We wrote in September about the subscription regime being brought forward to January 2027. The detail has now arrived. The Digital Markets, Competition and Consumers Act sets the core requirements, and the new regulations and guidance fill in how they work in practice: what has to be shown before sign-up, when reminders go out, how cooling-off works and how members must be able to cancel.
Industry bodies lobbied for a statutory grace period. The government declined. In a blog post on 14 October, the CMA said its early focus will be on helping businesses comply, but commentators have been clear that enforcement is not suspended, and egregious breaches of well-understood rules could see action from the first day.
- 14 October 2026: CMA sets out its early approach to the regime
- 19 October 2026: draft regulations laid before Parliament, guidance published
- 1 January 2027: regime applies to subscriptions entered into from this date, subject to approval
A reminder of what the CMA is already fining
On 14 October the CMA fined a London gym franchise £45,000 for advertising membership prices without the mandatory joining fee, and ordered refunds to 726 customers. That case was brought under the price transparency rules already in force, not the new subscription regime. It shows the regulator is looking at membership pricing now, and that small operators are not too small to notice.
The question is no longer what the rules say. It is whether your join, renewal and cancel journeys will follow them by January.
What to do before Christmas
- Read the guidance against your own membership types, and note where it is ambiguous for your structure so you can take advice on those points specifically
- Check that the full price, including any joining or admin fee, appears wherever a membership price is shown
- Build and test the online cancellation route in the member account area, not just the policy wording
- Set up the renewal reminder templates and the data they need, such as the renewal date, amount and how to cancel
- Agree who signs off changes, so the work is not waiting on a committee in late December
Most of this is a few weeks of focused work on the website and CRM if it starts now. Left until the January renewal run, it becomes a rush job on the most sensitive journey you have.
