On 20 November 2025 the UK government confirmed that the secondary legislation which is required to clarify and bring into force the new consumer subscription contract regime under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) [A New Era for Consumer Law and Regulation] will be delayed until autumn 2026 at the earliest. This marks a shift from the government’s earlier position that the new regime (which will impose new specific requirements on businesses offering consumers subscription contracts designed to ensure consumers understand what they are signing up to and can easily cancel) would come into force in spring 2026.
Why the delay?
The delay follows a government consultation which invited businesses to provide feedback on the new regime that closed in February 2025 [Consultation on the implementation of the new subscription contracts regime – GOV.UK]. Following an initial analysis of the responses to that consultation, the Department for Business and Trade (DBT) has written to respondents advising them that more time is required to analyse their responses and prepare a formal government response alongside an acknowledgement that businesses need more time to prepare for the new regime.
As a result, the government has announced that the new regime will not come into force until autumn 2026 at the earliest with further details of timings to be provided in the formal response to the consultation which the DBT is in the process of preparing.
Make your voice heard
This announcement reiterates that participating in government consultations on potential legislative changes is an important and cost effective way for businesses to influence potential changes affecting them – we have already seen this year the government announce that planned changes to the widely disliked Commercial Agents Regulations were being dropped as a result of a lack of responses to its consultation on those [Commercial Agents Regulations: Here to Stay] and it is clear that consultations will play an important part in future changes relating to artificial intelligence [Clock is Ticking for Responses to UK Government Consultation on Copyright and Artificial Intelligence].
Sirrul Choudhury contributed to this article