DMCCA Subscriptions Contracts Regime – secondary legislation published, and a pragmatic signal from the CMA

Standfirst: Government has published the regulations and guidance that put the new subscription contracts regime into practice ahead of going live in January 2027. Here’s what’s changed and what it means for dating and social discovery platforms.

The Department for Business and Trade has laid the Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, alongside business guidance on the new regime. The regulations fill in the operational detail behind Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (DMCCA), which introduces tailored protections for consumers on auto-renewing contracts.

Government estimates UK consumers spend £1.6 billion a year on unwanted subscriptions. For dating and social discovery platforms, where subscriptions are the dominant model, this is the most significant change to consumer law in years.

What the regulations do

• Cooling-off periods can stretch to 12 months. Consumers already get a 14-day cooling-off period at the start of a contract and after certain renewals. If a business fails to meet the required pre-contract information duties, that window can be extended up to a maximum of 12 months.
• A waiver for digital content. For subscriptions to digital content only, consumers can expressly give up their cooling-off right so that supply starts immediately.
• Refunds and returns. The regulations set out what happens when a consumer cancels, during a cooling-off period or because a business has breached its duties, including how refunds are calculated. These largely mirror the existing Consumer Contracts Regulations.
• The best right wins. Where a consumer has more than one cancellation right, they can use whichever is most advantageous to them.
• Notices and exits. New provisions make sure required information and reminder notices aren’t overlooked, and that consumers can easily end a contract and stop future payments.
• Scope. The rules apply across England, Wales, Scotland and Northern Ireland. Once in force, they replace the pre-contract information and cancellation parts of the Consumer Contracts Regulations for subscription contracts. Consumers can enforce their rights directly, and the CMA can impose financial penalties.

Where the industry’s concerns landed

Government’s consultation drew 75 responses. Businesses argued for cooling-off refunds to be calculated differently and for the digital content waiver to apply more widely. Government chose to keep both consistent with existing rules.

For our sector, the practical questions remain around how cooling-off refunds work for services that can be used heavily in the first days of a subscription, and where dating subscriptions sit between digital content and services. ODDA will keep pressing for clear, workable guidance on both.

The CMA’s approach to enforcement

In a blog published on 14 October, the CMA set out how it will approach the regime’s first months. Its focus will be on supporting businesses to get compliance right. It will use its powers proportionately, target the most serious conduct, and take genuine efforts to comply into account when deciding whether to intervene.

The CMA is also clear that this is not a pause. Enforcement is not being delayed, conduct during this period can still be considered later, and it expects businesses to be working towards compliance as quickly as possible.

The ODDA welcomes this, and in our letter following the September roundtable, we asked for a pragmatic transition given the tight timeline to January. The CMA’s statement reflects that approach, while making it clear that businesses are expected to start taking action now.

“We asked for a realistic, proportionate start to the new regime, and the CMA’s statement is about as clear a signal as we could have hoped for. But it is not a free pass. Members should treat the next few months as the window to get compliant, and ODDA is here to help them do it.” 

— Simon Newman, CEO, ODDA

What members should do now

1. Review pre-contract information and checkout flows against the new requirements. Gaps here are what trigger extended cooling-off periods.
2. Check that cancellation and auto-renewal exits are simple and online, in line with how customers sign up.
3. Map renewal reminder notices to the points in the contract where they’re required.
4. Document your compliance work. Genuine, evidenced efforts are what the CMA says it will take into account.

Read the government guidance on subscription contracts and the CMA’s blog, Direct consumer enforcement: 18 months on.

ODDA members with questions about the new rules can contact us.