New UK Subscription Rules Arrive in January 2027

A new UK subscription contracts regime is due to come into force in January 2027, and it will reshape how beauty boxes, clothing rental, styling services and app-based wardrobe subscriptions sign people up and let them leave. It introduces a separate pre-contract notice before you subscribe, compulsory reminders before a renewal, a new 14-day cooling-off right when a trial converts or a long contract renews, and a requirement that anything bought online can be cancelled online. As of October 2026 the secondary legislation and detailed guidance have not yet been published, so the exact commencement day is not confirmed. Here is what the regime covers and why it lands on fashion and beauty harder than on most sectors.

Why January 2027, not spring 2027

The rules sit under the Digital Markets, Competition and Consumers Act 2024. The Government’s response to its consultation on implementing the subscription contracts regime, updated on 2 April 2026, said it anticipated commencement in spring 2027.

That has since been pulled forward. Analysis published by Latham & Watkins on 14 September 2026 records that the regime “will come into force in January 2027”, bringing forward the previously anticipated spring 2027 date. The Competition and Markets Authority confirmed the same timing in a blog post published on 14 October 2026 by Emma Cochrane, its Executive Director for Consumer Protection, which states that the regime “will come into force in January” once the Government has published secondary legislation and further guidance.

No calendar date within January has been published. As of October 2026, “January 2027” is as precise as the official position gets.

What changes for the shopper

Four things, in the order you will meet them.

A separate notice before you subscribe. Businesses will have to give prescribed subscription-specific information immediately before you enter the contract, kept separate from the general pre-contract information and terms. It must cover auto-renewal, how often you will be charged, any minimum commitment, how prices may change, what reminders you will get and how to cancel. You will also have to acknowledge that placing the order creates an obligation to pay.

Reminders before renewal. You must be reminded before a subscription renews, with the timing depending on the type of subscription. Stricter rules apply where a trial converts into a paid plan, or where a renewal commits you for 12 months or more. The reminder must give you enough time to cancel, and must state the renewal date, the amount and how to cancel.

A new cooling-off right at renewal. The familiar 14-day cooling-off period when you first sign up stays. On top of that, there will be a fresh 14-day cooling-off period after a free or discounted trial ends and converts, and on renewals of 12 months or more. Businesses will have to send a separate cooling-off notice on the first day of each renewal cooling-off period, or as soon as reasonably practicable afterwards. Where the required information, reminders or cancellation facilities are not provided, you may be able to cancel and get a refund — and missing information can extend the cooling-off period.

Cancellation that actually works. Termination must be straightforward. If you signed up online, you must be able to cancel online, and you must generally be able to switch off auto-renewal at any time before the next renewal. The Government’s consultation response adds that refunds must be paid without undue delay and within 14 days of cancellation, using the same payment method unless you agree otherwise, and that terms making cancellation disproportionately difficult are prohibited.

Why this matters more in fashion and beauty

Subscription is now a default commercial model across this category, and it is usually the trial that does the selling: a £5 first box, three months at half price, a rental membership with a discounted first month, a styling service that takes a card before it takes your measurements. Those are precisely the structures the new renewal cooling-off right is aimed at.

Rental and resale add a wrinkle. The consultation response notes that refunds during the renewal cooling-off period are proportionate for services and digital content, while goods that are returnable are refunded in full. For a clothing rental membership, that distinction between a service you have partly used and an item you can send back is going to need unpicking in each provider’s terms.

The enforcement context

The CMA has had direct consumer enforcement powers since April 2025, and its October 2026 blog sets out what it has done with them. In the period since April 2026 it opened six new investigations — Ryanair, Euro Car Parks, Microsoft, Virgin Atlantic, Trainline and Red Driving School — taking the total to 20, and settled seven cases, with redress ordered of over £2.3 million and fines imposed of over £11.8 million.

Online retail is already in scope. Seven of the eight original online pricing investigations launched in November 2025 have settled, and Gold’s Gym, Wayfair and Buy It Direct together drew penalties of over £6 million and consumer redress of over £440,000.

The CMA also flags where it is heading next. It will keep targeting drip pricing and partition pricing, and online designs that obscure the true cost: the total price must be shown clearly throughout the purchase journey, discounts must be genuine, and extras must not be pre-selected. It says it is reviewing how online retailers disclose delivery fees and will update “shortly”. The Government has separately set out plans for new laws to ban mandatory hidden fees from online shopping. Fake review investigations continue into Autotrader, Feefo, Dignity, Just Eat and Pasta Evangelists.

On subscriptions specifically, the CMA says it will focus early on helping businesses comply, that this does not mean enforcement is delayed, and that conduct during that period may still be considered.

The autumn the rules land in

The timing arrives into a soft season for clothing. The BRC-KPMG Retail Sales Monitor published on 13 October 2026, covering the five weeks from 30 August to 3 October 2026, put total UK retail sales up 1.3% year on year, against 2.3% in September 2025, with non-food sales up just 0.3%.

The BRC’s Helen Dickinson said “Clothing and footwear had a weak month as unseasonally warm weather weakened demand”, helped only partly by back-to-school spending. KPMG’s Linda Ellett said fashion “faced a particularly difficult September” and suggested the prolonged summer may have delayed shoppers’ move into autumn and winter wardrobes, while the approach of Black Friday may be encouraging people to wait for discounts.

A delayed seasonal transition and a wait-for-the-discount mood are exactly the conditions in which trials and introductory offers get pushed hardest — which is worth knowing a few months before the rules governing them change.

Frequently asked questions

Does this apply to subscriptions I already have? The regime’s application to existing contracts will be set out in the secondary legislation, which as of October 2026 has not been published. Watch for the regulations and the accompanying guidance.

Will I get a refund if a free trial rolls into a paid plan? Under the new regime there will be a 14-day cooling-off period after a trial converts, with a separate notice telling you about it. Refunds are proportionate for services and digital content, and full for returnable goods.

Can a brand still make me phone up to cancel? Not where you subscribed online. The regime requires a straightforward termination process and online cancellation for contracts concluded online.

Who do I complain to? The CMA enforces the consumer protection regime directly and has the power to order redress and impose fines. Its consumer protection pages on GOV.UK are the official route for information on current investigations.