The ODDA calls for changes to draft subscription refund guidance
The ODDA has written to Department of Business, Innovation, Science and Trade (DBIST) outlining concerns about the draft guidance for the upcoming Consumer Subscription Contracts Regulations.
We support the new regime and the stronger protections it gives consumers, and we took part in the government roundtable on 16 September. But we believe some parts of the draft guidance need further review before the final version is published.
Cooling-off refunds
We support the new regime and the stronger protections it gives consumers. But as currently drafted, the guidance leaves real uncertainty about how refunds should be calculated for digital services. Unlike a gym membership, where the number of days used is easy to count, usage of a digital service cannot be measured by time alone. Content can be consumed intensively in a short period, so someone could use much of what a service offers, cancel within the cooling-off period, and still receive a full refund.
That creates a cost that platforms cannot recover, and one that ultimately falls on the consumers who use services as intended. A rule designed to protect consumers should not reward the minority who cancel once they have had the full benefit.
A single refund approach does not reflect how different digital services work. We have shared a scenario from our sector with DBIST to outline the practical challenges, and offered to work with them on guidance that is fair to consumers and workable for online dating platforms.
Implementation timing
The go-live date has been brought forward to January 2027. With the guidance still in draft, this allows very little time for businesses to make the required changes. We are asking government to instruct the CMA to allow a grace period for enforcement while businesses adapt.
