Retailers have been warned they may need to accelerate preparations for the government’s incoming subscription rules, after the implementation date was brought forward to January 2027.
The warning comes a day after plans for the new subscription protections were confirmed, with businesses now facing a shorter window than many had expected to overhaul recurring payment models, customer communications and sign-up processes.
Mills & Reeve partner and consumer law expert Katrina Anderson said the latest timetable change could leave brands that had been preparing for a spring 2027 introduction scrambling to comply.
“The date for introducing new protections against ‘subscription traps’ has already moved three times – spring 2026, autumn 2026, then spring 2027,” she said.
“This is the first time it has moved in the other direction, and the danger is that many brands planning around spring next year will have lost a quarter and will now need to fast track their compliance activities to be ready for the new deadline.”
The rules form part of a wider government push to clamp down on subscription traps, where consumers can find themselves locked into recurring payments or face unnecessary obstacles when attempting to cancel.
For retailers and other businesses using subscriptions or recurring payment models, the changes are expected to require more than alterations to customer-facing terms.
Anderson said affected companies will need to review the entire subscription journey, including the way customers sign up and the systems used to communicate with them throughout the life of their subscription.
“Businesses selling subscriptions, or anything operating on a recurring payment model, should urgently consider whether they are caught by the new regime,” she said.
“Those that are caught will need to make significant changes to their online sign-up processes and implement internal systems to ensure consumers receive the required notifications.
“There is also likely to be a need for staff training and a review of existing subscription terms and conditions.”
The tighter timetable will be particularly relevant to retailers that have expanded into membership programmes, replenishment services and other recurring revenue models as they seek to build loyalty and more predictable customer spending.
Businesses also face significant penalties if they fall foul of the requirements once the regime takes effect.
The Competition and Markets Authority will have powers to enforce the rules directly, including the ability to issue fines of up to 10% of a company’s global turnover or £300,000, whichever is higher.
Anderson said the regulator’s approach to other elements of the Digital Markets, Competition and Consumers Act suggested businesses should not expect a lengthy grace period once the rules come into force.
“The CMA has already been very active in enforcing other aspects of the DMCC Act, and we can expect a similar approach to the new subscription requirements,” she said.
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