Later in 2026 (expected Autumn, exact date TBA), the UK will have new subscription contract rules under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).
This change is designed to ensure fair practices for consumers which includes your individual members.
Does the DMCCA apply to you?
If you are a local, national or international body with UK individuals as members, yes, this law applies..
What counts as a subscription?
Subscriptions are defined as members being automatically billed for their membership. This includes:
- Recurring credit/debit card payments
- Direct Debit (which already has longstanding consumer protection rules)
Note: If you require members to proactively log in and pay manually each year, fewer changes are required.
DMCCA Compliance Checklist for Membership Subscriptions
To comply with the new rules, membership bodies must implement the following changes:
- Separate Renewal Notices: Provide clear advanced notices ahead of renewal. These must be standalone emails, separate from marketing communications. These notices must reiterate the details of the subscription as well as explaining how to cancel the renewal.
- “Easy Exit” Cancellation: Ensure the member area provides clear and easily accessible ways to cancel membership
- Rule of Thumb: It should be “as easy to exit as it was to enter”. If a member joined online in two clicks, a member should be able to cancel online in around two clicks.
- Exit Surveys: You may ask an optional “Reason for leaving” question, but you cannot force a member to call a phone number if they joined online.
- Clear Terms & Conditions: When a member chooses a subscription payment method, you must clearly display:
- The subscription commitment length e.g, 12 months
- The total price payable for the subscription period e.g. £120 for the year, paid £10 monthly
- Auto-renewal frequency e.g. annually
- How, where, and when to cancel
- Details of any discount periods or future price rises
- That renewal reminders will be sent before each renewal
- Audit Trails: Maintain records showing that members received required information and when.
Pro-tip: Annual Commitments vs. Monthly Payments
Most memberships we see are 12-month commitments. When these are not paid in full, these are paid in installments (monthly or quarterly). If your members sign up for a full year, this is treated as an annual contract. This means you don’t need to send reminder notices every 6 months, just one pre-renewal notice before the year end is sufficient. However, remember that when the next year renews, the member needs to receive a new 14-day cooling-off period where they can cancel their renewal.
If you are concerned about how your membership body is currently managing subscriptions with respect to these changes, we are happy to speak with you to help better understand these changes, the nuances of best practices and practical tips on how to comply. Please contact us on the form below.
Concerned about compliance? The VeryConnect membership software is fully DMCCA compliant and we will be working with our customers ahead of time to ensure that they feel comfortable with the changes ahead of the 2026 deadline for new rules coming into effect.
Frequently Asked Questions (FAQs)
Does the DMCCA apply to corporate memberships?
The law specifically protects individual consumers. While limited companies generally do not fall under this scope, individual sole traders might. We recommend applying these best practices for all your members to ensure a consistent, high-quality member experience.
We don’t have any UK-based members at the moment but it is possible for UK individuals to join. Do we need to comply?
Yes, if you allow UK consumers to buy memberships, you must ensure these rules are followed. An example given is, if UK addresses can be entered on application forms, then you invite UK consumers to be able to apply and therefore these rules apply to protect this UK consumer.
How often must we send renewal notices?
- For Annual Commitment Renewals: Notices must be sent before every annual renewal.
- For Monthly Rolling Commitments: Notices must be sent before the first renewal, and at 6 monthly intervals from then on.
Does the requirement to provide renewal notice apply only to the first renewal after the changes, or to all subsequent renewals?
Renewal notices must be sent before the first renewal payment, and at regular intervals thereafter e.g. generally every 6 months for monthly payers, or before every annual renewal.
Explicitly, for shorter commitments such as a monthly commitment, notices must be sent before the first renewal, and at 6-month intervals thereafter.
Does this affect payment “cooling off” period (i.e. the 14 day period for refunds) for initial subscriptions and/or renewals?
Some details regarding cooling off periods are still to be confirmed/laid out by the UK Government, however for services or digital content, the 14-day cooling off period, in which people may cancel for any reason and receive a refund, runs from the day after the subscription/contract starts. This encapsulates the existing consumer cancellation right in the UK’s Consumer Contracts Regulations 2013 (CCR), but the DMCCA expressly incorporates it for subscriptions.
There will be a renewal cooling off period as well which will apply when a subscription auto-renews after a free trial or discounted period, or when an ongoing contract auto-renews into a contract that binds the consumer for 12 months or more. This latter case is likely to apply for many 12 month membership renewal subscriptions.
Since membership services start immediately, the consumer may still cancel after a renewal, during the renewal cooling off period, but the refund will likely be minus the days for which the membership has been held since renewal, and before cancellation. Regulations will set out how this works in detail before the new rules come into force. Of course, retaining this pro-rata membership fee is optional and membership bodies may opt to refund in full given two weeks is 3.84% of a 12 month membership fee. It may prove uneconomical both with respect to financial control and reputationally to seek to retain such a minimal percentage of the income. As always, the overall goal for membership bodies should be engagement and retention such that renewal cooling off cancellations are the exception.
Can I ask members why they are cancelling?
Most of our membership customers ask for members to complete an application form to become a member. Therefore it is not unreasonable to ask a brief, optional question or two when the member is cancelling, such as “What is your reason for cancelling your membership?”. If your membership sign up requirements are less rigorous such as becoming a paid subscriber with just an email address and a credit card, you may want to ask any questions on screen after cancellation to prevent any blockages to the ease at which members can cancel.
What are the penalties for non-compliance?
Serious breaches of consumer protection requirements may incur penalties of: 10% of global turnover or £300,000, whichever is greater. There is a sliding scale of penalisation including failure to comply with investigation requests with a penalty enforceable of 1% of global turnover or £30,000, whichever is greater. These penalties are designed to incentivise even very large organisations to fully comply with the law.
What has motivated this change for subscription rules in the UK?
Taken from the UK Government website: “There are approximately 155 million active subscriptions in […] the UK, representing consumer spend of approximately £26 billion per year. Approximately 5.8% of active subscriptions are unwanted by the consumer, meaning an estimated 9.7 million unwanted subscription contracts are active in the UK.
[…] An estimated 3.6 million are thought to be the direct result of being rolled over from a free or discounted subscription trial period, whilst approximately 1.3 million are thought to be the result of auto-renewing subscriptions.”
“An estimated £1.6B is spent by consumers on unwanted subscription contracts annually.”
Learn more
If you would like to speak to our team to get a better understanding of these changes, or get a demo of VeryConnect’s fully DMCCA-compliant membership software, please complete the form below.