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 what Evidencee does for each of those obligations today.
Last updated September 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 January 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.
November 2025
First CMA consumer investigations
The CMA opens its first investigations under the new direct consumer-enforcement powers.
January 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. A cancellation journey that is harder than signing up risks breaching the rules.
14-Day Cooling-Off Period
Mandatory for all subscriptionsSubscribers have a 14-day cooling-off right when a subscription starts, when a free or discounted trial ends, and when a contract renews for 12 months or longer. You must process cooling-off refund requests promptly and evidence the decision.
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 Misleading or Fake Discounts
Banned commercial practiceAdvertising a saving against a price you never genuinely charged is banned. A “was” price must have been your real selling price for a meaningful period beforehand, a stated reduction must match the actual arithmetic, and a quoted RRP must be one the manufacturer actually recommends. Invented reference prices are 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.
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
What Evidencee does today
One platform, and a plain statement of what it does not yet check.
Pre-contract information
Pre-contract template editor; every published version is recorded in the Evidence Vault with its content hash, and Evidencee can check your live page for the block. You paste the block into your own sign-up or checkout page — Evidencee adds nothing to any checkout by itself.
Renewal notices
Configurable reminder schedules, sent through your own Resend, SendGrid, Postmark, Amazon SES or SMTP account (Mandrill is connected but not yet tested against a live account). Reminders are sent for Stripe and GoCardless brands. Shopify shows a subscription only to the app that created it, so Evidencee cannot see who is about to renew and sends no reminders for Shopify shops. Every send is logged as evidence.
Easy cancellation
Hosted cancellation page with magic-link verification. Evidencee grades the sign-up and cancel step counts you record for each channel, and flags any channel where cancelling takes more steps.
Cooling-off rights
14-day cooling-off queue. Approve a refund and Evidencee sends it through your connected Stripe or GoCardless account — built and tested against a stand-in, not yet run on a live account — or record one you paid 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)
Daily scans of your Shopify catalogue and your Stripe prices and payment links flag prices shown without tax, and — on Stripe payment links — shipping, service fees and mandatory add-ons left out of the headline price. Each finding records the source, the missing component, and the operator who resolved it.
No fake / incentivised reviews
Connect your review sources: Judge.me is verified end to end; Trustpilot, Yotpo, Loox, Okendo, Stamped and Google are connected but not yet verified against a live account. Daily scans flag bursts of reviews, near-duplicate text, repeat reviewers and ratings that contradict their own text; your team marks each finding reviewed, actioned or dismissed.
Evidence records
Every record carries a SHA-256 hash and is linked to the record before it, so a later change to any record shows. Export the records for a subscriber, a subscription, a case or a date range as one self-contained HTML bundle, sealed with a SHA-256 Merkle-root manifest.
Misleading or fake discounts — partly checked
We check the arithmetic: a stated saving that does not match the prices shown (“50% off” on a 40% reduction), or a “was” price that is not actually higher. We also check whether a “was” price on your Shopify catalogue was genuinely charged, against the price history we have recorded since August 2026. Our working test is that the “was” price must have genuinely been the selling price at some point in the last 30 days — a test we chose so the check could run, not a settled legal one — and a product with too little history shows as not yet checkable, never as a pass. We cannot check a quoted RRP at all, because no source for a manufacturer’s real RRP exists. Treat that as your own manual check.
Readiness score
19-control audit across pre-contract, reminders, cancellation parity, cooling-off, evidence logging and data retention — recomputed from your live data each time you open it, showing exactly what's passing and what needs attention.