This guide is our plain-English reading of the Act, the draft regulations and the government's draft guidance published on 19 October 2026. It is not legal advice, and the regulations still need Parliament's approval. We'll update this page as the final versions are published.
The new subscription rules in the Digital Markets, Competition and Consumers Act 2024 have been a long time coming, and the start date has moved more than once. In April 2026 the government expected them in spring 2027. In August it brought the date forward to 1 January 2027. On 19 October 2026 it published 77 pages of draft guidance and laid the draft regulations before Parliament.
The regulations still need approval and the guidance is marked as draft. But the direction is clear and the date is close. This guide sets out what the rules mean for publishers selling subscriptions, which the government's guidance doesn't address directly: it doesn't mention magazines, newspapers or print at all.
Who the rules cover
A subscription contract, for these rules, is a contract between a business and a consumer for goods, services or digital content, where either:
- the supply carries on automatically and the consumer is charged automatically for each period unless they stop it; or
- there's a free or discounted period, after which the consumer automatically starts paying, or paying more, unless they stop it first.
So the classic continuous-payment magazine subscription is in, whether it's monthly direct debit or an annual card renewal. Free trials and introductory offers that roll onto full price are in. Subscriptions that simply end unless the reader chooses to pay a renewal invoice are out, because nothing renews automatically.
Consumers, not businesses
A consumer is an individual acting wholly or mainly outside their business. The draft guidance is clear that a business buying subscriptions for its own use, or for its employees, is business to business and out of scope.
That matters a lot for B2B titles. Company-paid subscriptions and corporate licences are out. But most B2B and specialist titles also have readers paying personally: students, retired members of the profession, enthusiasts, people who prefer to pay themselves. Those readers are probably consumers. Your first job is to work out how many you have.
Only new contracts
The rules apply to contracts entered into on or after 1 January 2027. They're not retrospective, and the draft guidance says that holds even when an existing subscription renews after that date. What isn't addressed is whether an upgrade or a significant change to an existing subscription creates a new contract, so take advice if you plan to move existing subscribers onto new terms.
Before they sign up: the key information
Before a consumer commits, you must give them a short block of key information, together, set apart from everything else and in plain language. Online, it has to be readable as part of the sign-up journey itself: the draft guidance says a link to it is not enough. It includes:
- that the subscription will continue and they'll keep paying unless they end it, and any minimum period;
- for a trial or offer, that they'll be charged (or charged more) unless they cancel, the date that starts and how much it will be;
- how often they pay and the minimum amount each time;
- the monthly equivalent, if they don't pay monthly (the guidance's example: £120 a year is £10 a month);
- the minimum total they'll be liable for;
- any built-in price changes;
- how to end the subscription and any notice period;
- when you'll send reminder notices;
- a summary of their cooling-off rights.
The full pre-contract information (company details, delivery, complaints, cooling-off details and so on) can sit behind a prominent, clearly labelled link online, but it then has to be sent on a durable medium, such as an email, soon after sign-up and before the first issue is sent.
The order button has to make clear the reader is agreeing to pay. If the final step doesn't involve them expressly acknowledging that, they're not bound by the contract.
Reminder notices
This is the change most subscription systems will feel. Reminders are required:
- roughly every six months on rolling subscriptions that renew more often than yearly, such as monthly direct debits (not every month);
- before the first payment after a free or discounted period, or the first payment at a higher rate;
- before every renewal onto a term of 12 months or more, plus an additional, earlier reminder at a reasonable time before that one. Annual subscriptions get two reminders a year.
Timing is your choice, then it's a promise
There's no fixed number of days in the law. You choose a reminder period, state it in the key information, and then you have to send every reminder within it. It must give the reader a reasonable chance to decide and to act before they're charged. If your stated period isn't reasonable, or a reminder goes out late, the reader gets the right to cancel and reclaim payments (more on that below).
That means your renewal series needs to run on time, every time, for every title. For most publishers, that's a system question as much as a copywriting one.
What a reminder must say
Each reminder must be on a durable medium (email, letter or text), be clearly a reminder (the guidance suggests saying so in the subject line), and put the required information more prominently than anything else in it. Marketing is allowed alongside, as long as it's less prominent. The required information includes the renewal date and amount, the previous amount and any increase, what happens after renewal, and how and by when to cancel to avoid paying. Our example reminder wording shows one way to lay it out.
Making it easy to leave
Readers must be able to end their subscription at any time, in a straightforward way, without steps that aren't reasonably necessary. The draft guidance puts it simply: exiting should be as easy as signing up.
- If they could sign up online, they must be able to end it online, for example with a clearly labelled button or a simple web form.
- An email address on its own is not a straightforward online exit, according to the draft guidance.
- Retention offers are allowed, but mustn't prolong the process or put people off finishing it. Feedback can be asked for, not required.
When a subscription ends, you must send an end of contract notice confirming the date it ends: within 24 hours if they ended it online, or within three working days otherwise. Ending a subscription stops future renewals; the reader still gets what they've already paid for.
Cooling-off: two chances to change their mind
There's an initial 14-day cooling-off period, and a new renewal cooling-off period of 14 days after a trial or offer converts to full price and after each renewal onto a term of 12 months or more. After a qualifying renewal you must send a separate cooling-off notice with no marketing in it, and it can't be combined with a reminder.
A few points matter particularly for publishers:
- Print subscriptions: where goods are supplied, the initial 14 days run from when the reader receives the first delivery in full. The government declined to treat magazines and newspapers as perishable goods, which suggests printed issues will be treated as returnable goods: on cancellation, readers return them or pay for them.
- Digital-only subscriptions: readers can lose the initial cooling-off right once access starts, but only if they expressly asked for access to start straight away, acknowledged they'd lose the right, and you confirmed both in writing. A pre-ticked box doesn't count.
- Print and digital bundles: where goods and digital content come under one contract, the reader can't waive the initial cooling-off right.
- Digital renewals: if a reader cancels during a renewal cooling-off period, you can charge only for the access they've had. The guidance's example is £4 for four days of a £365 annual plan.
If you don't give the cooling-off information properly, the period can run for up to 12 months longer.
When you take the money
One rule is easy to miss. A term that makes the reader liable for a renewal payment before the day the subscription renews has no effect. If you currently collect annual renewals a couple of weeks before expiry, look at your payment timing.
What happens if you get it wrong
Several of the duties become terms implied into every subscription contract. If you don't give the key information properly, don't send a required reminder, set an unreasonable reminder period or make leaving too hard, the reader can cancel, within 12 months, and in many cases get back what they have paid since the breach. The Competition and Markets Authority can also enforce the rules directly, with fines of up to £300,000 or 10% of turnover, whichever is higher.
If a bureau or agency runs your subscriptions, the duties still sit with you as the business the reader contracts with. You need your partner to do it correctly and to keep evidence that every notice went out.
What to do before 1 January
- Count your consumers. Separate personally paid, auto-renewing subscribers from company-paid ones and from invoice renewals.
- Rewrite the sign-up journey. Put the key information block, with the monthly equivalent and your reminder period, before the order button on every offer page.
- Decide your reminder periods for each kind of subscription and write them down.
- Rebuild the renewal series so the compulsory reminders go out on time, with the required information first.
- Build the online exit and the automatic end of contract notice.
- Add the renewal cooling-off notice for trial conversions and annual renewals.
- Check payment timing against renewal dates.
- Check your partners: bureaux, fulfilment houses, payment providers and agencies.
Our free subscription rules checklist breaks this down into individual tasks you can tick off and print.
How we can help
In Avio, our platform for larger publishers, renewal series are set per product and every batch is tracked, so you can show which reminders went out and when. In Adeptis, our platform for smaller publishers, the renewals desk shows who's coming up for renewal. If you'd rather hand the work over, our bureau runs renewals, notices and cancellations for publishers.
If you'd like to talk through what the rules mean for your titles, get in touch.
Questions
Do the rules apply to our existing subscribers?
Not legally. They apply to contracts entered into on or after 1 January 2027, and the draft guidance says they are not retrospective, even when an existing subscription renews after that date. The guidance does say best practice is for consumers to get consistent protection whenever they signed up, and running two processes side by side is hard work, so many publishers will move everyone over.
We're a B2B publisher. Are we affected?
Only for subscribers who are consumers. A company buying subscriptions for itself or its staff is business to business and out of scope. But individuals who pay personally, for their own reasons, are consumers, even if they work in your industry. If you have a meaningful number of them, the rules apply to that part of your file.
Our annual subscriptions renew by invoice. Are they covered?
If the subscription only continues when the reader chooses to pay a renewal invoice, it doesn't renew automatically, so it isn't a subscription contract under these rules. The rules bite where the reader is charged, or becomes liable to pay, unless they act to stop it: continuous card payments, direct debits and auto-renewing terms.
Are free controlled circulation copies covered?
The rules cover contracts where the consumer pays, or will become liable to pay. A free qualified copy with no payment and no automatic move to a paid rate shouldn't be caught. A free trial that rolls onto a paid subscription is caught.
Is there a required number of days for the reminder?
No. You choose the reminder period, state it in the key information at sign-up, and then must stick to it. It has to give the reader a real chance to decide and act before they're charged. The draft guidance suggests wording like 'a reminder notice will be sent X to Y days before' but sets no numbers.
Who is responsible if a bureau or agency runs our subscriptions?
The duties sit with the trader the consumer contracts with, which is normally the publisher, even if a bureau sends the notices and takes the payments on its behalf. In practice you need your bureau to do the work correctly and to keep the evidence that it did.
Sources
- DBT, Guidance on the subscription contracts rules (draft, 19 October 2026)
- Draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026
- Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 2
- Government response to the consultation on implementing the subscription contracts regime
- PPA: government brings forward implementation of subscription rules to January 2027