DMCC Subscriptions: What UK businesses must do
The Digital Markets, Competition and Consumers Act 2024 introduced the most significant change to UK subscription law in decades. This guide explains what it requires and how Evidencee helps you meet every obligation.
Last reviewed March 2026 · Authoritative text: Digital Markets, Competition and Consumers Act 2024 on legislation.gov.uk. This page is for general information only and is not legal advice.
What is the DMCC Act?
The Digital Markets, Competition and Consumers Act 2024 received Royal Assent in May 2024. The bans on fake or incentivised reviews and drip pricing came into force in April 2025; the subscription-specific rules (pre-contract information, renewal reminders, easy cancellation and cooling-off) are expected to come into force in Spring 2027, once the supporting secondary legislation is finalised.
The Act was introduced in response to widespread consumer harm from subscription “traps” — businesses making it easy to sign up but difficult to cancel, hiding renewal charges, and failing to provide adequate notice before billing.
The Competition and Markets Authority (CMA) is responsible for enforcement and has made clear it will actively investigate non-compliant businesses, particularly in the e-commerce, SaaS, and media sectors.
April 2025
Consumer-protection regime in force
The CMA’s direct enforcement powers, plus the bans on fake / incentivised reviews and drip pricing, take effect.
December 2025
First CMA consumer investigations
The CMA opens its first investigations under the new direct consumer-enforcement powers.
Spring 2027 (expected)
Subscription rules expected to apply
Pre-contract information, renewal reminders, easy cancellation and cooling-off are expected to come into force, subject to secondary legislation.
Core DMCC compliance requirements
Every UK subscription business must meet these requirements. There is no minimum turnover threshold — the rules apply equally to startups and large enterprises.
Pre-Contract Information
Required before paymentBefore taking any payment, you must display a clear subscription summary including the price, what the customer gets, when payments are taken, the cancellation process, and the cooling-off rights. This information must be presented in a standardised format.
Renewal Reminder Notices
Mandatory timing rulesYou must send advance reminder notices before trial endings and annual renewals. The notice must clearly state the upcoming charge, the subscription terms, and how to cancel. Timing, content, and delivery channel are all regulated.
Easy Cancellation
Parity requirementSubscribers must be able to cancel as easily as they signed up — in a single online session, without having to speak to anyone or navigate unnecessary steps. Cancellation flows with more steps than sign-up are a direct breach.
14-Day Cooling-Off Period
Mandatory for all subscriptionsSubscribers have a 14-day cooling-off right after any subscription starts or renews. You must process cooling-off refund requests promptly and evidence the decision. Auto-refund or manual review workflows are both permitted.
Total Price Up-Front (No Drip Pricing)
Price-clarity obligationThe total price the consumer will pay — including mandatory fees, taxes, shipping, and add-on charges — must be displayed before the consumer commits to the transaction. Revealing extra costs only at checkout (drip pricing) is a banned practice under the DMCC unfair-commercial-practices regime and a stated CMA priority area.
No Fake or Incentivised Reviews
Banned commercial practiceSubmitting, commissioning, hosting, or failing to take reasonable steps to remove fake reviews and undisclosed incentivised reviews is banned. Businesses must operate review systems with adequate moderation and clear disclosure of any incentivised content.
Immutable Evidence Records
Required for CMA complianceYou must be able to demonstrate compliance if investigated. This means maintaining evidence of pre-contract disclosures, notice delivery, cancellation journeys, refund decisions, drip-pricing scan results, and review-moderation actions — with proof of integrity.
Enforcement consequences
The CMA has broad powers to investigate and penalise non-compliant businesses.
Maximum fine
10% of global annual turnover or £300,000 — whichever is higher
Investigation trigger
Consumer complaints, monitoring, or proactive CMA review
Public naming
Enforcement decisions are published on the CMA website
Business disruption
The CMA can require businesses to stop trading pending compliance
Under the DMCC Act, the CMA can impose penalties of up to 10% of global annual turnover or £300,000 — whichever is higher — for breaches of consumer-protection law.
Source: Digital Markets, Competition and Consumers Act 2024 · CMA direct consumer-enforcement guidance
How Evidencee covers every requirement
One platform. Every control. Immutable proof.
Pre-contract information
Template editor with DMCC-validated content blocks. Pre-contract records logged to Evidence Vault on every sign-up.
Renewal notices
Configurable notice schedules. Automated delivery to Shopify Email, SendGrid, or Mandrill (Mailchimp). Works with Shopify, Stripe, and GoCardless. Delivery confirmed and logged.
Easy cancellation
Hosted cancellation page with magic-link verification. Automatic parity comparison between sign-up and cancel steps. Violations flagged.
Cooling-off rights
14-day cooling-off queue. Approve a refund and it is issued through your connected payment provider — or record one you handled yourself; the money always comes from your own balance, not from Evidencee. Every decision is evidence-logged with the reference, date, timestamp, and handler.
Total price up-front (drip pricing)
Scheduled scans of your Shopify catalogue and Stripe checkout flag missing or hidden price components — taxes, shipping, add-on fees. Each finding records the source, the missing component, and the operator who resolved it.
No fake / incentivised reviews
Connect Trustpilot, Judge.me, Yotpo, Loox, Okendo, or Stamped review sources (Google in limited preview). Scheduled scans surface incentivised, paid, or duplicated patterns; reviewers triage findings as actioned, dismissed, or referred to legal.
Evidence records
Immutable event log signed with SHA-256 payload hashes and a continuous linked chain. Export a complete, regulator-ready HTML audit bundle, sealed with a Merkle-root manifest, in minutes.
Readiness score
19-control audit across all DMCC obligations. Real-time status showing exactly what's passing and what needs attention.