New subscription rules

New year intentions, short-lived commitments: what the new subscription rules mean for memberships

Laura Crowe, Senior Associate

If your business operates in fitness and wellbeing, lifestyle and leisure, beauty, retail, or other consumer‑facing sectors, upcoming changes in Autumn 2026 to subscription rules are likely to affect you. Any business taking recurring payments from UK consumers, either monthly, quarterly or annually should be paying close attention.

The Digital Markets, Competition and Consumers Act 2024 (the DMCC Act) introduces new requirements for subscription contracts. While the government has indicated that the subscription rules are unlikely to take effect before autumn at the earliest, this is best viewed as a prepare now change rather than one to defer.

What counts as a “subscription contract”?

Under the new legislation, a subscription contract is broadly framed to capture auto‑renewing or rolling arrangements under which consumers pay recurring charges for goods, services or digital content.

This is highly likely to include gym, club and leisure memberships, where customers gain ongoing access to facilities or services in exchange for regular payments.

Note: Different considerations apply where memberships are offered solely on a business‑to‑business basis.

Each January, gyms and fitness apps typically see a spike in “New Year, New Me” sign‑ups, often supported by discounted introductory offers or free trials. By February, many consumers disengage, yet their subscriptions frequently continue. The DMCC Act is aimed at preventing consumers being retained by default, by improving transparency, reminders and cancellation rights.

Key changes businesses should plan for

1. Clearer information before sign‑up

The new framework places strong emphasis on the information provided before a consumer commits, including a clear summary of key terms. Membership sign‑up journeys should clearly explain:

• total price and payment frequency, including any price increase mechanisms;
• minimum commitment periods and what happens when they end;
• how and when customers can cancel, including notice periods;
• whether the membership auto‑renews or rolls on;
• how trials or introductory offers operate and when full pricing applies.

2. A genuinely straightforward cancellation route and cooling-off periods

Consumers must be able to cancel subscriptions easily, ideally via a single communication. Businesses should review whether:

• customers who join online can also cancel online;
• cancellation is conditional on phone calls, in‑person visits or retention scripts;
• app‑based subscriptions can be cancelled directly within the app;
• cooling off periods at initial sign-up stage and after any trial ends or after an auto-renewal.

Unnecessary friction at this stage is likely to be a key enforcement focus.

3. Reminder notices at key points

The legislation is expected to require reminder communications around renewals, giving consumers a real opportunity to reassess and cancel.

Annual memberships and 12‑month commitment deals are obvious candidates, but rolling monthly subscriptions where payments can easily be forgotten are also in scope.

4. Greater scrutiny of trials and introductory offers

Free or discounted trials that roll into full‑price subscriptions are firmly covered by the new rules. The intention is to prevent consumers being caught out by automatic conversions.

Where promotions such as “£1 for the first month, then £49 per month” are used, the transition date and price should be unmistakably clear and reinforced through reminders.

What to do now: a readiness checklist

To prepare for the new regime, businesses should consider:

1. Mapping all subscription and membership offerings.
2. Auditing sign‑up flows and customer‑facing terms.
3. Updating subscription wording to ensure clarity on pricing, renewal and cancellation.
4. Embedding reminder triggers into CRM or billing systems.
5. Addressing cancellation bottlenecks early.

If you would like support reviewing or updating your subscription or membership arrangements, or assessing how the new rules apply to your business model, our commercial team would be happy to assist.