Guides

UK subscription rules 2027 for US companies

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

If you sell auto-renewing subscriptions to consumers in the UK, a new set of rules applies to every UK subscription that starts on or after 1 January 2027. Being based in the US does not take you out of scope: the draft government guidance says traders outside the UK who sell to UK consumers need to comply (Guidance FAQ 9).

Where the rules come from

• Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 (sections 254 to 281 and Schedules 22 and 23).
• The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026, laid before Parliament on 19 October 2026 and due to come into force on 1 January 2027, subject to approval by both Houses.
• Draft government guidance published the same day.

The rules apply only to contracts entered into on or after the start date (regulation 2(2)). Existing subscribers stay under the older Consumer Contracts Regulations 2013.

What changes for your business

1. Key information at checkout. Before the customer subscribes, show together and separately from other content: that the plan auto-renews, the price and when the first charge happens, the minimum total, how to cancel, when you will send reminders, and a summary of cooling-off rights (Schedule 23 Part 1). A link is not enough for this key information (Guidance FAQ 17).
2. Reminder notices. Before the renewal payment that closes each six-month period, before the first charge after a free or discounted trial, and an extra early reminder for annual plans (sections 258 and 259). See reminder notices.
3. A new 14-day cooling-off period after a trial converts or an annual plan renews, with a separate notice (sections 265 and 266). See cooling-off after a free trial.
4. Proportionate refunds if a customer cancels in a cooling-off period (regulations 19 to 21). See proportionate refunds.
5. Easy online cancellation and a confirmation within 24 hours (sections 260 and 261). See online cancellation.

What is at stake

Customers can cancel and recover payments if you miss certain duties, for up to 12 months (draft regulations 23 and 24). The Competition and Markets Authority can impose penalties of up to £300,000 or 10% of global turnover, whichever is higher. See CMA penalties.

If you bill through Stripe

Stripe’s built-in emails were designed for US and card-network rules and do not cover the UK schedule. See Stripe and the UK subscription rules.