New Netflix, gym, and other subscription rules planned for the UK

The UK government has indicated that it will begin regulating subscriptions over concerns that consumers often forget what they’ve signed up for and don’t realise when contracts have renewed. This can lead to situations where they are locked into purchasing goods or services they aren’t always using for a significant period.

According to legal firm Travers Smith, the new regime is intended to ensure that consumers:

• They are given clearer information when they first sign up;
• Benefit from a cooling-off period (allowing them to withdraw if they change their minds); and
• Get periodic reminders before subscriptions are due to renew.
  

“The Government has indicated that it expects to implement the new rules in “Autumn 2026″ (it had originally stated that it would not implement before April 2026, but this was widely seen as the date the Government was aiming for),” the firm said.

“It’s also important to note that most of the other consumer law provisions of the Digital Markets, Competition and Consumers Act 2024 have been in force since April 2025 – and as noted above, the CMA is now beginning to use its new enforcement powers under the legislation.”

There are, however, still awaiting two key pieces of the regulatory jigsaw in this area:

• First, the Government needs to respond to a consultation launched in 2024 on certain detailed aspects of implementation; and

• Second, the CMA needs to issue guidance on how it expects businesses to comply with the new regime.

The firm notes that concept of a “subscription contract” under the new regime is broad.  It is defined as an agreement that provides for an automatically recurring or continuous supply of goods, services or digital content to the consumer for either an indefinite or fixed period.  

In particular, the following arrangements are – subject to the exceptions highlighted below – likely to be caught:

• A rolling monthly subscription, continuing for an indefinite period (such as a gym membership); and
  
• A 12 month subscription which auto-renews i.e. where the consumer would need to take action to stop it rolling over into a new contract at the end of the first 12 months (such as a magazine or newspaper subscription (whether digital or in print)).

Subscriptions which offer an initial free period will also be caught.  Even businesses which do not use subscriptions as part of their core offering may be caught – for example, a visitor attraction that offers annual season tickets which auto-renew.

“Although there are still areas of uncertainty, our view is that the legislation and the Government’s consultation on the detail provide enough of a steer to enable at least some meaningful planning to take place now,” the firm said.

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