How UK subscription contracts law affects auto-renewal and cancellation

What to take away

Auto-renewal is lawful, but only where the consumer sees the total price, the renewal period and the exit route before being bound.
Distance contracts carry a 14-day cooling-off period, and nothing is chargeable during it unless the consumer asked for early supply.
The CMA treats hidden renewal terms, default charges and blocked exits as unfair commercial practices.
The DMCC Act 2024 lets the CMA rule a practice unfair and fine up to 10 per cent of global turnover, or £300,000 where that is higher.
The DMCC Act subscriptions regime awaits secondary legislation and is not yet in force.

Where the 2013 Regulations bite on auto-renewal

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 cover most subscription contracts entered at a distance: web checkouts, card-billed app purchases and telephone sales.

Before the consumer is bound you must give the main characteristics, the total price inclusive of VAT, the duration and the conditions for ending the contract.

A linked terms page is not enough: the information must be storable and reproducible, so send an email confirmation or a downloadable summary.

See the Consumer Contracts Regulations 2013 for the full information schedule. If you are still deciding which rules attach to which product line, map subscription commerce UK regulations before you build the checkout.

The 14-day cooling-off window and default charges

For distance contracts the consumer has 14 days from the conclusion of the contract to cancel without reason or penalty. Miss that disclosure and the window extends by up to 12 months.

Cooling-off clock start

Service contract
day concluded
Goods
day of possession
Multiple items
last item delivered
No cancellation notice
extends up to 12 months

During the window the consumer owes nothing. Where they expressly asked for supply to start early, you may charge a proportionate amount for what was supplied.

Default charges are void: a pre-ticked add-on box takes payment without active consent, and that money is refundable.

Cooling-off window and default charges

Stage	Rule	Common failure
Before sign-up	Total price, duration, renewal and exit terms	Terms only in a linked PDF
At payment	Active consent to any paid extra	Pre-ticked add-on box
Before renewal	Clear reminder of the next charge	No reminder sent
On cancellation	Exit completes on request	Retention loop that cannot be skipped

Numbered steps for a defensible exit

A cancellation flow survives a trading standards mystery shop when it follows these steps in order.

Offer cancellation inside the account area, with no chat queue or phone call.
Confirm the request on screen and by email, timestamped, before the consumer leaves the page.
Make any retention offer declinable in one click, with the exit still completing.
Stop the next charge when the request is made, not at the end of the billing period.
Refund amounts taken after the request to the original payment method.
Keep one record showing the request, the confirmation and the stop instruction.

Six steps to a defensible exit

Offer cancellation in account area
Let consumer cancel in original channel
Show effective and last payment date
Send dated confirmation email
Log cancellation, timestamp and processor
Stop billing and refund post-cancellation payments

How the CMA enforces against subscription traps

The CMA uses the Consumer Protection from Unfair Trading Regulations 2008 as its main lever and publishes CMA consumer enforcement guidance on what it expects from a sign-up.

Its online games consoles investigation ended with Microsoft, Sony and Nintendo agreeing in 2022 to change auto-renewal practices across their subscription services.

The ASA's CAP Code takes the same line on pricing claims, so agreeing a subscription commerce disclosure policy before a campaign runs saves rework.

What the DMCC Act 2024 changes

The Digital Markets, Competition and Consumers Act 2024 received Royal Assent on 24 May 2024.

It puts subscription contracts on a statutory footing: pre-contract information, reminder notices before renewal, a cooling-off exit right and consent to renewal. The detail sits in secondary legislation, not in the Act.

The consumer protection provisions were due in April 2025 and that date has slipped; the subscription contracts regime is not yet in force.

Read the Digital Markets, Competition and Consumers Act 2024 for the subscription provisions. Penalties reach 10 per cent of global turnover, or £300,000 where that sum is higher.

The evidence set to keep

The sign-up screen as the consumer saw it, dated.
The pre-contract information issued and how it was delivered.
Consent records for paid extras and early supply requests.
Every renewal reminder sent, with dates.
Every cancellation request and its confirmation.
The stop instruction sent to the payment provider.

Hold these under a lawful basis and delete them when no longer needed; ICO GDPR guidance covers retention for cancellation data.

File each record against the rule it supports, because the split between renewal reminders or pre-contract information is where audits often land.

Common questions

Is auto-renewal legal in the UK?

Yes. It becomes a problem when the consumer never saw the renewal term, the price or the exit route before being bound.

What may I charge during the cooling-off period?

Nothing, unless the consumer expressly asked for early supply; then a proportionate charge for what was delivered applies.

When do the DMCC Act subscription rules start?

The Act is law. The subscription contracts regime awaits secondary legislation, so check commencement regulations before setting a compliance date.