What changes in January 2027
The DMCC Act's subscription contracts regime is expected to start in January 2027, subject to implementing regulations. Three moments in the flow matter most. Recheck after every release.
Information before sign-up
The ongoing price and the commitment, clear before the customer agrees.
Read the rule →Implementation details, commencement arrangements, exclusions and cooling-off rights need confirmation in the relevant regulations.
Rule by rule
Each rule in plain English.
What each provision says, what it asks of a screen, and where the line runs, with one example that fits, one worth a look and one outside the rule. The pricing, unfair-practice and consent rules apply today; subscription rules are expected in January 2027. Every rule chip in the benchmarks links to its card here.
| Rule | In plain English | In benchmarks |
|---|---|---|
| In force today | ||
| B · DMCC s 230 B · DMCC s 230In force since April 2025 Total price up frontThe price shown includes every charge the customer has to pay. Read the rule, with examples → | Total price up frontThe price shown includes every charge the customer has to pay. | 4 reportsConsumer software and media · Online retail · Subscription boxes · Travel and ticketing |
| B · CCR reg 40 B · CCR reg 40In force since 2014 Paid extras need a clear yesNo paid extra without a deliberate yes; pre-ticked is not a yes. Read the rule, with examples → | Paid extras need a clear yesNo paid extra without a deliberate yes; pre-ticked is not a yes.In force since 2014 | 4 reportsConsumer software and media · Online retail · Subscription boxes · Travel and ticketing |
| C · DMCC Sch 20 § 7 C · DMCC Sch 20 § 7In force since April 2025 No false "ends soon"A time limit used to push a decision has to be real. Read the rule, with examples → | No false "ends soon"A time limit used to push a decision has to be real. | 1 reportTravel and ticketing |
| C · DMCC ss 226-228 C · DMCC ss 226-228In force since April 2025 Misleading or pressuring, in contextPrices and key facts as clear as the decision needs, without undue pressure. Read the rule, with examples → | Misleading or pressuring, in contextPrices and key facts as clear as the decision needs, without undue pressure. | 3 reportsConsumer software and media · Subscription boxes · Travel and ticketing |
| D · PECR reg 6 D · PECR reg 6In force; amended February 2026 Cookies wait for a clear choiceNon-essential cookies need consent first; refusing is as easy as accepting. Read the rule, with examples → | Cookies wait for a clear choiceNon-essential cookies need consent first; refusing is as easy as accepting. | 4 reportsConsumer software and media · Online retail · Subscription boxes · Travel and ticketing |
| D · PECR reg 22 D · PECR reg 22In force since 2003 Marketing emails need a clear opt-inNo marketing emails or texts without consent; a pre-ticked box is not consent. Read the rule, with examples → | Marketing emails need a clear opt-inNo marketing emails or texts without consent; a pre-ticked box is not consent. | 4 reportsConsumer software and media · Online retail · Subscription boxes · Travel and ticketing |
| Expected January 2027 | ||
| A · DMCC ss 256-257 A · DMCC ss 256-257Expected January 2027 Clear terms before sign-upPrice, renewal and how to end it, shown before the customer signs up. Read the rule, with examples → | Clear terms before sign-upPrice, renewal and how to end it, shown before the customer signs up. | 2 reportsConsumer software and media · Subscription boxes |
| A · DMCC ss 258-259 A · DMCC ss 258-259Expected January 2027 Reminders before a renewalA reminder before a trial ends and before later renewals. Read the rule, with examples → | Reminders before a renewalA reminder before a trial ends and before later renewals. | 1 reportConsumer software and media |
| A · DMCC s 260 A · DMCC s 260Expected January 2027 A straightforward exitEnding is straightforward, and online if the contract started online. Read the rule, with examples → | A straightforward exitEnding is straightforward, and online if the contract started online. | 2 reportsConsumer software and media · Subscription boxes |
The price shown includes every charge the customer has to pay.
Read the rule, with examples →In force since April 2025Total price up front
DMCC Act 2024, section 230 · legislation.gov.uk ↗ (opens in a new tab)
When a screen invites the customer to buy, the price it shows has to be the total: every fee, tax or charge the customer will necessarily pay. If part of the price cannot be worked out in advance, the screen says how it will be calculated. Delivery charges that are not in the total are stated there too.
What it asks on the screen
- The first price the customer can buy at includes every charge they cannot avoid.
- A charge that depends on the basket or the address shows how it is calculated, beside the price.
- A charge and its condition read the same on every screen that shows them.
Where the line runs
Fits the rule
Event page: "£48.50 including £3.50 booking fee". The basket shows the same £48.50.
The fee every customer pays is in the price from the first screen.
Worth a look
A product page at £38. A £4.50 service fee appears for the first time at the payment step.
A charge the customer cannot avoid sits outside the price they were invited to buy at.
Outside this rule
Gift wrapping for £3, offered as an unticked option at checkout.
An optional extra the customer can leave out is not part of the total price.
No paid extra without a deliberate yes; pre-ticked is not a yes.
Read the rule, with examples →In force since 2014Paid extras need a clear yes
Consumer Contracts Regulations 2013, regulation 40 · legislation.gov.uk ↗ (opens in a new tab)
Before the customer is bound, a business needs their express consent to any payment on top of the main price. Consent cannot come from a default: a pre-ticked box, or an extra already in the basket, is not consent. Where it happens anyway, the customer can claim that payment back.
What it asks on the screen
- Every paid extra starts unticked and outside the basket.
- The customer adds it with a deliberate action, with its price in view.
Where the line runs
Fits the rule
Parcel protection for £1.49 as an unticked box, with the price beside it.
The customer has to choose it.
Worth a look
Parcel protection for £1.49 is already added to the basket. The customer has to remove it to avoid the charge.
An option to remove a paid extra does not show that the customer chose to add it.
Outside this rule
A free sample pre-selected in the basket.
Nothing extra is paid, so this rule does not apply. The default can still be looked at in context.
A time limit used to push a decision has to be real.
Read the rule, with examples →In force since April 2025No false "ends soon"
DMCC Act 2024, Schedule 20, paragraph 7 · legislation.gov.uk ↗ (opens in a new tab)
Schedule 20 lists commercial practices that are always unfair, whatever their effect on the customer. Paragraph 7 is one of them: falsely saying a product, or a price or term, is available only for a very limited time, to push the customer into deciding at once.
What it asks on the screen
- A countdown or "ends tonight" matches a real end: afterwards the offer is gone or the terms change.
- Keep the facts behind each claim: when it started, when it ended, what changed.
Where the line runs
Fits the rule
"Sale ends Sunday 23:59". On Monday the sale prices are gone.
The time limit is real.
Worth a look
A 10-minute countdown that starts again from 10:00 each time the page is reloaded.
A limit that never runs out is not a real limit.
Outside this rule
"Only 3 left" that reflects live stock.
A stock claim is not a time limit. If it were untrue, it would be looked at as a misleading action (s 226).
Prices and key facts as clear as the decision needs, without undue pressure.
Read the rule, with examples →In force since April 2025Misleading or pressuring, in context
DMCC Act 2024, sections 226 to 228 · legislation.gov.uk ↗ (opens in a new tab)
Outside the banned list, a practice is unfair if it misleads by what it shows (s 226) or by what it leaves out or makes unclear (s 227), or puts undue pressure on the customer (s 228), and is likely to change what the average customer decides. Whether a screen does that depends on the whole context.
What it asks on the screen
- The price a guest will pay is as clear as any member or app price.
- Information the customer needs for the decision is not hidden, unclear or late.
- Declining an extra or an account is as easy as accepting it.
Where the line runs
Fits the rule
Member price £18 and guest price £24, side by side at the same size.
Both prices are equally clear.
Worth a look
A large £18 "member price" on the product page; the £24 guest price appears only in the basket.
The price most customers will pay is less clear than the one they will not.
Outside this rule
An account offered at checkout, with "Continue as guest" just as visible.
Offering an account is fine when saying no is equally easy.
Price, renewal and how to end it, shown before the customer signs up.
Read the rule, with examples →Expected January 2027Clear terms before sign-up
DMCC Act 2024, sections 256 and 257 · legislation.gov.uk ↗ (opens in a new tab)
Before a subscription starts, the business gives key information, kept apart from everything else: what the customer will pay and how often, any free or discounted period and the price after it, how long the contract runs, that it renews, and how to end it. Online, the key information is shown without extra clicks.
What it asks on the screen
- The price after an introductory period sits beside the introductory price.
- Term, renewal and how to end it are on the screen where the customer commits, not only in the terms.
Where the line runs
Fits the rule
Beside the button: "£1 for the first box, then £29.99 every 4 weeks. Renews until you cancel online."
Price, renewal and exit are where the customer commits.
Worth a look
"First box £1" on the plan screen; the £29.99 price and the renewal appear only in the FAQ.
Key information sits one level deeper than the commitment.
Outside this rule
A one-off gift box with no renewal.
Without a recurring contract, the subscription rules do not apply.
A reminder before a trial ends and before later renewals.
Read the rule, with examples →Expected January 2027Reminders before a renewal
DMCC Act 2024, sections 258 and 259 · legislation.gov.uk ↗ (opens in a new tab)
While a subscription runs, the business sends reminder notices: before a free or discounted period turns into full price, and at set points before later payments. Each reminder says what will be charged and how to end the contract, stands out from anything sent with it, and arrives early enough for the customer to decide.
What it asks on the screen
- A reminder before the first full charge after a trial or discount.
- Each reminder states the price and how to end the contract, and comes before the last day to cancel.
Where the line runs
Fits the rule
Email five days before a trial ends: "£9.99 a month from 14 March. Cancel in your account in two clicks."
It arrives in time and says what happens next.
Worth a look
A 30-day trial that turns into £9.99 a month with no message before the first charge.
The customer is not reminded before paying.
Outside this rule
A pay-as-you-go top-up with no automatic payment.
Without automatic renewal, there is nothing to remind about.
Ending is straightforward, and online if the contract started online.
Read the rule, with examples →Expected January 2027A straightforward exit
DMCC Act 2024, section 260 · legislation.gov.uk ↗ (opens in a new tab)
The business makes it possible to end a subscription in a straightforward way, without steps that are not reasonably necessary. A contract taken out online can be ended online, with the instructions shown prominently. The customer can also end it with any clear statement of their decision.
What it asks on the screen
- A cancel route is easy to find from the account and the help pages.
- A subscription taken out online can be ended online, without a call or a letter.
- Each step on the way out is one the customer reasonably needs.
Where the line runs
Fits the rule
"Cancel subscription" in the account menu: one optional reason screen, then a confirmation.
Online, easy to find, and only the steps it needs.
Worth a look
Two online steps to sign up; cancelling only by phone during office hours.
A contract taken out online has no online way out.
Outside this rule
A plan agreed by phone, ended by phone.
The online route is required where the contract was made online. The exit still has to be straightforward.
Non-essential cookies need consent first; refusing is as easy as accepting.
Read the rule, with examples →In force; amended February 2026Cookies wait for a clear choice
Privacy and Electronic Communications (EC Directive) Regulations 2003, regulation 6 · legislation.gov.uk ↗ (opens in a new tab)
Before a site stores or reads anything on a visitor's device that it does not strictly need, it says what it is for and asks for consent. Since February 2026 some low-risk uses, such as simple statistics and site functionality, can run without consent if the visitor is told and can object. Advertising and cross-site tracking still wait for a clear yes, and saying no has to be as easy as saying yes.
What it asks on the screen
- Refusing non-essential cookies takes no more effort than accepting them, on the same layer.
- Optional categories start switched off.
- Advertising cookies are set only after the visitor says yes.
Where the line runs
Fits the rule
A banner with 'Accept all' and 'Reject all' as two buttons of the same size.
Both choices take one click.
Worth a look
A large 'Accept all' button beside a small 'Manage settings' link, with advertising cookies already set.
Refusing takes more steps, and tracking starts before the choice.
Outside this rule
A cookie that keeps the basket filled between pages.
It is strictly necessary for the service the visitor asked for.
No marketing emails or texts without consent; a pre-ticked box is not consent.
Read the rule, with examples →In force since 2003Marketing emails need a clear opt-in
Privacy and Electronic Communications (EC Directive) Regulations 2003, regulation 22 · legislation.gov.uk ↗ (opens in a new tab)
A business sends marketing emails or texts to an individual only with their consent, and a pre-ticked box, silence or inactivity is not consent. There is one route for existing customers: similar products, contact details collected during a sale, and a clear chance to refuse when the details are collected and in every message.
What it asks on the screen
- The marketing box starts unticked.
- Where the existing-customer route is used, the opt-out sits beside the email field, not in the privacy policy.
Where the line runs
Fits the rule
An unticked box 'Email me news and offers' under the checkout email field.
The customer opts in with a deliberate tick.
Worth a look
'Email me news and offers' already ticked under the checkout email field.
A pre-ticked box is not consent.
Outside this rule
An order confirmation and delivery updates sent by email.
Service messages about an order are not marketing.
Existing subscribers and scope
Do not assume the future subscription regime automatically covers every existing contract. Your advisers should confirm transitional arrangements, exclusions and the rules already applicable to your business. Flowlane records the screens, relevant provisions, confidence and evidence gaps.
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Sources and scope
Page updated: 7 October 2026. Applicability, exclusions and transitional arrangements need assessment by your advisers. Review the flow after every release.