On 09 August, the Prime Minister announced a series of ‘everyday fixes’ to alleviate household costs in the UK. One of these was a commitment to end subscription traps as soon as possible. Last year, we ran several webinars on a new subscription regime introduced by the Digital Markets, Competition and Consumer Act 2024 (‘DMCC’) (see our online post for more information here). The changes were due to go live in spring 2026 but then delayed by a year until April 2027.
With this latest Government announcement, the regime is now set to enter into force this coming January, but further detail as to how this will be achieved during the latter half of the 2026/2027 Parliamentary session is not yet known. With Parliament currently in summer recess, party conferences in October and the Christmas pause, it seems that work to enact the new regime will need to take place around late October/November. With both secondary legislation and Competition and Markets Authorly guidance required, much needs to be achieved. However, in short, organisations who thought they had almost 8 months to go might need to get themselves DMCC compliant that bit sooner.
Do get in touch if you’d like to understand the implications for your organisation and any legal requirements you should be preparing for.
Note – In April, the Government confirmed it had removed certain charitable memberships from the new subscription regime, described as “contracts which are between a charity and a consumer and that allow consumers to attend performances, see collections, or visit places (for example, museums, galleries, historical properties, landscapes, wildlife, performing arts) which are related to [their] charitable purpose. Charity Finance Group has identified the types of subscriptions as potentially still being caught by the new framework as: memberships or subscriptions that are purely digital in nature, professional or supporter memberships not linked to access, subscriptions operated through commercial trading subsidiaries, or hybrid arrangements offering substantial commercial benefits. We are monitoring legal developments and will provide a further update for charities and non-profits once we know more.