Guides

The new 14-day cooling-off period after a free trial

Updated Invalid Date. Based on the Digital Markets, Competition and Consumers Act 2024 and the draft 2026 Regulations and guidance. Not legal advice.

UK subscribers already have 14 days to cancel after signing up. From 1 January 2027 they also get a renewal cooling-off period: a further 14 days to cancel after certain renewals (DMCCA s.265, Act).

What triggers it

A “relevant renewal” happens when (s.265(3)):

• the customer becomes liable for the first payment after a free or discounted period, or
• a renewal payment is due and the next one is more than 12 months away, which covers annual plans, or no further payment is due but the contract runs past 12 months.

The period starts on the day of the renewal and ends 14 days after it (s.265(2)). A trial that converts on 15 January gives a right to cancel until the end of 29 January.

The cooling-off notice

For each renewal cooling-off period you must send a separate notice, on the first day or as soon as reasonably practicable after (s.266(3)). It must say (s.266(2)):

• that the subscription is continuing;
• that the customer can cancel during the period, when it starts and ends, and how;
• if the right can be lost, when;
• what happens if they cancel: any refund, why it might be reduced, and for goods whether they must return them.

It must be in writing on a durable medium and readily recognisable as this notice (draft reg 36). Promotions do not belong in the same message.

If the notice is missed

The period does not end after 14 days. It runs until 14 days after you send a corrected notice, or for 12 months if you never do (draft reg 6). During that time the customer can cancel and you may have to refund in full, because you can only keep a proportionate amount if the notice was given (draft regs 19(3) and 20(1)(c)).

See proportionate refunds and the cooling-off template.