Part 4 Chapter 2: review the future pre-contract information duties and implementing rules. Expected January 2027; recheck after every release.
ACL section 48D: check covered subscription disclosures, including introductory pricing. From 1 July 2027; recheck after every release.
2Full price and extras
DMCC section 230: mandatory charges and total price. CCR regulation 40: express consent to additional payments.
ACL section 48A: per-transaction charge disclosure beside the base price, where applicable.
3Trial and renewal
Review reminder timing, cooling-off information and transition from an introductory offer under the subscription framework.
Record the introductory period, recurring amount and price steps under the applicable subscription disclosures.
4Cancellation
Review a straightforward route to end a covered contract and the applicable notices, scope and exceptions.
ACL section 48F: review the cancellation route, including online cancellation for covered subscriptions entered into online.
5Evidence and recheck
Keep the source screen, provision, assessment confidence and reason. Compare the changed flow after every release.
Keep observations separate from judgement under the general prohibition. Record confidence, reasons and the next check.
Check your flow
Work through it, screen by screen.
Tick what you have checked and export your record. Recheck the same points after every release.
Your record: each check becomes a row with screen, date, market, provision, confidence and next check.
1Before sign-up
2Full price and extras
3Trial and renewal
4Cancellation
5Customer choices
6Consent
Planning the review itself? Use the review checklist →
How to run it in one session
Choose one sign-up, renewal or cancellation flow. Agree the account state and device, remove personal data from examples and record what is visible at each decision. This checklist supports review; your advisers determine the applicable legal requirements.
Keep the record useful
For each row, record the screen, date, market, relevant provision, finding confidence, recommended change, owner and next check. Missing access or evidence stays an explicit limitation. Recheck the same scope after every release.
Sources and scope
Page updated: 7 October 2026. Applicability, exclusions and transitional arrangements need assessment by your advisers. Review the flow after every release.