UK subscription rules 2027 (DMCCA): a guide for Shopify merchants

If you sell subscriptions to customers in the United Kingdom, the way you sell them is about to be regulated in much more detail. The Digital Markets, Competition and Consumers Act 2024 (the DMCCA, often shortened to the DMCC Act) was passed in May 2024, and its subscription contracts regime comes into force in January 2027. That date was brought forward from the spring 2027 date set in April 2026 by the government's announcement of 9 August 2026, which put the rules in place "in time for when customers often start new subscriptions".

The government confirmed the shape of the new UK subscription rules in its consultation response published in April 2026. The secondary legislation that will set out exact notice formats and wording is still pending, but the core duties are now settled enough for merchants to plan around.

The scale explains why the government is doing this. According to the official announcement from April 2026, there are around 155 million active subscriptions in the UK, roughly 10 million of them unwanted, and the reforms are expected to save consumers around £400 million per year, or about £14 per month for each unwanted subscription. This article walks through what the regime covers, the duties it creates, and what you can sensibly do now if you run Shopify subscriptions and sell to UK consumers.

Who is covered

The subscription contracts regime applies to traders selling subscriptions to UK consumers, wherever the business is based. If your Shopify store ships subscription boxes from the Netherlands, Poland or the United States to customers in the UK, you are in scope. It covers subscriptions for goods, services and digital content, whether they renew automatically or start as a trial that converts into a paid contract.

There are sector exclusions: utilities, financial services, certain healthcare, services regulated by Ofcom, gambling, travel and accommodation, education, and charity subscriptions all sit outside the regime. There is also a narrow exception for "everyday consumables delivered to the home", but it is only available to micro-entity traders, so most established merchants should not rely on it. Law firm analyses from Taylor Wessing and White & Case cover the scope in more detail.

What this means for your store: a typical Shopify subscription product, such as coffee, supplements, cosmetics, pet food or a digital membership, sold on auto-renewal to UK consumers, will almost certainly fall under the regime. Being based outside the UK does not take you out of it.

The duties, one by one

1. Clear pre-contract information

Before a customer signs up, you will need to give them key information clearly and prominently: what the subscription costs, how often it renews and is charged, the minimum commitment, how a trial converts into a paid plan, and how to cancel. The exact list and format will be fixed in secondary legislation, but the direction is clear: the essentials must be visible before checkout, not buried in terms and conditions.

What this means for your store: review your product pages, plan selectors and checkout flow. The renewal frequency, price after any trial, and cancellation route should be readable at the point where the customer commits, not one click away.

2. Renewal reminders

The regime introduces mandatory reminder notices. Merchants will need to send a reminder before a free or discounted trial ends, before the first renewal payment is taken, then at least every six months for rolling contracts, and before the renewal of any contract lasting 12 months or longer. The reminder must tell the customer, in effect, that money is about to leave their account and how to stop it.

What this means for your store: "silent" renewals are on the way out for UK customers. If your subscription setup cannot send renewal reminders today, that is the single most concrete gap to close, and it is worth closing early: reminder emails also reduce chargebacks and angry support tickets regardless of regulation.

3. Two cooling-off periods

Consumers will get a 14-day cooling-off period when they enter the contract, which is familiar from existing distance selling rules. The DMCCA adds a second one: another 14-day cooling-off period after a trial converts into a paid subscription, and after a contract of 12 months or longer auto-renews. During these windows the customer can exit and receive a full or proportionate refund.

What this means for your store: trials and annual plans deserve a fresh look. A customer who forgets to cancel a trial will be able to unwind the conversion for 14 days, and an annual subscriber will be able to do the same after each yearly renewal. Model that into your revenue expectations for trial-heavy and annual offers, and make sure your refund process can handle proportionate refunds cleanly.

4. Cancellation as easy as signing up (click to cancel)

The widely reported "click to cancel" duty means cancelling must be as straightforward as subscribing. If a customer signed up online, they must be able to cancel online, without phoning a call centre or writing a letter. On top of that, traders must accept any clear statement of cancellation, whatever the channel it arrives through: an email, a chat message or a note in an order reply all count.

What this means for your store: the customer portal needs a working, self-serve cancel button, and your support team needs a simple rule: if a customer clearly says they want to cancel, that is a cancellation, no matter where they said it. Retention offers are still allowed, but they cannot stand between the customer and the exit.

5. Refunds and payment timing

Refunds due under the regime must be paid within 14 days. Merchants will also be prohibited from charging a customer before a renewal actually falls due, which rules out taking payment early "for convenience".

What this means for your store: check how quickly refunds actually reach customers through your payment setup, and confirm that your billing engine only charges on the renewal date itself.

Enforcement: the CMA can fine directly

This is not a regime that depends on individual consumers suing. Under the DMCCA, the Competition and Markets Authority can fine businesses directly, up to £300,000 or 10% of global annual turnover, whichever is higher. And enforcement is already visibly active: in April 2026 the CMA fined the AA £4.2 million, plus over £760,000 in customer refunds, under the DMCCA's consumer protection provisions, over a hidden mandatory fee at checkout. The subscription-specific duties arrive in January 2027, but the regulator's appetite is already on display.

What you can do now

January 2027 is about five months away rather than eighteen, so there is no time left to wait for the final statutory wording. The practical preparations are things a well-run subscription business benefits from anyway:

• Turn on renewal reminders. Send an email before each charge, and before a trial converts. This is the heart of the new regime and it improves customer trust today.
• Make online cancellation self-serve. A customer who signed up online should be able to cancel online, in the customer portal, without contacting support.
• Review trial and annual plans. Understand how the two 14-day cooling-off periods will apply to your trial conversions and 12-month-plus renewals, and how refunds would be calculated.
• Keep records of the notices you send. If a dispute or an enquiry ever comes, you will want to show which reminder went to which customer and when.
• Watch for the secondary legislation. The exact notice formats and final wording are still to come, so leave room to adjust templates before January 2027.

Where Progus Subscriptions fits

If you run your subscriptions on Progus Subscriptions, two of the items above are already covered: the app supports configurable renewal reminder emails before each charge, on both card billing and SEPA direct debit via Mollie, and customers can cancel themselves in the customer portal. The remaining preparations, above all reviewing how your trials and annual plans are structured, are decisions for you as the merchant, and worth starting well before January 2027.

The bottom line

The DMCCA's subscription contracts regime is the biggest change to UK subscription selling in a decade: renewal reminders, two cooling-off periods, easy cancellation and direct CMA enforcement, in force from January 2027. For merchants who already treat subscribers fairly, most of it is formalising good practice. The sensible move is to get reminders and self-serve cancellation in place now, keep records, and fine-tune the details once the secondary legislation lands.

This article is general information, not legal advice. For advice on how the DMCCA applies to your business, speak to a qualified solicitor.